EPA/ROD/R01-95/112
1995
EPA Superfund
Record of Decision:
FORT DEVENS
EPA ID: MA7210025154
OU04
FORT DEVENS, MA
03/28/1995
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RECORD OF DECISION
Barnum Road Maintenance Yards, AOCs 44 & 52
EXECUTIVE SUMMARY
Fort Devens is located in Middlesex and Worcester Counties and is within the Town of Ayer,
Harvard, Lancaster and Shirley, Massachusetts. There are 73 Study Areas (SAs) and Areas of
Contamination (AOCs) at Fort Devens which are currently under investigation for potential
environmental restoration.
This Record of Decision (ROD) relates to the Barnum Road Maintenance Yards (AOCs 44 & 52). The
site is situated in the northeast corner of the Main Post near the Barnum Gate (Figure 1 of
Appendix A). This ROD sets forth the selected remedy for the Barnum Road Maintenance Yards
which addresses the contaminated surface soils and soils associated with two known releases (hot
spot areas). This decision is based on the Administrative Record which is available for public
review at the Fort Devens Base Realignment and Closure (BRAG) Environmental Office, Building
P12, Fort Devens, Massachusetts, and at the Ayer Town Hall, Main Street, Ayer, Massachusetts.
The Administrative Record Index (Appendix E) identifies the reports, correspondence and other
documentation comprising the Administrative Record upon which the selection of the remedial
action is based.
The total area of the Barnum Road Maintenance Yards is approximately 8.8 acres. The Barnum Road
Maintenance Yards are divided into two study areas which were investigated and identified as
AOCs 44 and 52 (Figure 2 of Appendix A). AOC 44 is known as the Cannibalization Yard. It is an
area where vehicles were stored before being dismantled for usable parts. AOC 44 is a
maintenance yard where vehicles are stored while awaiting repairs. It was previously known as
the TDA Maintenance Yard. Northwest of the Cannibalization yard is a separately fenced
vehicle storage yard known as the RTS Yard. An area that is fenced southeast of the main
portion of the TDA Maintenance Yard is known as the K-Yard. All four of these yards have a
long and continuing history of vehicle storage and possible crankcase releases and have been
combined as one site identified as the Maintenance Yards. The only known significant vehicle
release was an estimated 20 gallons of "mogas" (motor vehicle gasoline) and hydraulic fluid
released near the center of the Cannibalization Yard in 1985. Also, a 1,000-gallon underground
waste oil storage tank was located in the Cannibalization Yard until its removal in May 1992.
The Army conducted a series of field investigation during the 1992 to 1993 period. Site
investigations and feasibility study reports were written in 1993 detailing the investigations
performed, the nature and extent of contamination found at the Maintenance Yards, and the
potential health risks associated with the site.
In general, contamination at the Maintenance Yards consists of pollutants commonly associated
with used motor oil. Contaminants creating a potential health risk are located in the surface
soil (top two feet) at the site. Additionally, contaminants were detected in deeper soil around
the former waste oil storage tank and in the vicinity of the reported mogas spill in the
Cannibalization Yard (hot spot areas). There is no evidence that contaminants found in the
Maintenance Yard soils are affecting groundwater guality.
The Army developed seven remedial options for the Maintenance Yards in a document entitled
"Final Feasibility Study Report for Unsaturated Soils at the Maintenance Yards." This report
evaluated each of the alternatives using criteria developed by the United States Environmental
Protection Agency (USEPA) for use in the Superfund process.
Of the seven alternatives, one was chosen as the preferred alternative by the Army. State and
community acceptance, were evaluated following receipt of comments from the Massachusetts
Department of Environmental Protection (MADEP) and the public on the Proposed Plan. Details of
the preferred alternative were provided to the public in a Fact Sheet and Proposed Plan issued
on May 16, 1994. On May 24, 1994, the Army held an informational meeting at Fort Devens to
discuss the results of the field investigations and to present the Army's Proposed Plan. From
May 25 to June 24, 1994, the Army held a 30-day public comment period to accept public comments
on the alternatives presented in the Feasibility Study and the Proposed Plan. On June 15, 1994
the Army held a formal public meeting at Fort Devens to accept any verbal comments on the
preferred alternative. A transcript of this meeting and the comments and the Army's response to
comments are included in the responsiveness summary (Appendix C). The comments received by the
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community and local governments generally support the selected remedy. MADEP has reviewed the
various alternatives and formally concur with the selected remedy for the Maintenance Yards. A
copy of the declaration of concurrence is attached as Appendix D.
The selected remedy is protective of human health and the environment, attains federal and state
reguirements that are applicable or relevant and appropriate for this remedial action, and is
cost effective. This remedy satisfies the statutory preference for remedies that utilize
treatment as a principal element to reduce the toxicity, mobility, or volume of hazardous
substances. In addition, this remedy utilizes permanent solutions and innovative treatment
technologies to the maximum extent practicable.
The selected remedy includes the following components:
• Excavate surface soil (top two feet across the site),
• Excavate the two hot spot areas,
• Stockpile soils for sampling and analysis,
• Cold mix asphalt batch soils exceeding site cleanup levels of 7 ppm (average) total
carcinogenic polynuclear aromatic hydrocarbons (cPAHs) and 500 ppm total petroleum
hydrocarbon compounds (TPHC) ,
• Backfill excavations with uncontaminated stockpiled soil and apply the asphalt
batched material over the surface of the site,
• Apply a pavement wearing course for a vehicle parking surface,
• Expand the existing stormwater collection system,
• Perform groundwater monitoring,
• As a precautionary measure, institute the following deed restrictions: 1) prohibit
residential development/use of the Maintenance Yards, 2) minimize the possibility of
long-term (working lifetime) exposure to subsurface soils, and 3) reguire
management of soils resulting from construction related activities.
Site restoration is estimated to take approximately four months to complete. Estimated capital
cost for remediation is $1,865,000. Total operation and maintenance costs are estimated to be
$72,000. Total present worth cost is $1,937,000.
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RECORD OF DECISION SUMMARY
BARNUM ROAD MAINTENANCE YARDS
AREAS OF CONTAMINATION 44 & 52
MARCH 1995
I. SITE NAME, LOCATION AND DESCRIPTION
Fort Devens is a Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)
National Priorities List (NPL) site which is located in Middlesex and Worcester Counties and is
within the Towns of Ayer, Harvard, Lancaster and Shirley, Massachusetts. There are 73 Study
Areas (SAs) and Areas of Contamination (AOCs) at Fort Devens which are currently under
investigation.
The Record of Decision relates to the Barnum Road Maintenance Yards (AOCs 44 & 52). The site is
situated in the northeast corner of the Main Post near the Barnum Gate (Figure 1) approximately
one mile southwest of the Town of Ayer Route 2A/110 intersection.
The total area of the site is approximately 8.8 acres (Figure 2). The Maintenance Yards are
bordered to the north by Massachusetts Army National Guard property, which is used for similar
vehicle storage activities as the Barnum Road Maintenance Yards. Boston and Maine Railroad
property and Barnum Road border the site to the west and east, respectively. Building 3713,
located south of the site, is a 6-acre building used by the Army for vehicle maintenance
activities. The Maintenance Yards are fenced and presently used for military vehicle storage.
AOC 44 is known as the Cannibalization Yard. It is an area where vehicles are stored before
being dismantled for usable parts. AOC 52 is a maintenance yard where vehicles are stored while
awaiting repairs. It was previously known as the TDA (Table of Distribution and Allowances)
Maintenance Yard. Northwest of the Cannibalization Yard is a separately fenced vehicle storage
yard known as the RTS (Regional Training Site) Yard. An area that is fenced-off southeast of
the main portion of the TDA Maintenance Yard is known as the K-Yard. All yards show evidence of
being at least partly paved at one time. In areas where pavement is visible, the pavement has
generally been broken-up with age if not mostly disintegrated. All four of these yards have a
long and continuing history of vehicle storage; hence at the direction of the Army, they were
all included as AOCs 44 & 52 and combined as one operable unit. They are referred to
collectively in this Record of Decision (ROD) Summary as the Maintenance Yards, or the Site.
Soils in the area of the Maintenance Yards are products of glacial meltwater deposition in lake
and ice-contact environments during the final retreat of Pleistocene glaciers. The yards are
located on a kame terrace. The deposits consist of stratified sands and gravelly sands possibly
overlying till.
Groundwater in the aquifer underlying the yards has been assigned to Class I under Commonwealth
of Massachusetts regulations. Class I consists of groundwater that is designated as a source of
potable water supply. Based on 1992 Site Investigation water level survey, inferred groundwater
flow from the Maintenance Yards is northeast toward Grove Pond. The town of Ayer currently owns
and operates two water supply wells within 150 feet of the south side of Grove Pond and
approximately one-half mile from the yards (Figure 1). The wells are currently used as a backup
to the town's other supply wells on Spectacle Pond. As part of a plan for meeting future water
needs, the town of Ayer is planning to return its well source on Grove Pond to regular service.
The town engaged a consultant to establish a Zone II area of influence around the wells which is
defined as the conceptual zone of contribution to the wells under specific set of conditions
which simulate the most severe pumping and recharge conditions that can be anticipated
realistically. The report shows the Zone II area as including the Maintenance Yards (Figure 1).
The Maintenance Yards are also located approximately 1,600 to 1,700 feet from the Fort Devens
Grove Pond wellfield, which is within the default Zone II (One-half mile radius) of this Army
wellfield. Currently there is no evidence that contaminants found in the Maintenance Yards'
soils are affecting groundwater quality.
The Maintenance Yards are located approximately 1,200 feet west of Cold Spring Brook. Surface
water from the Maintenance Yards drain into part of the Fort Devens stormwater collection system
which discharges to Cold Spring Brook (Figure 3). Cold Spring Brook merges with Bowers Brook
and flows northeast into Grove Pond and then to Plow Shop Pond. Ultimately these ponds drain
into Nonacoicus Brook which flows about 1 mile northwest before its confluence with the Nashua
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River.
A more complete description of the Maintenance Yards can be found in the Site Investigation (SI)
Report, April 1993, Sections 2 and 4 of Volume I and the Feasibility Study (FS) Report, January
1993, Section 1.2.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Land Use and Response History
Fort Devens was established in 1917 as Camp Devens, a temporary training camp for soldiers from
the New England area. In 1931, the camp became permanent installation and was redesignated as
Fort Devens. Throughout its history, Fort Devens has served as a training and induction center
for military personnel and a unit mobilization and demobilization site. All or portions of this
function occurred during World Wars I and II, the Korean and Vietnam conflicts, and operations
Desert Shield and Desert Storm. The primary mission of Fort Devens is to command, train, and
provide logistical support for non-divisional troop units and to support and execute Base
Realignment and Closure (BRAG) activities. The installation also supports the Army Readiness
Region and the National Guard units in the New England area.
As a support for these activities, the Maintenance Yards on Barnum Road have had a long and
continuing history of Army vehicle storage. As a conseguence, the soils of the site have been
exposed to possible crankcase releases over a long duration. Gasoline, motor oil, and other
automotive fluids have also likely been released during vehicle dismantling operations in the
Cannibalization Yard. Individual releases are not likely to have been of significant volume,
but numerous releases during the period in which the yard has been used account for the soil
contamination problem. The only recorded significant vehicle release was an estimated 20
gallons of "mogas" motor vehicle gasoline) and hydraulic fluid released near the center of the
Cannibalization Yard in 1985 during the cannibalization process. Approximately 4 cubic yards
(cy) of visibly contaminated soils were excavated immediately and containerized by Army
personnel.
A 1,000-gallon underground storage tank (UST), formerly used to store waste oil, was located in
the Cannibalization Yard until its removal in May 1992. Visibly contaminated soil was
stockpiled, and laboratory analysis of soil samples from the bottom and one side of the tank
excavation showed total petroleum hydrocarbon compound (TPHC) concentrations of 17,600 parts per
million (ppm) and 9,780 ppm, respectively. Laboratory analysis was also conducted on a waste
oil sludge sample obtained from inside the tank. Results revealed the following levels of
semivolatile organic compounds (SVOCS) and Toxicity Characteristic Leaching Procedure (TCLP)
metals: 110 ppm naphthalene, 128 ppm bis(2-ethylhexyl)phthalate (B2EHP), 240 ppm
2-methylnaphthalene, 0.04 ppm cadmium, 0.4 ppm lead, 0.05 ppm nickel and 3.07 ppm zinc.
Analytical results did not reveal the presence of volatile organic compounds (VOCs) and
polychlorinated biphenyls (PCBs). Reportedly, the tank was observed to be in good condition
with no holes or severe corrosion. However, inspection revealed that the fill pipe was
improperly connected to the bung of the tank, allowing the pipe contents to leak at the
connection. Later in July 1992, contaminated soils surrounding the removed tank were excavated.
Laboratory tests on samples collected by the contractor from two sidewalls and stockpile
following the over excavation revealed residual TPHC concentrations ranging from 1,110 to 2,740
ppm. A total of 91 tons (an estimated 120 cy) of contaminated soils were removed from the waste
oil storage tank area in May and July and shipped off-site for treatment and reuse.
Exploratory test pits were excavated for construction of a concrete spill-containment basin in
the southeast corner of the TDA Maintenance Yard (Figure 2), in July 1991. These test pits
revealed zones of contaminated soil below the surface. TCLP analyses detected 3 to 7 micrograms
per liter (jlg/1) of benzene in leachate from the soil samples. TPHC was found at 420 to 700
ppm concentrations in surface soil samples and at 80 ppm in one sample from a 4-foot depth.
TPHC was not detected in the 8-foot-deep soil samples. In November and December 1991 the
approximate 100-foot by 160-foot proposed spill-containment basin area was excavated to begin
construction. Excavation continued until field screening (non-dispersive infrared analysis
[NDIR]) and visual observation indicated that contaminated soils had been removed. It was
possible to distinguish the contaminated ("dirty", dark brown and black sand and silt) upper
layer from the non-contaminated ("clean", reddish yellow coarse sand) lower layer. The
contaminated layer was between 8 and 12 inches thick. The uncontaminated layer extended below
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the upper layer to the construction subgrade limit throughout the spill-containment basin's
extent. Approximately 1,200 tons of soil were excavated and stockpiled. Laboratory analysis
(USEPA Method 418.1) was performed on samples from stockpiled soil. TPHC concentrations ranged
from 130 to 800 ppm. In addition, a petroleum identification analysis (ASTM D 3328) was
performed on six of the 10 stockpile samples. These samples showed a presence of a hydrocarbon
pattern in the C24 to C36 range but the pattern did not match any of the fuel standards for
gasoline, No. 2, 4, and 6 fuel oils, kerosene or motor oil/transmission fluid. The soil was
suspected to be an asphalt treated, gravel road base. Samples collected from the proposed
basin's subgrade at the bottom of the excavation contained TPHC concentrations ranging from
nondetect to 7 ppm.
A more detailed description of the site history can be found in the SI Report, April 1993,
Sections 2 and 4 of Volume I and the FS Report, January 1993, Section 1.2.
B. Enforcement History
In conjunction with the Army's Installation Restoration Program (IRP), Fort Devens and the U.S.
Army Environmental Center (USAEC; formerly the U.S. Army Toxic and Hazardous Materials Agency)
initiated a Master Environmental Plan (MEP) in 1988. The MEP consists of assessments of the
environmental statue of Sas, specifies necessary investigations, and provides recommendations
for response actions with the objective of identifying priorities for environmental restoration
at Fort Devens. AOCs (SAs) 44 & 52 were identified as potential sources of contamination in the
MEP. The MEP recommended that a record search be conducted to better define past and current
activities. It also recommended that the extent of contamination be determined by drilling soil
borings and sampling for the United States Environmental Protection Agency (USEPA) hazardous
substance list compounds and TPHC. It suggested installing monitoring wells if the deeper soils
were found contaminated.
On December 21, 1989, Fort Devens was placed on the National Priorities List under CERCLA as
amended by the Superfund Amendments and Reauthorization Act (SARA). The listing of Fort Devens
as an NPL site was a result of contamination at two other sites (VOC contamination in the
groundwater at the Shepley's Hill Landfill and metal contamination in the groundwater at the
Cold Spring Brook Landfill), and the proximity of both locations to public water supplies. A
Federal Facilities Interagency Agreement (IAG) was developed and signed by the Army and USEPA
Region I on May 13, 1991 and finalized on November 15, 1991. The IAG provides the framework for
the implementation of the CERCLA/SARA process at Fort Devens.
Under Public Law 101-510, the Defense BRAG Act of 1990, Fort Devens was selected for cessation
of operations and closure. An important aspect of BRAG actions is to determine environmental
restoration reguirements before property transfer can be considered. As a result, an Enhanced
Preliminary Assessment (PA) was performed at Fort Devens to address areas not normally included
in the CERCLA process, but reguiring review prior to closure. Although the Enhanced PA covers
MEP activities, its main focus is to determine if additional areas reguire detailed records
review and site investigation and to provide information and procedures to investigate
installation wide areas reguiring environmental evaluation. A final version of the Enhanced PA
report was completed in April 1992. No additional findings or recommendations for AOCs 44 & 52
were provided in the PA. A current total of 59 SAs have been identified and placed in 13
priority groups defined in the IAG between the Army and USEPA.
In 1992, the Department of Defense (DoD), through USAEC, initiated a SI for AOCs 44 & 52 along
with 10 other SAs in SA Groups 3, 5 and 6 at Fort Devens. The Final SI Report was issued April
1993. The purpose of the SI was to verify the presence or absence of environmental
contamination and to determine whether further investigation or remediation was warranted. In
June 1993, a supplemental SI (SSI) was conducted to fill specific data gaps identified during
the FS process. The SI and SSI met the reguirements of a Remedial Investigation in defining the
nature and extent of contamination at the Maintenenace Yards. As a result of the SI and SSI,
the Maintenance Yards SAs were designated as AOCs due to contamination detected in the
unsaturated soils. A FS was prepared to evaluate remedial action alternatives for cleanup of
the Maintenance Yards. This study identifies and screens 11 remedial alternatives and provides
a detailed analysis of seven remedial alternatives to allow the decision-makers to select a
remedy for cleanup of the Maintenance Yards. The Final FS was issued January 1994. The
Proposed Plan detailing the Army's preferred remedial alternative was issued in May 1994 for
public comment. Technical comments presented during the public comment period are included in
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the Administrative Record. A summary of these comments as well as the Army's responses, which
describe how these comments affected the remedy selection, are included in the Responsiveness
Summary, Appendix C of this document.
III. COMMUNITY PARTICIPATION
Throughout the Site's history, community concern and involvement has generally centered around
the fact that the Maintenance Yards are located in close proximity to the town of Ayer Grove
Pond wells. The Army has kept the community and other interested parties apprized of Site
activities through regular and freguent informational meetings, fact sheets, press releases and
public meetings.
The Army released a community relations plan in February 1992, that had been submitted earlier
for public review, outlining a program to address community concerns, and to keep citizens
informed about and involved in activities during remedial activities. As part of this plan, the
Army established a Technical Review Committee (TRC) in early 1992. The TRC, as reguired by SARA
Section 211 and Army Regulation 200-1, includes representatives from USEPA, USAEC, Fort Devens,
Massachusetts Department of Environmental Protection (MADEP), local officials and the community.
The committee generally met guarterly (until January 1994, when it was replaced by the
Restoration Advisory Board [RAB]) to review and provide technical comments on work products,
schedules, work plans and proposed activities for the SAs at Fort Devens. The SI and FS
Reports, Proposed Plan and other related support documents were all submitted to the TRC for
their review and comment. Additionally, AOCs 44 & 52 activity was specifically discussed at TRC
meetings held March 24, 1992, January 5, 1993, August 2, 1993 and January 26, 1994.
As part of the Army's commitment to involving the affected communities, a RAB is formed when an
installation closure involves transfer of property to the community. The RAB was formed in
February 1994 to add members of the Citizen's Advisory Committee (CAC) with current TRC members.
The CAC was previously established to address Massachusetts Environmental Policy Act
(MEPA)/Environmental Assessment issues concerning the reuse of property at Fort Devens. The RAB
consists of 28 members (15 original TRC members plus 13 new members) who are representatives
from the Army, USEPA Region I, MADEP, local governments and citizens of the local communities.
It meets monthly and provides advice to the installation and regulatory agencies on Fort Devens
cleanup programs. Specific responsibilities include: addressing cleanup issues such as land
use and cleanup goals; reviewing plans and documents; identifying proposed reguirements and
priorities; and conducting regular meetings which are open to the public. The proposed plan for
AOCs 44 & 52 was presented at the June 2, 1994 RAB meeting.
On May 16, 1994, the Army issued a fact sheet to more than 100 citizens and organizations,
providing the public with a brief explanation of the preferred alternative for cleanup of the
Maintenance Yards. It described the opportunities for public participation, and provided
details on the public comment period and public meetings to be held.
On May 16, the Army issued a press release concerning the proposed cleanup at the Maintenance
Yards, to the Lowell Sun, Worcester Telegram, Fitchburg-Leominster Sentinel & Enterprise,
Harvard Post, Public Spirit (Ayer) and Fort Devens Dispatch. During the week of June 6, 1994,
the Army published a public notice concerning the Proposed Plan and public hearing in the Public
Spirit, the Fitchburg-Leominster Sentinel & Enterprise, the Lowell Sun, and the Fort Devens
Dispatch. The Army also made the plan available to the public at the information repositories
located at the libraries in Ayer, Shirley, Lancaster, Harvard and at Fort Devens.
On May 24, 1994, the Army held an informal informational meeting at Fort Devens to discuss the
results of the field investigation and the cleanup alternatives presented in the FS and to
present the Army's Proposed Plan. This meeting also provided the opportunity for open
discussion concerning the proposed cleanup. From May 25 to June 24, 1994, the Army held a 30-day
public comment period to accept public comments on the alternatives presented in the FS and the
Proposed Plan and on other documents released to the public. On June 15, 1994 the Army held a
formal public meeting at Fort Devens to discuss the Proposed Plan and to accept any verbal
comments from the public. A transcript of this meeting and the comments and the Army's response
to comments are included in the attached responsiveness summary (Appendix C).
All supporting documentation for the decision regarding the Maintenance Yards is placed in the
Administrative Record for review. The Administrative Record is a collection of all the
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documents considered by the Army in choosing the remedy for the Maintenance Yards. On May 27,
1994 the Army made the Administrative Record available for public review at the Fort Devens BRAG
Environmental Office, and at the Ayer Town Hall, Ayer, Massachusetts. An index to the
Administrative Record was available at the USEPA Records Center, 90 Canal Street, Boston,
Massachusetts and is provided as Appendix E.
IV. SCOPE AND ROIiE OF THE RESPONSE ACTION
The remedy selected for the Maintenance Yards will provide protection of human health and the
environment by reducing the toxicity and mobility of carcinogenic polynuclear aromatic
hydrocarbons (cPAHs) and TPHC in the surface soil (top two feet) and mogas spill and waste oil
storage tank soils (referred to in this ROD as hot spot area soils) through on-site treatment.
The selected remedy also minimizes the potential migration of contamination to the groundwater,
reduces the potential of off-site runoff of contaminants to the Cold Spring Brook wetlands, and
provides environmental monitoring of groundwater for a period of five years following
remediation. The remediation of the Maintenance Yards will not adversely impact any future
response actions at the Maintenance Yards should they be reguired.
This remedial action will address the threat to human health posed from long-term exposure to
contaminated surface soils at the Maintenance Yards and remove known hot spot areas at the site.
V. SUMMARY OF SITE CHARACTERISTICS
Section 1.0 of the FS contains an overview of the SI and SSI performed at the Maintenance Yards.
In 1992, the USAEC initiated a SI for the Maintenance Yards along with 10 other SAs in SA Groups
3, 5 and 6 at Fort Devens. Field investigations were conducted from May to October 1992.
During the preparation and regulatory review of the FS, specific data gaps were identified which
reguired supplemental field investigation and data gathering. As a result, a SSI was conducted
in June 1993. The significant findings of the SI and SSI regarding soil, groundwater and
surface water and sediment are summarized in the following paragraphs.
A. Soil
1. SI Results
The Maintenance Yards are located on a kame terrace. Soil data from borings in these yards
indicate that the soil in the area is generally clean sand with variable gravel and silt
content. Grain-size analysis for soils encountered during the drilling program at the
Maintenance Yards reveal a gravel content ranging between 4 and 23 percent; a sand content
ranging between 74 and 93 percent; and a fine content (percent passing the #200 sieve) ranging
between 2 and 19 percent.
During the SI, 16 soil borings were advanced to observe and sample soils throughout the
Maintenance Yards (Figure 4). One of these borings, G3M-92-04X, was converted to a monitoring
well. Soil samples were collected at the 0- to 2-foot, 5- to 7-foot and 10- to 12-foot depths.
(Except G3M-92-04X where samples were collected at 0- to 2-foot, 12- to 14-foot, and 26- to
28-foot depths.) The SI focused on sampling soil for analysis of a variety of organic and
inorganic analyses and for TPHC. Tables 1 and 2 present the laboratory results for organic
compounds from each of the 16 soil borings. Tables 3 and 4 present the results for inorganic
analyses. Figures 5, 6, and 7 show the distribution of total VOCs, SVOCs and TPHC in soils
collected at the three depth intervals. Figures 8, 9 and 10 show the distribution of total
cPAHs, total polynuclear aromatic hydrocarbons (PAHs) and total SVOCs at the same three depth
intervals. Figures 11, 12, and 13 show the distribution of inorganic analyses at the three
depth intervals exceeding calculated background concentrations for typical Fort Devens soils.
Aromatic VOCs (ethylbenzene, toluene and xylenes at maximum concentrations of 0.5 ppm, 0.05 ppm,
and 4.0 ppm, respectively) were detected in three out of a total of 48 soil samples. One of the
three samples was from boring 44B-92-06X, which is believed to be associated with the 1985 mogas
spill. There appears to be no obvious lateral or vertical distribution pattern of VOCs in soil.
SVOCs, predominantly PAHs, were detected in 34 of 48 samples throughout the Maintenance Yards.
Carcinogenic PAH concentrations ranged from nondetect to 220 ppm. SVOC concentrations are
typically higher in surface samples and are generally absent or of lower concentration with
depth. TPHC appears to mimic the vertical distribution of SVOCs. The average TPHC
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concentrations across the site at the 0- to 2-foot, 5- to 7-foot and 10- to 12-foot ranges are
315 ppm, 52 ppm and 33 ppm, respectively. Maximum concentrations are 1210 ppm, 170 ppm and 119
ppm, respectively. These values exclude the TPHC concentrations at boring 44B-92-06X (that may
be associated with the mogas spill) and TPHC concentrations associated with the waste oil UST.
No lateral distribution pattern for SVOCs or TPHC is evident. No chlorinated solvents were
detected.
Generally, the same vertical trend in concentrations found for the SVOCs and TPHC appears to
exist with the inorganic analytes (i.e., higher concentrations of inorganic analytes are found
near the ground surface). Soils near the surface exhibit inorganic analyte concentrations
generally two to three times higher than soils at 5-foot and 10 foot depths. Chromium, copper,
nickel, zinc, sodium and beryllium are analytes that show a pattern of consistent exceedances
above background concentrations. The appearance of chromium, copper, nickel and zinc in almost
all surface soil samples could be the result of vehicle maintenance activity. Sodium is likely
attributable to road salting. Beryllium occurs on a more random basis (in instances at higher
concentration at greater depth) and is believed to be naturally occurring. Surface soils that
appear to contain the most inorganic analytes were found at sampling locations 44B-92-06X,
44B-92-01X, 52B-92-01X and 52B-92-06X.
Motor oil is a potential source of the organic and inorganic analytes detected. Cutting and
welding activities may be an additional source of the inorganic analytes associated with metal
alloys. The potential routes of contaminant migration which could occur at the Maintenance
Yards include downward migration via precipitation infiltration to the groundwater and by
stormwater discharge via the stormwater collection system to Cold Spring Brook (Figure 3).
Sampling of groundwater and Cold Spring Brook surface water and sediments was performed as part
of the SI and SSI to assess these potential migration routes. A summary of these sampling
results are discussed in later paragraphs in this section.
2. SSI Results (Hot Spot Area Investigation)
Defining the vertical and horizontal extent of contamination around the former underground waste
oil tank and spill areas was reguired to better assess the remedial alternatives to be evaluated
in the FS. Although soil removal actions have taken place around the excavated tank, the extent
(specifically depth) of remaining contamination was not readily defined due to the lack of
conclusive analytical data at the time of the soil over-excavation. The horizontal and vertical
extent of contamination from the mogas spill was unknown except perhaps in the vicinity of
existing boring 44B-92-06X. This boring may have been located only at the periphery of the
spill or not in the spill area at all. An Army Pollution Incident Report located the mogas
spill closer to the center of the Cannibalization Yard.
The SSI entailed drilling a total of four borings, (44B-93-07X, -08X, -09X and -10X), in the
Cannibalization Yard in the vicinity of the excavated underground tank area and mogas spill area
(Figure 14) and then sampling soil from these borings to better define the extent of
contamination. Soil analyses were conducted for inorganics (only lead in 44B-93-09X and -10X)
SVOCs, TPHC, and PCBs. Table 5 presents the laboratory results for organic and inorganic
compounds for each of the four borings. Figures 15 through 18 show the distribution of SVOCs,
TPHC, PCBs and inorganics at four depth intervals (5, 10, 15 and 25 feet below ground surface
[bgs]).
TPHC was detected in only two of 16 samples; 121 ppm in boring 44B-93-08X at 10 feet bgs and
38.1 ppm in boring 44B-93-09X at 5 feet bgs. Boring 44B-93-08X is located near the southeast
end of the excavated UST. The TPHC detected at the 10-foot level generally corresponds with the
location of the tank bottom and is likely due to residual contamination from the excavated UST.
Boring 44B-93-09X is located in the Cannibalization Yard approximately 25 feet north of the area
where the mogas spill was suspected of occurring. The duplicate of this sample revealed a
concentration below the detection level (29.6 ppm). It is not conclusive if this detected
concentration is a result of the mogas spill. The only SVOC compounds detected were B2EHP at
1.4 ppm in 44B-93-09X at the 25-foot depth and trace concentrations of fluoranthene,
phenanthrene and pyrene (0.25, 0.09, and 0.12, respectively) in 44B-93-09X at the 5-foot depth.
The duplicate of the 5-foot depth sample revealed concentrations below detection level for these
PAHs.
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Inorganics which exceed background concentrations include arsenic, beryllium, copper, nickel and
sodium. Of these analytes, only arsenic is a typical constituent of used automotive oil.
Nickel was also detected in a waste oil sludge sample taken from the UST. These five inorganic
analytes are present in the mogas spill and waste oil storage tank area soils at concentrations
which are the same order of magnitude above background as detected on an AOCs 44 and 52
site-wide basis.
B. Groundwater
1. SI Results
During the SI, seven monitoring wells were installed (one in the TDA Maintenance Yard, as shown
in Figure 4). Well locations were selected to provide circumferential coverage of the Group 3
Sas and to provide for evaluation of the Maintenance Yards impact on groundwater. Groundwater
at well location G3M-92-04X, located in the TDA Maintenance Yard, is approximately 28.5 feet
bgs. Monitoring wells were sampled in July 1992 and October 1992. Only chloroform was detected
in the samples collected from monitoring well G3M-92-04X. The chloroform is likely to be a
laboratory contaminant since it was also detected in half of the method blanks at a similar
concentration. Of the inorganic analytes detected, only manganese was detected at a
concentration above its drinking water standard. However, only a secondary Maximum Contaminant
Level (MCL) exists for manganese. No health-based drinking water standard exists for this
analyte. Based on groundwater sampling conducted during the SI, there is no evidence that
contaminants found in Maintenance Yards soils are affecting groundwater guality.
2. SSI Results
The need to investigate groundwater directly downgradient of the former waste oil tank and mogas
spill was discussed during a draft FS review meeting held at Fort Devens on May 5, 1993. During
the meeting it was suggested that the existing wells located in and around the area of the
Maintenance Yards may not be positioned to readily detect the full impact of the tank and spill
contamination sources on the groundwater.
To assess groundwater conditions near these two potential contamination sources, two additional
groundwater monitoring wells, G3M-93-10X and -11X, were installed downgradient of the removed
underground waste oil storage tank and mogas spill in the Cannibalization Yard, respectively
(Figure 14). Table 6 presents the results for two rounds of sampling from these monitoring
wells for organic and inorganic analytes. Analysis was performed for VOCs, SVOCs, TPHC,
inorganics and total suspended solids (TSS). Figure 19 shows the distribution of organic and
inorganic analytes detected in these two wells.
Results from Round 1 (June 1993) show no detectable concentrations of TPHC or VOCs present. The
only organic contaminant detected was B2EHP at 22 ]lg/l in G3M-93-10X. Historically, B2EHP has
been found to be a lab contaminant. Inorganic contaminants generally exceeded background
concentrations, but are likely due to suspended particulates and are not representative of
groundwater quality at that location. TSS for G3M-93-10X and -11X were 206 and 1,110 milligrams
per liter (mg/1), respectively.
In Round 2 (September 1993), trace concentrations of toluene (2.6 ]lg/l and 1.25 ]lg/l in
G3M-93-10X and -11X, respectively) and tetrachloroethene (2.6 ]lg/l in G3M-93-10X) were detected
in the groundwater. Concentrations for both these analytes are below state and federal MCLs for
drinking water. The exact source of these compounds is unknown but they are not believed to be
derived from soils at the Maintenance Yards. No tetrachloroethene was detected in soil samples
from borings upgradient or in the vicinity of G3M-93-10X, or in any other soil samples collected
at the Maintenance Yards. Sludge samples from the excavated UST upgradient of G3M-93-10X were
free of VOC contaminants. Trace concentrations of toluene (0.05 ppm and lower) were detected in
only three of 67 soil samples collected in the Maintenance Yards during the SI and SSI. No
toluene was detected in soil samples collected below 5 feet in depth. As in Round 1, inorganic
contaminants in Round 2 unfiltered samples generally exceeded background concentrations but are
due to suspended particulates and are not representative of groundwater guality at that
location. Only sodium exceeded background concentration in filtered samples (13,800 and 16,800
]lg/l for G3M-93-10X and -11X respectively) and is likely due to use of road salt. Detected
concentrations of sodium are below state and federal guidelines for drinking water. Based on
the sampling results from these two wells and the sampling conducted in the SI for the Group 3
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area, there is no evidence that contaminants associated with the hot spot areas or those found
in other areas of the Maintenance Yards have adversely affected groundwater quality.
C. Cold Spring Brook Surface Water and Sediment
During the SI, surface water and sediment samples were collected from Cold Spring Brook to
assess potential contaminant migration from the Group 3 SAs. No organic compounds were detected
in surface water and few inorganic analytes were detected. Sediment samples exhibited some
organic compound contamination. The results of sediment sampling support the conclusion that
contaminant migration via storm and surface water runoff is a possible source of sediment
contamination in Cold Spring Brook. However, it is not possible to conclude if the organic
compounds detected in the downstream sediment sample are specifically derived from the
Maintenance Yards or some other location serviced by the same stormwater collection system.
Figure 3 shows the stormwater drainage system layout for the Maintenance Yards. Cold Spring
Brook sediments are outside the scope of this operable unit. The Army is addressing sediment
issues under Area Requiring Environmental Evaluation (AREE) 70 Storm Water Discharge System.
A complete discussion of site characteristics can be found in the SI Report, April 1993, Section
4, Volume I and the FS Report, January 1994, Section 1.
VI. SUMMARY OF SITE RISKS
A Quantitative Human Health Risk Evaluation and a Preliminary Ecological Risk Evaluation were
performed to estimate the probability and magnitude of potential adverse human health and
environmental effects from exposure to contaminants associated with the Maintenance Yards. The
results of the Quantitative Human Health Risk Evaluation and Preliminary Ecological Risk
Evaluation for the site are discussed in the following subsections. Subsection A discusses the
general approach and assumptions used in performing the baseline risk assessment. Subsection B
discusses the results of the baseline risk assessment. Subsection C discusses the ecological
risk evaluation.
A. Baseline Risk Assessment Approach and Assumptions
The human health risk assessment followed a four step process: 1) contaminant identification,
which identified those hazardous substances that, given the specifics of the site were of
significant concern; 2) exposure assessment, which identified actual or potential exposure
pathways, characterized the potentially exposed populations, and determined the extent of
possible exposure; 3) toxicity assessment, which considered the types and magnitude of adverse
health effects associated with exposure to hazardous substances, and 4) risk characterization,
which integrated the three earlier steps to summarize the potential and actual risks posed by
hazardous substances at the site, including carcinogenic and non-carcinogenic risks.
Thirty-seven contaminants of concern, listed in Table 7 and 8 (for surface and subsurface soils,
respectively) of this ROD were selected for evaluation in the risk assessment. These
contaminants constitute a representative subset of the more than 43 contaminants identified at
the Maintenance Yards during the SI. The 37 contaminants of concern were selected to represent
potential site-related hazards based on toxicity, concentration, frequency of detection, and
mobility and persistence in the environment. A summary of the health effects of each of the
contaminants of concern can be found in the risk evaluation detailed in the SI Report, Section
4, Volume I and the FS Report, Section 1.
Potential human health effects associated with exposure to the contaminants of concern were
estimated quantitatively through the development of the following hypothetical exposure
pathways:
• Exposure to soil associated with crankcase releases (across the Maintenance Yards)
considering:
>• Ingestion/dermal contact/inhalation with surface and subsurface soil by
construction workers;
>• Ingestion/dermal contact with surface soil by long-term workers;
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• Exposure to soil associated with the mogas spill (localized in the Cannibalization
Yard) considering ingestion/dermal contact with surface and subsurface soils by
construction workers.
These pathways were developed to reflect the potential for exposure to hazardous substances
based on the present uses, potential future uses, and location of the Maintenance Yards. The
site has a long history of vehicle storage and repair and will continue to be used for this
purpose until the yards close. (During the development of the FS, the Army was projecting that
the yards would be closed in the summer of 1996. However, due to recent redevelopment
interests, this schedule may be accelerated and the Army could vacate the yards by early 1995).
Following closure of the Maintenance Yards, the site and surrounding area is expected to remain
commercial/industrial property based on Fort Devens Federal Land Disposition plans by the
Massachusetts Government Land Bank. Reuse possibilities of the yard and adjacent Building 3713
being investigated include development of a rail yard with railroad car refurbishing facility.
The area directly south of Building 3713 (DOL vehicle maintenance building) is anticipated to
become part of the Devens Inland Port due to proximity to the railway. The following is a brief
summary of the exposure pathways evaluated. For each pathway evaluated, an average and a
reasonable maximum exposure estimate was generated corresponding to exposure to the average and
the maximum concentration detected in that particular medium. A more thorough description can
be found in the human health risk evaluation detailed in the SI Report, Section 4, Volume I and
the FS Report, Section 1.
1. Crankcase Releases
Under current and future use, it is possible that a worker could be exposed to chemicals
detected in soil if excavation were to occur. This might occur for utility repair or new
building construction. It is also possible that an employee of Building 3713 could contact
contaminants in surface soil during an activity such as grounds maintenance.
For the construction worker exposure scenario, it was assumed that a construction worker would
be exposed to surface and subsurface soils (to a depth of 10 feet) for a period of three months
(five workdays for 12 weeks). It was further assumed that the worker would be exposed through
direct contact with the chemicals on his arms and hands and through the incidental ingestion of
soil particles.
For the long-term worker exposure scenario, it was assumed that an employee of Building 3713
could be exposed to chemicals in the surface soil (to a depth of 2 feet) in the Maintenance
Yards for a working lifetime of 25 years (250 days/year). As for the construction worker
scenario, it was assumed that the worker would be exposed through direct contact on his arms and
hands and incidental ingestion.
To evaluate the impact of inhalation exposure, the construction worker receptor was also
evaluated for potential exposures to surface and subsurface soil contaminants (to a depth of 10
feet) via the inhalation of particulates raised during construction activities. It was assumed
that contaminant concentrations in airborne particulates would be eguivalent to the
concentrations (arithmetic average) of contaminants in surface and subsurface soil. A range of
potential Exposure Point Concentrations (EPCs) in air was then calculated. First, it was
assumed that the respirable particulate concentration (PM10) in the air was egual to the
National Ambient Air Quality Standard (NAAQS) of 50 jig per cubic meter (]lg/m3) annual
arithmetic mean concentration. Second, a reasonable air upper-bound EPC was calculated by
assuming that the PM10 concentration was egual to 150 jlg/m3, the NAAQS maximum concentration
for a 24-hour period not to be exceeded more than once per year. Using the calculated air
contaminant EPCs that construction workers were assumed exposed to for the entire exposure
duration, and an inhalation rate of 2.5 m3 per hour (or 20 m3 per day divided by an 8-hour
workday), risks were evaluated for the particulate inhalation pathway. Toxicity constants (i.e.,
inhalation cancer slope factors, and inhalation reference concentrations) were obtained from the
USEPA Integration Risk Information System (IRIS) or USEPA's Health Effects Assessment Summary
Tables (HEAST). Inhalation toxicity constants were used if available. Chemicals lacking
inhalation slope factors or reference concentrations were evaluated using oral slope factors or
oral reference doses as surrogate values. As with the other exposure routes (direct contact and
incidental ingestion), a construction worker was assumed to inhale particles five days per week
for a three month-long construction project.
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The site worker receptor was not evaluated for the particulate inhalation pathway. Normal site
worker activities are unlikely to raise dust in amounts or for periods of time which would
result in significant exposures. Therefore, risks from the particulate inhalation pathway under
exposure scenarios that do not include dust-producing activities can be expected to be
insignificant compared to risks from other soil exposure pathways, and have not been quantified.
2. Mogas Spill
Under current and future use, it is possible that a worker could be exposed to chemicals
detected in soil if excavation were to occur in the mogas spill area. This might occur for
utility repair or new building construction. Because of the limited extent of this spill
(represented by sampling location 44B-92-06X), long-term, repeated exposure is considered to be
unlikely. Therefore, worker exposure that would be chronic in duration was not evaluated.
It was assumed that a construction worker would be exposed to chemicals in the surface and
subsurface soil in the area of the mogas spill for a period of three months (5 workdays for 12
weeks). This represents a conservative assumption because repeated exposure to soil in this
particular area is unlikely. It was further assumed that the worker would be exposed through
direct contact with the chemicals and through the incidental ingestion of soil particles. The
maximum concentration detected at any depth at sampling location 44B-92-06X was selected to
represent the EPC. Most of the residual contamination associated with the mogas release was
detected and reported as TPHC. This is consistent with the composition of mogas, a high-octane
leaded gasoline. Because no dose-response value exists with which to evaluate the toxicity of
TPHC, a surrogate dose-response value was used, that of gasoline. Details of this evaluation
are covered in SI Report, Section 4, Volume I.
B. Baseline Risk Assessment Results
Excess lifetime cancer risks were determined for each exposure pathway by multiplying the
exposure level with the chemical-specific cancer factor. Cancer potency 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 risk predicted. The resulting risk estimates are expressed in
scientific notation as a probability (e.g., 1 x 10-6 for 1/1,000,000) and indicate (using this
example), that an average individual is not likely to have greater that a one in a million
chance of developing cancer over 70 years as a result of site-related exposure as defined to the
compound at the stated concentration. Current USEPA practice considers carcinogenic risks to be
additive when assessing exposure to a mixture of hazardous substances. Two standard approaches
are commonly used for estimating cancer risks for cPAHs. The first and more conservative is the
benzo(a)pyrene [B(a)P] approach. Cancer risk estimates are made assuming that all cPAHs are as
potent as benzo(a)pyrene. This standard approach was the method used by USEPA Region I at the
time that the risk estimates for the Maintenance Yards were developed. The second method is the
toxic equivalency factor (TEF) approach which utilizes TEFs to convert each cPAH's concentration
to an equivalent concentration of benzo(a)pyrene thereby establishing a potency relative to
B(a)P, which is the method which has been recently adopted for use by USEPA Region I.
The hazard index was also calculated for each pathway as USEPA's measure of the potential for
non-carcinogenic health effects. A hazard quotient is calculated by dividing the exposure level
by the reference dose (RfD) or other suitable benchmark for non-carcinogenic health effects for
an individual compound. Reference doses have been developed by USEPA to protect sensitive
individuals over the course of a lifetime and they reflect a daily exposure level that is likely
to be without an appreciable risk of an adverse health effect. RfDs are derived from
epidemiological or animal studies and incorporate uncertainty factors to help ensure that
adverse health effects will not occur. The hazard quotient is often expressed as a single value
(e.g., 0.3) indicating the ratio of the stated exposure as defined to the RfD value (in this
example, the exposure as characterized is approximately one-third of an acceptable exposure
level for the given compound). The hazard quotient is only considered additive for compounds
that have the same or similar toxic endpoint and the sum is referred to as the hazard index
(HI). (For example: the hazard quotient for a compound known to produce liver damage should
not be added to a second whose toxic endpoint is kidney damage).
Tables 9 through 16 depict the carcinogenic and non-carcinogenic risk summary for the
contaminants of concern for each exposure pathway previously described for the Maintenance
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Yards.
1. Crankcase Releases
Risk estimates made under a construction worker exposure scenario for crankcase releases at the
Maintenance Yards fell within the USEPA Superfund target risk range of 1E-4 to 1E-6 excess
cancer risk for carcinogens and a target HI of 1. The cancer risk estimates ranged from 4E-6 to
5E-5, assuming exposure to AOC average and maximum concentrations (in soil to a depth of 10
feet). Impacts from inhalation exposure were determined to be negligible. The carcinogenic
risks from inhalation ranged from 3E-8 to 8E-8 at the ambient particulate limits of 50 and 150
jlg/m3, respectively. The hazard indices ranged from 0.04 to 0.1. These risks are well within
USEPA Superfund target risk limits.
Risk estimates made under a long-term worker exposure scenario exceeded the USEPA Superfund
target risk range of 1E-4 to 1E-6 excess cancer risk for carcinogens. The cancer risk estimates
ranged from 4E-3 to 7E-4, assuming exposure to AOC maximum and average concentrations (in soil
to a depth of 2 feet).
The chemicals that contribute most significantly to carcinogenic risk are cPAHs, arsenic, and
beryllium. (Although the cancer risk associated with long-term exposure to arsenic is 1.3 x
10-5, the average concentration of arsenic in surface soil across the Maintenance Yards [14 ppm]
is below the base-wide calculated background concentration of 21 ppm. As discussed in the SI
Report, beryllium does not appear to be related to Army activity and is probably naturally
occurring.) The hazard indices for both exposure scenarios are below or approximate 1.
2. Mogas Spill
Risk estimates made under a construction worker exposure scenario for the mogas spill in the
Cannibalization Yard fell within the acceptable USEPA Superfund target risk range of 1E-4 to
1E-6 excess cancer risk for carcinogens. The cancer risk estimate was calculated to be 2E-6,
assuming exposure to the maximum concentration found at sampling location 44B-92-06X. The HI
was estimated at 1.9. The chemicals that contribute most significantly to the HI are arsenic
(HI = 0.8) and TPHC (HI = 0.7). Following USEPA risk assessment guidance, when an HI exceeds
1.0, it is appropriate to consider the toxicological endpoints upon which the non-carcinogenic
hazards are based and the target organs for toxicological effects. Hazard indices for
individual compounds should properly be added together only if the toxicological endpoints or
mechanisms of action of the compounds are similar. In the case of arsenic and TPHC, their
toxicological effects would be expected to differ. The dose/response value for arsenic is based
on effects to the skin (i.e., hyperpigmentation and keratosis) while the dose/response value for
TPHC (gasoline) is based on reduction in body weight gain. The toxicity of gasoline is
attributed primarily to Central Nervous System effects. Because the toxicological endpoints of
concern for arsenic and TPHC are different, it is inappropriate to add their hazard indices
together. Therefore, based on this consideration, the noncarcinogenic HI would be less than
1.0.
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected in this ROD, may present an imminent and substantial
endangerment to public health and welfare. Specifically, current or future exposure to the
surface soils for a working lifetime poses a threat to human health. Therefore, based on
estimated human health risk, the remedial method focuses on treatment of, and/or minimizing
exposure to contaminants within the top two feet such that the cancer risk estimates fall within
USEPA Superfund target risk range. Contaminants which drive the risk in the top two feet of
soil are predominantly cPAHs. Arsenic and beryllium also are carcinogenic compounds but only
contribute approximately 5 percent to the cancer risk estimate and are believed to be naturally
occurring. Therefore, based on estimated risk, remedial methods will focus on the organic
contaminants present, primarily cPAHs.
C. Ecological Risk Evaluation
A preliminary ecological risk evaluation was performed for the Maintenance Yards. It was
concluded that no significant habitat for resident or migratory ecological receptors occur at
the site, and no rare or endangered species are known to occur in the vicinity of the
Maintenance Yards. The Maintenance Yards are typically filled with parked heavy eguipment
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vehicles and are surrounded by fence. The sites are devoid of any woody or herbaceous
vegetation. Based on the lack of ecological exposure pathways, no comparison of surface soil
analytes to protective contaminant level (PCL) reference values was conducted.
In conclusion, based on this evaluation, it is not likely that the contaminants found within the
Maintenance Yards will impact ecological receptors at the site. Potential risks for exposure
to surface water and sediments in the portion of Cold Spring Brook adjacent to this general area
are being evaluated as part of the AREE 70 evaluation.
VII. DEVELOPMENT AND SCREENING OF ALTERNATIVES
A. Statutory Requirements/Response Objectives
Under its legal authorities, the Army's primary responsibility at Superfund sites is to
undertake remedial actions that are protective of human health and the environment. In
addition, Section 121 of CERCLA establishes several other statutory reguirements and
preferences, including: a reguirement that the remedial action, when complete, must comply with
all federal and more stringent state environmental standards, reguirements, criteria or
limitations, unless a waiver is invoked; a reguirement that a remedial action be cost-effective
and utilize permanent solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable; and a preference for remedies in which treatment
which permanently and significantly reduces the volume, toxicity or mobility of the hazardous
substances is a principal element over remedies not involving such treatment. Response
alternatives were developed to be consistent with these Congressional mandates.
Based on preliminary information relating to types of contaminants, environmental media of
concern, and potential exposure pathways, remedial action objectives were developed to aid in
the development and screening of alternatives. These remedial action objectives were developed
to mitigate existing and future potential threats to public health and the environment. The
response objectives are:
1. Minimize direct contact/ingestion and inhalation with surface soils at the Maintenance
Yards which are estimated to exceed the USEPA Superfund target range of 1E-4 to 1E-6
excess cancer risk for carcinogens.
2. Reduce off-site run-off of contaminants that might result in concentrations in excess
of ambient surface water guality standards and in background concentrations in
sediments.
3. Reduce or contain the source of contamination to minimize potential migration of
contaminants of concern which might result in groundwater concentrations in excess of
the MCLs.
B. Technology and Alternative Development and Screening
CERCLA and the National Contingency Plan (NCP) set forth the process by which remedial actions
are evaluated and selected. In accordance with these reguirements, a range of alternatives was
developed for the site.
The FS developed a range of alternatives in which treatment that reduces the toxicity, mobility,
or volume of the hazardous substances is a principal element. This range included an
alternative that removes or destroys hazardous substances to the maximum extent feasible,
eliminating or minimizing to the degree possible the need for long-term management. This range
also included alternatives that treat the principal threats posed by the site but vary in the
degree of treatment employed and the guantities and characteristics of the treatment residuals
and untreated waste that must be managed; alternatives that involve little or no treatment but
provide protection through engineering or institutional controls; and a no action alternative.
As discussed in Sections 3 and 4 of the FS, the FS identified, assessed and screened
technologies and process options based on implementability, effectiveness and cost. Over 20
technologies were determined to be potentially applicable to meet the remedial response
objectives. This assessment retained certain technologies and process options which led to the
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assembly of a number of remedial alternatives. Section 5 of the FS identified, evaluated and
screened 11 remedial alternatives based on implementability, effectiveness and cost, as
described in Section 300.430 (e) (4) of the NCP. From this screening process, seven remedial
alternatives were retained for detailed analysis. Table 17 identifies the seven alternatives
that were retained through the screening process, as well as those that were eliminated from
further consideration.
VIII. DESCRIPTION OF ALTERNATIVES
This Section provides a narrative summary of each alternative as evaluated in the FS. Eleven
alternatives were initially developed in the FS Report. Of the 11 alternatives, seven were
retained in the FS screening step and were evaluated in detail. The seven alternatives are
summarized below. Time and cost for completion of each Alternative as reported in the FS was
based on the Army occupying the Maintenance Yards until the summer of 1996. A detailed tabular
assessment of each alternative can be found in Table 7-1 of the FS Report.
A. Alternative 1: No-Action
• Groundwater and stormwater/sediment monitoring.
The No Action Alternative involves sampling of groundwater monitoring wells and
stormwater catch basins located within and downgradient of the Maintenance Yards. There is no
data indicating that off-site migration of contaminants is a problem at the Maintenance Yards.
However, as a conservative measure, sampling of groundwater from six existing wells and
stormwater/sediment from the two catch basins located in the Maintenance Yards would be
performed yearly for a five-year period to monitor for any potential migration of contaminants,
even though such migration is not likely. Analytes tested would be those tested in the SI
(ABB-ES, 1993) for the Maintenance Yards. The No Action Alternative does not involve remedial
actions to control migration of contaminants or institutional controls to prevent exposure to
contaminated soils within the Maintenance Yards. As reguired by CERCLA, Alternative 1 is
developed to provide a baseline for comparison with the other remedial alternatives.
Estimated Time for Restoration: not applicable
Estimated Capital Costs: $0
Estimated Operation and Maintenance Costs: $133,000
(net present worth)
Estimated Total Costs: $133,000
(net present worth, assuming 10 percent discount rate)
B. Alternative 2: Fencing/Asphalt Batching Hot spot Areas
• Excavate hot spot areas,
• Asphalt batch hot spot area soils on site,
• Maintain fencing around the Maintenance Yards and implement deed and land use
restrictions, and
• Groundwater and stormwater/sediment monitoring.
This alternative includes preventing access by maintaining fencing around the site that would
prevent access thereby minimizing potential exposure pathways. Deed restrictions would act as
an institutional control to ensure that the fence remained intact in the future. Excavation and
cold mix asphalt batching soil from the hot spot areas in the would reduce the volume of
contaminants present in the highest concentrations at the Maintenance Yards. Sampling and
analysis of groundwater, stormwater and sediments as discussed in Alternative 1 would also be
performed as a conservative measure to monitor for off-site migration.
The location-specific applicable or relevant and appropriate reguirement (ARAR) identified for
this alternative regarding wetlands protection will not be met if contaminants from the
Maintenance Yards are currently migrating off-site via the stormwater system. This alternative
will not reduce potential off-site runoff of contaminants in surface water from the Maintenance
Yards to the wetlands. Alternative 2 would not comply with chemical-specific risk-based values
because the remediation would not reduce contaminant concentrations to these levels.
Remediation would limit exposure to these chemicals.
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Estimated Time for Restoration: Approximately three weeks for treatment; restoration completed
prior to closing of the Maintenance Yards
Estimated Capital Costs: $204,000
Estimated Operation and Maintenance Costs: $152,000
(net present worth)
Estimated Total Costs: $356,000
(net present worth, assuming 10 percent discount rate)
C. Alternative 3: Capping Bite/Asphalt Batching Hot Spot Areas
• Excavate hot spot areas,
• Asphalt batch hot spot area soils on site,
• Cap entire site with asphalt pavement and implement deed and land use restrictions,
and
• Groundwater monitoring.
This alternative entails excavating and asphalt batching the hot spot area soils on site,
capping the entire site with asphalt pavement, and groundwater monitoring. Excavation and
asphalt batching soil from the hot spot areas in the Cannibalization Yard would reduce the
volume of contaminants present in the highest concentrations at the Maintenance Yards. Asphalt
batched material from the hot spots can be used as paving base material for the cap. Capping
the site with bituminous pavement would minimize potential exposure pathways, thus mitigate
future risk to public health associated with the surface soil. Additionally, potential of
contaminant migration off-site is minimized. Deed and land use restrictions would act as an
institutional control to ensure that the cap remained intact in the future. Sampling and
analysis of groundwater within or downgradient of the Maintenance Yards would also be performed
as detailed in Alternative 1.
The location-specific ARAR identified for this alternative regarding wetlands protection would
be met. This alternative covers the site with pavement, thus reducing potential off-site runoff
of contaminants in surface water from the Maintenance Yards to the wetlands. The remedy will be
designed and constructed to manage the increased surface water flow (due to paved surfaces) in a
manner that will minimize impact to the adjacent wetlands. Alternative 3 would not comply with
chemical-specific risk-based values because the remediation would not reduce contaminant
concentrations to these levels. However, remediation would limit exposure to these chemicals.
Estimated Time for Restoration: Approximately three months; restoration completed prior to
closing of the Maintenance Yards.
Estimated Capital Costs: $1,017,000
Estimated Operation and Maintenance Costs: $204,000
(net present worth)
Estimated Total Costs: $1,221,000
(net present worth, assuming 10 percent discount rate)
D. Alternative 5: Asphalt Batching Site/Asphalt Batching Hot Spot Areas
• Excavate the top two feet across the site and contaminated soils in the hot spot
areas,
• Stockpile/sample/analyze soils and asphalt batch soil that exceed cleanup levels,
• Backfill excavations with stockpiled soil not found to be contaminated above site
cleanup levels,
• Place asphalt batched material on the site surface, and
• Groundwater monitoring.
This alternative involves excavating the top two feet of soil across the Maintenance Yards and
contaminated soils in the hot spot areas; placing excavated soils in piles at the site for
sampling and analysis; asphalt batching soils which exceed site cleanup levels; and performing
groundwater monitoring at the Maintenance Yards. Soil with concentrations below the cleanup
criteria will be placed back in the excavation area. Asphalt batching would immobilize the
contaminants exceeding cleanup levels present in the top two feet, thus minimizing direct
contact/ingestion and inhalation of the soils having a carcinogenic risk. Excavation and
asphalt batching soil from the hot spot areas in the Cannibalization Yard would reduce the
volume of contaminants present in the highest concentrations at the Maintenance Yards.
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Additionally, potential of contaminant migration off-site is minimized. Sampling and analysis
of groundwater within or downgradient of the Maintenance Yards would also be performed as
detailed in Alternative 1.
As described in the May 1994 Final FS Addendum, a pavement wearing course placed over the
batched material was not included in the FS cost as it reportedly would not be reguired by the
regulatory agencies. However, as detailed in the Proposed Plan, the Army has chosen to add a
pavement wearing course for a vehicle parking surface over the asphalt batched material as part
of Alternative 5. Addition of the wearing course will ensure the integrity of the asphalt
batched material as a parking lot base for current and future property use.
The location-specific ARAR identified for this alternative regarding wetlands protection would
be met. This alternative covers the site with pavement, thus reduces potential off-site runoff
of contaminants in surface water from the Maintenance Yards to the wetlands. The remedy will be
designed and constructed to manage the increased surface water flow (due to paved surfaces) in a
manner that will minimize impact to the adjacent wetlands. Alternative 5 would not comply with
chemical-specific risk-based values, because remediation would not reduce contaminant
concentrations to these levels. However, remediation would limit exposure by immobilizing the
contaminants. Asphalt batching binds the contaminants within an asphalt matrix via chemical and
physical processes. Cleanup levels are achieved by reducing the concentration of mobile
contaminants.
Estimated Time for Restoration: Approximately four months for treatment; restoration completed
prior to closing of the Maintenance Yards.
Estimated Capital Costs w/ wearing course: $1,865,000
Estimated Operation and Maintenance Costs: $72,000
(net present worth)
Estimated Total Costs: $1,937,000
(net present worth, assuming 10 percent discount rate)
E. Alternative 7: Bioventing Site and Hot Spot Areas
• Install and operate bioventing system to treat entire site and the hot spot soils.
• Groundwater monitoring.
This alternative includes bioventing the entire site and the hot spot areas, and performing
groundwater monitoring. Details of the bioventing technology are discussed in Section 4.3 of
the FS. This alternative includes initial nutrient injection by tractor; and installation of
vapor extraction and injection trenches and approximately 20 bioventing wells, with associated
piping, blowers, and humidifier. To prevent short circuiting of air, an asphalt pavement cap
will be installed over the entire area of the Maintenance Yards. Bioventing will reduce the
contaminants present in the top two feet thus minimize direct contact/ingestion and inhalation
of the soils having a carcinogenic risk. Additionally, the concentrations of the contaminants
of concern are reduced towards background levels in depths below two feet over the site area as
well as in the hot spot areas. Because the bioventing system reguires a cap to prevent short
circuiting of air, the potential of contaminant migration off-site is immediately minimized upon
construction of the cap. Sampling and analysis of groundwater within or downgradient of the
Maintenance Yards would be performed as detailed in Alternative 1. Duration of monitoring would
be for the treatment period (estimated to be 10 years).
The location-specific ARAR identified for this alternative regarding wetlands protection would
be met because the wetlands would not be adversely affected by the remedial action. This
alternative covers the site with pavement, thus reduces potential off-site runoff of
contaminants in surface water from soils of the Maintenance Yards to the wetlands. The remedy
will be designed and constructed to manage the increased surface water flow (due to paved
surfaces) in a manner that will minimize impact to the adjacent wetlands. Alternative 7 would
comply with the chemical-specific risk-based cleanup levels by promoting destructive
biodegradation of the carcinogenic organic compound, in the top two feet of the soil and
reducing the risk to within the USEPA Superfund target risk range of 1E-4 to 1E-6.
The initial injection of nutrients would need to be monitored so as to not impact either Grove
Pond and its wetlands or the Grove Pond water supply wells. This would minimize human health
risks associated with nitrate/nitrite in groundwater and ecological risks associated with
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nitrate and phosphate migrating to surface water. The MADEP Central Regional Office Water
Supply Section has indicated that bioventing is not recommended within public water supply
aguifer area. The concerns that they have include: high soil permeability, proximity to the
Grove Pond Wells, mobilization of contaminants through nutrient addition, the time to complete
degradation, and the difficulty biodegrading cPAHs. However, nutrients would be scientifically
applied and monitored and are not expected to increase the solubility and migration of cPAHs.
Treatability studies were conducted to determine the effectiveness of bioventing in reducing
cPAH and TPHC concentrations within the soils of the Maintenance Yards. Based on the 1993
Biological Treatability Study Report by ABB Environmental Services, Inc. (ABB-ES), bioventing
does not appear to be nearly as effective as landfarming or composting and in fact may not be an
effective alternative. The estimated treatment period to achieve a total cPAH concentration
reduction to 7 ppm is 10 years.
Estimated Time for Restoration: up to 10 years treatment; site restored approximately eight
years after closing of the Maintenance Yards.
Estimated Capital Costs: $1,070,000
Estimated Operation and Maintenance Costs: $478,000
(net present worth)
Estimated Total Costs: $1,548,000
(net present worth, assuming 10 percent discount rate)
F. Alternative 8: Landfarming Site/Excavating and Landfarming Hot Spot Areas
• Mechanically screen surface soil to remove pavement pieces.
• Excavate hot spots.
• Landfarm hot spot soils and site soils.
• Groundwater monitoring.
This alternative involves mechanically screening out the asphalt pavement pieces from surface
soil, landfarming the entire area of the Maintenance Yards, excavating and landfarming the hot
spot area soils that exceed cleanup levels, and performing groundwater monitoring. Landfarming
will reduce the contaminants present in the top two feet thus minimize direct contact/ingestion
and inhalation of the soils. Additionally, the concentration of the contaminants of concern
could be reduced in depths below two feet over the site area by applying excess nutrients and
water to the soil surface. To enable the yards to be used in part during remediation, design
would be based on treating a portion of the yard while the other portion remained functional as
a maintenance yard. After yard closure, the remaining portion would be remediated. Sampling
and analysis of groundwater within or downgradient of the Maintenance Yards would be performed
as detailed in Alternative 1. Duration of monitoring would be for the treatment period
(estimated to be seven years assuming yard closure in the summer of 1996).
The location-specific ARAR identified for previous alternatives regarding wetlands protection is
not applicable since as part of the landfarming operation, for Alternative 8, catch basins would
be removed thus eliminating any flow to the wetlands. Alternative 8 would comply with the
chemical-specific risk-based cleanup levels by promoting destructive biodegradation of the
carcinogenic organic compounds in the top two feet of the soil and reducing the risk to within
the USEPA Superfund target risk range of 1E-4 to 1E-6.
As described in Alternative 7, nutrients would need to be monitored so as to not impact either
Grove Pond and its wetlands or the Grove Pond water supply wells. The MADEP Central Regional
Office Water Supply Section has indicated that landfarming is not recommended within a public
water supply aguifer area for the same concerns discussed in Alternative 7. Nutrients would be
scientifically applied and monitored and are not expected to increase the solubility and
migration of cPAHs.
Treatability testing and literature studies indicate that the TPHC and cPAH contaminants in the
Maintenance Yard soils are biodegradable. Biodegradation of cPAHs in the soil is expected to
occur slowly, because it was not observable within the laboratory treatment time of 69 days.
However, bioremediation treatment time data indicates that cPAHs (specifically benzo(a)pyrene,
which is one of the more difficult cPAHs to biodegrade) have a half-life of approximately 11.5
months. Treatability testing also indicated that approximately 50 percent of the TPHC
biodegraded within the first month followed by slower reduction of the more recalcitrant TPHC
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compounds. Bioremediation pilot-scale testing of the AOCs 44 and 52 soils is recommended as a
design activity. Bioremediation of the first 20 percent of the Maintenance Yards will serve as
this test. Results will be used to further refine the design for treatment of the remaining 80
percent of the yards.
Estimated Time for Restoration: up to seven years treatment. Site restored approximately five
years after closing of the Maintenance Yards.
Estimated Capital Costs: $621,000
Estimated Operation and Maintenance Costs: $932,000
(net present worth)
Estimated Total Costs: $1,553,000
(net present worth, assuming 10 percent discount rate)
G. Alternative 9: Treatment of Site and Hot Spot Area Soils at a Central Soil Treatment
Facility
• Excavate the top two feet across the site and contaminated soils in the hot spot
areas. Mechanically screen to remove pavement pieces.
• Stockpile/sample/analyze soils and remove soil that exceeds cleanup levels off-site
for treatment.
• Compost/asphalt batch soils at a central soil treatment facility or dispose/treat
off-base if unsuitable for treatment on-base.
• Groundwater monitoring.
Alternative 9 includes excavating the top two feet of soil across the site and contaminated
soils in the Cannibalization Yard hot spot areas; placing excavated soils in piles at the site
for sampling and analysis; transporting soils which exceed site cleanup levels to a central soil
treatment facility on base; and performing groundwater monitoring at the Maintenance Yards. As
a pre-treatment process, surface soil in areas of the site containing bituminous pavement pieces
would be mechanically screened to remove large sized fragments. Screened debris and pavement
will be transported to the central soil treatment facility for crushing and asphalt batching.
As evaluated in the FS, the top two feet of soil from approximately 20 percent of the yard (west
end of the yard) and the Cannibalization hot spot areas would be excavated first. This phase of
the remediation would serve as a pilot test for windrow composting treatment. The remaining 80
percent of the yard would continue to be utilized by the Army and would not be remediated as
part of Alternative 9 until yard closure.
The proposed facility is discussed in the FS Report and the Final Siting Study Report (January
1994). The treatment methods to be used at the facility would be composting and cold mix
asphalt batching. These treatment methods would result in the reuse of soils on Fort Devens.
Excavated soil which is unsuitable for treatment (if any) at the central soil treatment facility
will be treated and/or disposed of off-base at an approved facility.
Alternative 9 would reduce the contaminants present in the top two feet and hot spot areas
excavated. Soils with contaminants exceeding cleanup levels would be removed from the site upon
yard closure permitting immediate reuse of the site. This will meet the remedial objectives of
minimizing direct contact/ingestion and inhalation of the soils having a carcinogenic risk.
Sampling and analysis of groundwater within or downgradient of the Maintenance Yards would also
be performed as detailed in Alternative 1.
The location-specific ARAR identified for this alternative regarding wetlands protection would
be met. This alternative removes contaminated surface soils, thus reduces potential off-site
runoff of contaminants in surface water from soils of the Maintenance Yards to the wetlands.
This alternative also needs to be in compliance with the Massachusetts Hazardous Waste Rules,
Location Standards for Facilities (310 CMR 30.700-30.707) regarding locating treatment facility
operations on lands that are not overlaying an actual, planned, or potential public or private
drinking water supply. If a groundwater recharge area does underlie a selected site, the site
has to be relocated or a waiver, if appropriate, would have to be obtained under the State
regulations. Details of the siting evaluation for the proposed facility are covered by the
Siting Study Report. Alternative 9 would comply with the chemical-specific risk-based cleanup
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levels. Compliance is achieved by physically removing soils containing carcinogenic organic
compounds exceeding the cleanup concentration in the top two feet of the soil thereby mitigating
the risk to within the USEPA Superfund target risk range of 1E-4 to 1E-6. As described in
Alternative 8, treatability testing and literature studies were conducted. They indicate that
the TPHC and cPAH contaminants in the Maintenance Yard soils are biodegradable, however,
biodegradation of cPAHs and recalcitrant TPHC in the soil are expected to occur slowly.
Estimated Time for Restoration: Site restoration complete approximately two months after
closing of the Maintenance Yards.
Estimated Capital Costs: $2,739,000
(net present worth)
Estimated Operation and Maintenance Costs: $659,000
(net present worth)
Estimated Total Costs: $3,398,000
(net present worth, assuming 10 percent discount rate)
IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
Section 121(b)(1) of CERCLA presents several factors that at a minimum the Army is reguired to
consider in its assessment of alternatives. Building upon these specific statutory mandates,
the NCP articulates nine evaluation criteria to be used in assessing the individual remedial
alternatives.
A detailed analysis was performed on the alternatives using the nine evaluation criteria in
order to select a site remedy. Specific discussion regarding this analysis is provided in
Section 6.0 of the FS Report. The nine criteria are summarized as follows:
Threshold Criteria
The two threshold criteria described below must be met in order for the alternatives to be
eligible for selection in accordance with the NCP.
1. Overall protection of human health and the environment addresses whether or not a
remedy provides adeguate protection and describes how risks posed through each pathway
are eliminated, reduced or controlled through treatment, engineering controls, or
institutional controls.
2. Compliance with ARARs addresses whether or not a remedy will meet all of the ARARs of
other federal and state environmental laws and/or provide grounds for invoking a
waiver.
Primary Balancing Criteria
The following five criteria are utilized to compare and evaluate the elements of one alternative
to another that meet the threshold criteria.
3. Long-term effectiveness and permanence addresses the criteria that are utilized to
assess alternatives for the long-term effectiveness and permanence they afford, along
with the degree of certainty that they will prove successful.
4. Reduction of toxicity, mobility, or volume through treatment addresses the degree to
which alternatives employ recycling or treatment that reduces toxicity, mobility, or
volume, including how treatment is used to address the principal threats posed by the
site
5. Short-term effectiveness addresses the period of time needed to achieve protection and
any adverse impacts on human health and the environment that may be posed during the
construction and implementation period, until cleanup goals are achieved.
6. Implementability addresses the technical and administrative feasibility of a remedy,
including the availability of materials and services needed to implement a particular
option.
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7. Cost includes estimated capital and Operation Maintenance (O&M) costs, as well as
present-worth costs.
Modifying Criteria
The modifying criteria are used on the final evaluation of remedial alternatives generally after
the Army has received public comment on the FS and Proposed Plan.
8. State acceptance addresses the state's position and key concerns related to the
preferred alternative and other alternatives, and the state's comments on ARARs or the
proposed use of waivers.
9. Community acceptance addresses the public's general response to the alternatives
described in the Proposed Plan and FS report
Following the detailed analysis of each individual alternative, a comparative analysis, focusing
on the relative performance of each alternative against the nine criteria, was conducted. This
comparative analysis can be found in Table 7-1 of the FS Report. It should be noted that Section
VIII of the ROD presents the alternatives as they appear in the FS Report. Upon the Army's
selection of the preferred alternative and development of the Proposed Plan, two concerns were
raised by the regulatory agencies that subsequently resulted in applying deed restrictions.
One concern was potential residential exposure to Maintenance Yard soils. The Maintenance Yards
and adjacent Barnum Road area have been targeted by the Massachusetts Government Land Bank for
future redevelopment as a rail/industrial area. The quantitative risk evaluation and cleanup
levels for the site assume this area will remain zoned for commercial/industrial use. Since the
risk evaluation was not performed considering residential exposure, an institutional control
would need to be implemented to ensure that the proposed commercial/industrial use for the
Maintenance Yards could not be changed to residential use. Consequently, the Army has applied a
deed restriction to Alternatives 5, 7, 8 and 9 which would prohibit residential development
within the Maintenance Yards.
The second concern was the lack of analytical data for soil between 2 feet and 5 feet bgs.
Sampling and analyses were performed during the SI on soil depths of 0 to 2 feet, 5 to 7 feet,
and 10 to 12 feet bgs (Boring G3M-92-04X was sampled at 0-2, 12-14 and 26-28 foot intervals).
Soil between 2 and 5 feet was not sampled. However, contaminants were found to be typically
higher in surface soil samples (0 to 2 feet) and generally absent or of lower concentration with
depth which is consistent with the reported release mechanisms (leaking or spilled vehicular
fluids). Contaminant concentrations in subsurface soils are unlikely to be higher than or equal
to contaminant concentrations in surface soils. Risk estimates for only one of three probable
soil exposure scenarios evaluated exceeded acceptable limits for carcinogens. The scenario for
which risks exceeded acceptable limits assumes a working lifetime exposure (250 days/year for 25
years) of a maintenance worker to surface soil (top 2 feet). Risk estimates for construction
worker scenarios (exposure to surface and subsurface soils [0 to 10 feet] for three months) were
within acceptable limits.
Although risks associated with exposure to soils deeper than 2 feet are within acceptable range,
the possibility exists that the entire top two feet of soil could be removed for a future land-
use scenario, and the 2- to 4-foot subsurface soil would become "surface" soil. The possibility
also exists that contaminants below 2 feet in depth could be at greater or similar
concentrations to the surface soils. There is no analytical information available for this soil
level to conclude, without a doubt, that there would be no carcinogenic risk should the top two
feet of soil be removed.
Consequently, as a protective measure, the Army has applied institutional controls in the form
of deed restrictions to Alternatives 5, 8 and 9. (Alternative 7, which entails treatment of
subsurface soils would not require these institutional controls). The deed restrictions will
prohibit the removal of the top 2-foot cover or barrier from the site to prevent any possible
future long-term (working lifetime) surface soil exposure scenarios to what are presently
classified as subsurface soils. Additionally, the deed restrictions will institute soil
management procedures should future excavation below 2 feet occur.
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The section below presents the nine criteria and a brief narrative summary of the alternatives
and the strengths and weaknesses according to the detailed and comparative analysis. A detailed
assessment of each alternative according to the nine criteria can be found in Section 6.0 of the
FS Report.
1. Overall Protection of Human Health and the Environment
This criterion is one that, according to CERCLA, must be met for a remedial alternative to be
chosen as the final remedy for the site. Overall Protection of Human Health and the Environment
addresses how an alternative as a whole will protect human health and the environment. This
includes an assessment of how public health and environmental risks are properly eliminated,
reduced, or controlled through treatment, engineering controls, or institutional controls.
Alternative 1, the No Action alternative is not protective in that it provides no remedial
action, and does not impose institutional controls to prevent exposure to known contaminants.
USEPA' s target risk range would likely continue to be exceeded indefinitely for a site worker
without some type of remediation. Alternatives 2 and 3 would eliminate risks by minimizing
exposure through institutional controls (preventing access to the site and capping,
respectively). Alternative 5, the Preferred Alternative, would achieve an irreversible
reduction in mobility of the contaminants. It is expected that remedial action time would be
approximately four months. Alternative 7, bioventing, would achieve risk reduction by
contaminant destruction in approximately 10 years. However, the risk also would be eliminated
by minimizing exposure upon installation of the cap prior to the start of bioremediation. (A
cap is reguired for the bioventing technology.)
Alternative 8, landfarming, would achieve risk reduction by contaminant destruction in
approximately seven years, based on yard closure by the summer of 1996 as projected by the Army
during the development of the FS Report, or five years, based on potential accelerated yard
closure by early 1995. Alternative 9, would be protective immediately following soil
excavation, removal, and backfilling at the site, estimated to be within two months after
operations in the Maintenance Yards cease. The soil would then be remediated at a central Fort
Devens soil treatment facility. Alternatives 5, 7, 8 and 9 would have deed restrictions as
previously discussed in this Section.
2. Compliance with ARARs
CERCLA also reguires that the selected alternative comply with ARARs or a waiver be obtained if
the alternative does not comply. (ARARs identified for Alternative 5 are provided in Table 19).
The location-specific ARAR identified for the Maintenance Yards alternatives entails regulations
that protect wetlands. Alternatives 1 and 2 will not reduce potential off-site runoff of
contaminants in surface water from the Maintenance Yards to the wetlands. Alternatives 3, 5, 7,
8, and 9 all minimize the potential of off-site migration of contaminants via the stormwater
system. Impacts to wetlands due to increased stormwater runoff from paved surfaces
(Alternatives 2, 3, 5, and 7) would need to be considered during remediation and design of
the stormwater collection system expansion. Additional location-specific ARARs for siting of
hazardous waste treatment facilities would apply to the central soil treatment facility
(Alternative 9).
Action-specific regulations for groundwater monitoring is an ARAR for all of the alternatives,
including No Action, and would be met for all alternatives by instituting a groundwater
monitoring program for each alternative. The Massachusetts Hazardous Waste Regulations contain
ARARs for all remedial alternatives because of the nature of contamination at the site. Each
alternative would comply with these regulations during the design and implementation of the
remedial activity.
Federal and state air guality regulations would be met by all the alternatives. In particular,
dust suppression would be reguired for alternatives involving excavation, tilling, or other
activities that could generate dust.
Reguirements specific to remedial actions such as soil recycling by asphalt batching, biological
treatment, and land treatment would be met by the alternatives to which they apply.
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Although there are no chemical-specific ARARs for establishing cleanup levels for the soils at
the Maintenance Yards, risk-based cleanup criteria have been developed as a remediation goal.
Alternatives 1, 2, 3, and 5 do not reduce contaminant concentrations to meet these cleanup
levels; however, Alternatives 2, 3, and 5 do reduce risks by minimizing the potential for
exposure to the contaminants. Alternatives 2 and 3 rely on institutional controls to minimize
the exposure to surface soils. Alternatives 5, 7, 8, & 9 do not reguire institutional controls
to minimize exposure to surface soils under current and proposed industrial use scenarios.
However, they do use institutional controls to prohibit redevelopment for residential use.
Alternative 5 utilizes a treatment process (asphalt batching) to immobilize the contaminants in
surface soils but reguires restrictions on removal of the 2-foot cover or barrier from the site
to prevent any possible exposure to subsurface soils (2-foot to 5-foot level where sampling was
not performed). Also soil management procedures are reguired should future excavation below 2
feet occur. Although there is no current evidence that suggests contaminant levels at 2 to 5
feet bgs would create a risk if uncovered, precautions in the form of deed restrictions would be
taken regarding subsurface soils. Alternatives 8 and 9 would meet surface soil cleanup
objectives by using either in-situ or ex-situ response actions but also have similar subsurface
soil restrictions for the same reasons as Alternative 5. Alternative 7 would treat surface and
subsurface soils and would not have these restrictions.
3. Long-Term Effectiveness and Permanence
This criterion evaluates the reliability of each alternative in protecting human health and the
environment after the response objectives have been met, in terms of the magnitude of residual
risk, the reliability of controls and the degree of certainty that they will prove successful.
Alternative 1 provides no controls or treatment to protect human health and the environment.
Alternatives 2 and 3 rely mainly on institutional controls to prevent exposure to the surface
soils at the Maintenance Yards. Alternatives 5, 7, 8 and 9 utilize treatment technologies
(in-situ and ex-situ) for permanently immobilizing or destroying the contaminants and only use
deed restrictions to prevent future conditions from developing that may result in risk to human
health or the environment. All alternatives utilize groundwater monitoring for five years or
for the duration of treatment at the site (whichever is longer) from the start of remediation.
Groundwater monitoring is used as a means of assessing contaminant migration to the groundwater.
In terms of risk reduction over the entire site, Alternatives 8 and 9 might be considered the
most effective in that the target contaminants are destroyed or physically removed in lieu of
immobilizing as in Alternative 5. However, biodegradation of cPAHs in the soil is expected to
occur slowly (Alternatives 7, 8 and 9). Treatability testing detailed in the FS Report indicates
that Alternative 7, bieventing, is not nearly as effective in reducing contaminants as
landfarming (Alternative 8) or composting (component of Alternative 9) and, in fact, may not be
an effective alternative.
4. Reduction of Toxicitv, Mobility, or Volume through Treatment
Reduction of toxicity, mobility, or volume through treatment are three principal measures of the
overall performance of an alternative. The 1986 amendments to the Superfund statute emphasize
that, whenever possible, a remedy should be selected that uses a treatment process to reduce
permanently the level of toxicity of contaminants at the site, the spread of contaminants away
from the source of contamination, and the volume or amount of contamination at the site.
All alternatives except Alternative 1 employ treatment as an important element. Alternatives 2
and 3 will each reduce the mobility of contaminants in the hot spot areas that will become
asphalt batched material and be utilized as a pavement base course. Alternative 5 would reduce
the mobility of contaminants in the hot spot area soils and in the top two feet of soil across
the 8.8-acre site which exceed cleanup levels. Asphalt batched material will be the residual
remaining after treatment, which will be placed in a layer on the surface of the site.
Alternatives 7 and 8, which utilize biological treatment technologies entirely, will reduce the
toxicity, mobility, and volume of soil contaminants and will produce no residuals after
treatment. Alternative 7, which will entail bioventing the entire site, will treat the top two
feet and hot spot areas with potential of reducing contaminant concentrations with decreasing
effectiveness down to an approximate 10-foot depth across the site.
Alternatives 8 and 9, which will entail landfarming and off-site treatment, respectively, would
treat the hot spot areas and the top two feet of soil. Alternative 8 would have the potential
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of reducing contaminant concentrations with decreasing effectiveness at depths below 2 feet.
Alternative 9 removes the hot spot area soil and the top two feet of soil which exceed cleanup
criteria from the site. The off-site treatment process entails biological treatment which
reduces the toxicity, mobility, and volume of soil contaminants and produces no residuals after
treatment. It also uses asphalt batching on some soil which would reduce the mobility of
contaminants in the soil. Asphalt batched material will be the residual after treatment which
would be used as roadway material.
5. Short-Term Effectiveness
Short-term effectiveness refers to the likelihood of adverse impacts on human health or the
environment that may be posed during the construction and implementation of an alternative until
cleanup goals are achieved. This criterion also considers the duration of the remedial
alternative.
Alternative 1 would have the least impact during implementation because it would not involve
construction or operation. Alternative 7 would also have minimal impact on the community,
workers, and environment because remediation would take place in-situ. However, increased
stormwater runoff from the cap would need to be controlled to minimize impacts on the wetland
which receives drainage from this area. Runoff control would also be an issue for Alternatives
3, 5, and 2 (to a lesser extent) which would place the impermeable asphalt batched material over
the site. Alternatives 2, 3, 5, 8, and 9 involve excavation and handling of contaminated soils.
Adverse impacts from potential worker exposure would be mitigated by protective clothing and
eguipment and safe work practices. Fugitive dust would be controlled by application of water
during remedial actions.
Completion of remedial actions would be essentially immediate for Alternatives 2, 3, and 5
because work on site could be accomplished within a few weeks or months. As evaluated in the
FS Report, on-site remedial actions associated with Alternative 9 would be completed following
closure of the Maintenance Yards. Soils exceeding cleanup levels would be taken off-site to an
on-base treatment facility. During the development of the FS, the Army was projecting that the
yards would be closed in the summer of 1996. Based on this projection, excavation at the site
would be phased (excavation of hot spots and 20 percent of the site to begin in 1994, and the
remainder to begin in 1996) to accommodate the Maintenance Yards closure schedule. However, due
to recent redevelopment interests, this schedule may be accelerated and the Army could vacate
the yards by early 1995. It is likely that even under the accelerated schedule, soils from the
site would need to be removed in phases to minimize the size reguirement of the on-base
treatment facility. Similarly, Alternative 8 would take up to seven years to complete, based on
phased remediation (remediation of hot spots and 20 percent of the site to begin in 1994, and
the remainder to begin in 1996) to accommodate the Maintenance Yards FS projected closure
schedule, or five years if the yards close early in 1995. Although bioventing under Alternative
7 could begin in 1994 without major disruption to normal operations, remediation is expected to
take 10 years to complete, because this type of bioremediation is not as aggressive as
landfarming or composting.
6. Implementabilitv
This criterion evaluates each alternative's ease of construction and operation; administrative
feasibility; and availability of services, materials, eguipment, and specialists that may
reguired to construct and operate the technology. This criterion also considers the ease or
difficulty of implementing further remedial actions at a later date, and the effect the remedial
alternative would have on continued operations at the Maintenance Yards.
Alternative 1, which only includes groundwater monitoring, would be the easiest alternative to
implement at the site, and would have the least impact on future remedial actions and
Maintenance Yards activities. Similarly, Alternative 2 would be relatively easy to construct
and would have minimal impact on activities at the site. Alternatives 3 and 5 would be easy to
construct because they involve asphalt batching/paving the site, which utilize common
construction practices. However, if the yards are still functional upon commencement of
remedial activities, these alternatives would disrupt the yards for several weeks during
stormwater collection system modification, excavation and paving. Also, if further action is
warranted at a later date, the pavement may need to be removed.
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Alternative 9 involves excavating and transporting soil, which are common technologies.
Composting technology has been used for treatment of sewage sludge and is also applicable to
biodegradable contaminants in soil. This alternative would have minimal effect on future
remedial actions. However, if the yards are still functional upon commencement of remedial
actions, implementation would impact Army activities by confining current operations to 80
percent of the yards until the Maintenance Yards close. An existing central soil treatment
facility is not currently available; therefore, a facility will need to be sited and constructed
for soils from the Maintenance Yards. Construction of a facility with sufficient capacity to
treat all of the soil at once would be difficult in terms of facility siting and other
regulatory issues. Operation of the facility would be relatively simple and would not reguire
skilled operators, but may reguire bioremediation specialists to monitor performance and
troubleshoot on an as-needed basis.
Alternatives 7 and 8 would not be difficult to construct or operate but pose aguifer protection
concerns. Nutrients for Alternatives 7 and 8 would need to be monitored so as to not impact
either Grove Pond and its wetlands or the Grove Pond water supply wells. Stormwater collection
system expansion would also be an issue for Alternative 7, since this alternative entails
capping the entire site. Also, if further action is warranted at a later date, the paving may
need to be removed. Alternative 8 would have minimal impact on future actions. Alternative 7
will create similar disturbances within the yards as Alternative 3 due to the installation of
the bieventing system and stormwater piping and appurtenances, and the paving of the site.
Alternative 8 will create similar disturbances within the yards as Alternative 9 if the yards
are still functioning upon commencement of remedial activities.
7. Cost
A comparison of the estimated total present worth costs (based on a 10 percent discount) for
each alternative is as follows:
Alternative Total Capital Total O&M (net Total Costs (net
present worth) present worth
#1 $ 0 $ 133,000 $ 133,000
#2 $ 204,000 $ 152,000 $ 356,000
#3 $ 1,017,000 $ 204,000 $ 1,221,000
#5 $ 1,865,000 $ 72,000 $ 1,937,000
#7 $ 1,070,000 $ 478,000 $ 1,548,000
#8 $ 621,000 $ 932,000 $ 1,553,000
#9 $ 2,739,000 $ 659,000 $ 3,398,000
Capital, O&M, and present worth costs for each alternative were calculated within a range of
accuracy of +50 percent to -30 percent. The alternatives with the lowest capital costs are
those that include little remedial action, such as Alternatives 1, 2, and 3, and those that
utilize in-situ treatment technologies (Alternatives 8 and 7). Alternatives 5 and 9, which
involve excavation and treatment of soil, reguire larger capital. O&M costs are computed on an
annual basis, and are lowest for Alternative 5, which does not reguire long-term maintenance.
O&M costs for Alternatives 1, 2, 3, and 5 include environmental monitoring for 5 years.
Alternatives 7, 8, and 9 include operation of the treatment systems and groundwater monitoring
for the estimated duration of treatment.
Alternatives 1, 2 and 3 which have low capital costs, also have lower total present worth cost.
Alternatives 7 and 8 have high present worth costs due to longer treatment durations;
Alternative 5 has high costs due to treatment costs. Alternative 9 is the most expensive due to
treatment facility construction and extended treatment duration.
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8 . State Acceptance
MADEP has been actively involved with the Maintenance Yards during the development of the SI, FS
and this ROD. MADEP provided comments on the Army's Preferred Alternative during the public
hearing. In summary, MADEP believes that Alternative 5 is the most protective of the proposed
alternatives. MADEP expressed the desire that the Army excavate any grossly contaminated soil
that is encountered, besides the top two feet and the two hot spot areas. These would include
any areas where previous sampling has shown that soil below 2 feet was contaminated above
cleanup levels. MADEP also reguested that the Army review their spill management plan for the
Maintenance Yards to ensure that in the interim before remediation, there is a good management
plan for spills and that the spill containment pad is utilized to minimize the likelihood of
further contaminating soils.
A summary of these and other MADEP comments, and the Army's responses, are included in the
Responsiveness Summary attached as Appendix C to this ROD. The Commonwealth of Massachusetts
has indicated it's support for the remedy and the concurrence letter is located in Appendix D of
this ROD.
9. Community Acceptance
The comments received by the community and local governments are summarized and responded to in
the Responsiveness Summary attached to the ROD as Appendix C.
Comments were received from a merchant and two town officials from the town of Ayer and
representative of the Fort Devens Reuse Center. Comments generally supported the Army's choice
of the selected remedy.
X. THE SEIiECTED REMEDY
The remedy selected to address the contamination identified at the Maintenance Yards is
Alternative 5, Asphalt Batching the Site/Asphalt Batching the Hot Spot Areas. The remedy
includes the following components: excavating the top two feet of soil across the site and the
two hot spot areas; placing excavated soils in piles at the site for sampling and analysis; cold
mix asphalt batching soils which exceed site cleanup levels; backfilling site excavations with
stockpiled soil not found to be contaminated above cleanup levels and with the cold mix asphalt
batched material; expanding the existing stormwater collection system including construction of
detention pond(s); and applying a pavement wearing course for a vehicle parking surface over the
Maintenance Yards; performing groundwater monitoring; and instituting deed restrictions to:
prohibit residential development/use of the Maintenance Yards, minimize the possibility of
long-term (working lifetime) exposure to subsurface soils, and reguire management of soils
resulting from construction related activities.
The approximate cleanup timeframe for the selected remedy is four months following commencement
of remedial activities.
A. Soil Cleanup Levels
The FS investigated several methods for establishing a cleanup level to achieve a cancer risk
that is within the USEPA Superfund target risk range. During a Draft FS Report review meeting
with USEPA and MADEP, a cleanup level of 7 ppm average total cPAHs was selected for the FS
Report from the computed target range. This value was arrived at assuming all cPAHs are as
potent as benzo(a)pyrene (the B[a]P approach), which was USEPA Region I's standard approach for
computing risk estimates for cPAHs at the time the guantitative risk evaluation was performed
for the Maintenance Yards. This cleanup level for known and suspect carcinogens (Classes A, B,
and C compounds) achieves a 10-4 excess cancer risk level considering exposures via dermal
contact and incidental ingestion. (Although inhalation is a potential exposure route, risk
estimates indicate that it is an insignificant contributor to the overall risk at the
Maintenance Yards).
Since the development of the target level for cPAHs, USEPA views two critical assumptions
differently than at the time of the FS. The first assumption involves the use of the dermal
exposure route. Although benzo(a)pyrene has been known to cause skin cancer, USEPA Region I no
longer includes the dermal route of exposure when developing target levels for cPAHs because of
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inconclusive data. The second assumption involves assessing the relative toxicity of the cPAHs.
The toxic equivalency factor (TEF) approach involves applying TEFs to cPAHs based on each
compounds relative potency to that of benzo(a)pyrene. Toxicologists within USEPA Region I have
reviewed the TEF approach in light of USEPA provisional guidance and have recently accepted the
TEF method. To determine the effects of these assumptions on the target levels presented in the
FS, target levels were recalculated excluding the dermal route of exposure
and applying the relative potency factors (TEF approach). Results are listed in the following
table.
SOIL CLEANUP LEVELS FOR cPAHs
VARIOUS COMPUTATION APPROACHES
Target Level (ppm) at 10-4 Risk
Average Total cPAH Concentrations
Approach Ingestion/Dermal Ingestion
Routes Route Only
USEPA B(a)P approach 6.4 78
USEPA TEF approach 23 1300
USEPA Region I has recently formally accepted the TEF approach for new RI/FS sites where risk
assessment is not substantially underway or where the USEPA remedial project manager decides to
reevaluate risk with the new approach. However, MADEP's acceptance of the NCP risk assessment
approach for the site is contingent upon the dermal exposure pathway being utilized and the TEF
approach not being used, such that the cleanup level is consistent with the Massachusetts
Contingency Plan (MCP), 310 CMR 40.0000 (November 19, 1994). Conseguently, the cleanup level at
the Maintenance Yards will be 7 ppm average total cPAHs as was selected in the FS Report.
It is noted that the CERCLA risk approach to risk assessments does not measure risk resulting
from TPHC, which are a combination of a number of compounds often including cPAH contaminants.
Although not required to do so under CERCLA or the NCP, the Army has agreed, with MADEP
approval, to establish TPHC cleanup levels for soils at the Maintenance Yards based on guidance
from the MCP. The MCP establishes 500 ppm as the cleanup criteria for TPHC using MCP Method 1
and S-l Soil and GW-1 groundwater categories. As noted in the footnote to Table 2 in the MCP
regulations (310 CMR 40.0975(6) (a)), entitled "MCP Method 1: Soil Category S-l Standards", the
Method 1 S-l soil standard for TPHC does not apply to benzene, toluene, ethylbenzene, and xylene
(BTEX) compounds or specific PAH compounds. Therefore, the S-l soil standard for TPHC is used
for AOC 44 and 52 soils in conjunction with the site-specific cleanup level for cPAHs identified
above. Benzene was not detected in AOC 44 and 52 soil. As reported in Appendix A of the FS,
the risks associated with toluene, ethylbenzene, and xylenes in AOC 44 and 52 soils fall well
outside the Superfund target HI of one; assuming worker exposure to the maximum detected
concentrations of these compounds results in hazard quotients on the order of 3x10-7 or less.
Use of the TPHC soil standard under the Method 1, S-l soil and GW-1 groundwater categories
results in the most health-protective of the Method 1 standards. This is because S-l soil is,
by definition, the most accessible and therefore presents the greatest potential for exposure,
and GW-1 groundwater is assumed to be potable.
Based on the Baseline Risk Evaluation in the FS Report, exposure to non-carcinogenic Classes D
and E compounds are at an acceptable level to which the human population including sensitive
subgroups may be exposed without adverse affect during a lifetime or part of a lifetime.
Consequently no cleanup levels for these compounds were derived.
The cPAH and TPHC cleanup levels of 7 ppm average total cPAHs and 500 ppm TPHC must be met at
the completion of the remedial action within the present fenced surface area of the Maintenance
Yards to a two-foot depth and in the two hot spot surface and subsurface soil areas identified
as the mogas spill area and the leaking UST area. The cleanup level for cPAHs attains USEPA's
risk management goal for remedial actions and has been determined by USEPA to be protective of
human health and the environment. The cleanup level for TPHC meets the requirement of the MADEP
for this contaminant.
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B. Description of Remedial Components
The following is a description of the remedial components of the selected remedy for the
Maintenance Yards:
• Excavate surface soil (top two feet across the site),
• Excavate the two hot spot areas,
• Stockpile soils for sampling and analysis,
• Cold mix asphalt batch soils exceeding site cleanup levels,
• Backfill excavations with uncontaminated stockpiled soil and with the asphalt
batched material,
• Expand the existing stormwater collection system,
• Apply a pavement wearing course,
• Perform groundwater monitoring.
• Institute deed restrictions to prohibit residential development/use of the
Maintenance Yards, minimize the possibility of long-term (working lifetime) exposure
to subsurface soils, and reguire management of soils resulting from construction
related activities.
Excavate Surface Soils: Prior to commencement of the remedial design, predesign test pits will
be excavated to better predict the typical soil characteristics (color, texture, and presence of
pavement) and layers containing cPAHs that may be encountered when the top 2 feet of soil is
removed during remediation. This preview will enable planned optimization of soil excavation
and handling activities during remedial action; improve estimates on the volume of soils that
will reguire treatment; and provide soil gradation data for the asphalt batching design.
Details of these test pitting activities will be provided in a predesign work plan.
It is proposed that the Maintenance Yards surface soils be excavated in 6-inch layers down to a
2-foot depth, and stockpiled and sampled in 100-cy batches. Layers of other thickness may be
excavated depending on the observed thickness of layers in the test pits. It is believed that
layers with pavement will contain the highest concentration of cPAHs. If proven to be true from
test pit results, this soil will be stockpiled separately. Soils will be initially screened for
visible and olfactory evidence of waste material or overtly contaminated soils. Soils observed
to contain broken pieces of pavement will be segregated as cPAH-contaminated soil in maximum 100
cy piles and kept in separate piles for analytical screening. Soils with fuel odor or evidence
of petroleum contamination will also be separated from soil with no evidence of contamination.
All soil to a 2-foot depth will be excavated, stockpiled and sampled regardless of physical
evidence of contamination. This amounts to a total unexcavated soil volume of approximately
28,400 cy of soil. A topographic survey, to be performed as a predesign activity, will more
accurately guantify the soil volume to be excavated. Excavation seguence of surface soils and
installation of utilities will be detailed in the design and/or Contractors work plan.
An air monitoring program will be established to assess air guality during all excavation and
soil handling activities. Air monitoring will ensure that total suspended particulates (TSPs)
do not exceed predetermined action levels. Details of this program will be provided in the
remedial design.
Excavate Hot Spot Areas: Trench exploration will first be performed to include or exclude the
boring 44B-93-10X area as the potential mogas spill area. To initially identify the potential
hot spot area, trenches will be excavated over 44B-93-10X. Headspace screening by
photoionization detector (PID) or NDIR Modified Method 418.1 screening on the trench sidewalls.
This area will be excluded from further investigation and excavation if there is no detection of
volatiles or if TPHC is not over 500 ppm.
Trenches will also be excavated over boring 44B-92-06X to initially define the extent of the hot
spot area detected in this area. Headspace and NDIR screening will be performed on sidewalls
and/or bottom of trench if staining is not evident.
The hot spot will then be fully excavated to the approximate dimensions as determined by the
trench screening and excavation will continue until laboratory analysis reveals concentrations
less than 500 ppm.
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The hot spot area around the waste oil UST will also be excavated. This area has been
previously over-excavated and backfilled with clean soil. The clean backfill soil in the over-
excavated area will be excavated, segregated and sampled to ensure clean backfill and native
soil are clearly distinguished. Upon reaching native soil, excavation and sampling for TPHC will
be continue until laboratory analysis reveals concentrations less than 500 ppm.
Any other "hot spot areas" observed during the excavation of the surface soils will be
excavated, segregated, stockpiled and sampled in a similar manner as described in this ROD.
Depth of contamination is unknown in the hot spot areas. For planning purposes, contamination
was assumed to extend to an average 17-foot depth. Details of the trenching, excavation and
sampling for excavating the hot spot areas will be provided in the remedial design.
Stockpiling and Sampling and Analysis: Soils excavated from hot spot areas will be placed on,
and covered with, a minimum 8-mil polyethylene tarp to prevent mixing of TPHC contaminated soils
with clean soils. Surface soils will also be placed on polyethylene tarpaulins if there is
potential for soil to contaminate clean soil. All stockpiling of soils will be restricted to
the areas at the Maintenance Yards to be detailed in the design. Excavation work sequence in
relation to stockpiling methods will be detailed in the Contractor's work plan. Stockpiling and
analytical work will be done concurrently to minimize the duration that soils are left on-site.
Jersey barriers or concrete blocks may be used to separate piles if required.
Sampling and analysis to classify stockpiled soils from hot spot and surface soil excavations as
acceptable for reuse at the site without treatment, will require collecting five soil subsamples
and field compositing to yield one sample for every 100 cy of stockpiled soil or for every
segregated stockpile, whichever smaller in volume. Samples from hot spot stockpiled soils will
be analyzed in the field laboratory for TPHC using the Modified Method 418.1 (NDIR). Samples
from surface soil stockpiled soils will be analyzed in the field laboratory for TPHC using the
Modified Method 418.1 (NDIR) and for the following seven cPAHs using Modified Method 8270
(GC/MS) by a field laboratory:
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Chrysene
Dibenzo(a,h)anthracene
Indeno(1,2,3-cd)pyrene
All analytical samples will be screened through a No. 20 sieve at the laboratory to remove any
pavement particles down to the size of coarse sand prior to performing the analysis.
Asphalt Batch Soils Exceeding Site Cleaning Levels: Stockpiled soils with contaminants
exceeding an average total cPAH concentration of 7 ppm and 500 ppm TPHC, will be cold mix
asphalt batched on-site. Asphalt batching has been accepted by the regulators as a technology
that is successful at immobilizing compounds common in petroleum releases. As detailed in the
FS Report, leaching of contaminants from asphalt batched soils has been evaluated (with
favorable results) by sampling groundwater wells near stockpiled treated soils and by performing
laboratory leaching tests. Coupled with the formation of a relatively impermeable barrier, the
chemical and physical fixation of contaminants by asphalt batching is considered to be
protective of human health and effective in minimizing contaminant migration to the groundwater.
Asphalt batching site soils will immobilize the contaminants exceeding cleanup levels present in
the top two feet, thus minimizing direct contact/ingestion of the soils having a carcinogenic
risk. Asphalt batching the hot spot areas in the Cannibalization Yard will reduce the mobility
of organic contaminants present in the highest concentrations at the site.
The cold mix asphalt batching technology is performed at ambient temperatures and entails
recycling petroleum contaminated soil into a bituminous paving or road base product. Excavated
soils may be processed through a crusher or screen to produce a physically uniform soil
material. The soil may then be blended with other aggregate (if required due to existing soil
conditions) and asphalt emulsion in a pugmill. Soil gradation results and the pavement design
will dictate soil preparation needs. The finished product will be used as the base or subbase
material for parking lot construction over the Maintenance Yards. For costing purposes the FS
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Report assumed that approximately 17,000 cu yds (excavated volume) of surface and hot spot soils
will require asphalt batching. This estimate may be refined upon completion of the predesign
test pit field work.
Backfill Excavations: Excavations will be backfilled with "clean" stockpiled soil and with the
soils which have been asphalt batched. Site soil will be classified as "clean" if it meets the
cleanup criteria of 500 ppm for TPHC and the risk-based cleanup criteria of 7 ppm (average) for
total cPAHs. This soil will be used to refill a portion of the excavated areas at the
Maintenance Yard. Preferably, upon receipt of analytical results, the soil will be immediately
backfilled into designated areas. If backfill areas are not available, the soil will be stored
in designated piles separate from other soil for later use as on-site backfill. The asphalt
batched material will then be spread and rolled to the thickness and contours to be detailed in
the final design and will serve as the subbase or base course for the paved parking lot.
As an additional benefit, the asphalt batched material serves as a low-permeable barrier
minimizing surface water infiltration through site soils, thereby providing greater aguifer
protection. The quantity of off-site aggregate and pavement required for the parking lot
construction will be estimated in the remedial design based on pavement design loads, soil
gradation test results, a refined estimate of the soil requiring asphalt batching, site grading,
and other design details. Contingencies will also be considered for pavement design should
soils requiring asphalt batching be more and less than anticipated.
Expand the Existing Stormwater Collection System: Construction of the paved parking lot at the
Maintenance Yards will increase the amount of stormwater runoff during rain events. Therefore,
the selected remedy will include expansion of the existing stormwater collection system
including installation of additional catch basins, additional stormwater piping, and oil and
grease traps as required. Additionally, potential impacts to wetlands at stormwater outfalls
will be investigated and, as needed, minimized by construction of detention basins and flow
reducers.
Prior to the design of this system, a predesign investigation of the existing stormwater system
will be performed. To enable developing a representative model of the system, information
relating to the existing storm drainage system will be reviewed and field inspections will be
made as necessary. The model will be used to compute the current stormwater runoff flow and
predict future stormwater flow after construction of the parking lot. It will also be used as a
design tool by predicting the impact of detention pond((s) and other flow restriction devices on
system flows, enabling design criteria to be met. Details of the predesign investigation work
and the stormwater system expansion will be provided in a predesign work plan and the remedial
design respectively.
Apply a Pavement Wearing Course: A paving wearing course is a top coat of pavement that is
placed over a pavement base course to provide a smooth, durable surface in high traffic areas.
A pavement wearing course placed over the batched material is not a required remedial component
for selected remedy. However, the Army has chosen to add a pavement wearing course for a
vehicle parking surface over the asphalt batched material as an ancillary component. Addition
of the wearing course will ensure the integrity of the asphalt batched material as a parking lot
base for current and future property use.
Perform Groundwater Monitoring: The objective of groundwater monitoring is to provide assurance
to the public and the regulatory agencies that the groundwater in the aquifer underlying the
facility remains unaffected by past Maintenance Yard activities and that it has not been
impacted by the remedial activities. Sampling analysis of groundwater from existing wells at
the Maintenance Yards will be performed yearly for a period of five years upon commencement of
remedial activities. Sampling will be for the same analytes tested for during the SI. Details of
this program will be provided in the remedial design.
Institute Deed Restrictions: Institutional controls in the form of deed restrictions will be
implemented to prevent potential circumstances which may result in risk of harm to health,
safety, public welfare or the environment. These restrictions will include:
1. No residential development/use of the Maintenance Yards will be permitted. The
quantitative risk evaluation and established cleanup level assume the property will
remain zoned for commercial/industrial use.
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2. Removal of the 2-foot cover or an asphaltic barrier from the Maintenance Yards will be
prohibited to prevent surface soil exposure to existing subsurface soils (2-foot to
5-foot level). This deed restriction will be implemented as a precautionary measure to
minimize the possibility of long-term (working lifetime) exposure to subsurface soils.
This restriction will not apply to excavations undertaken in connection with
construction of buildings or other structures, utilities, infrastructures or any other
construction related purpose where the cover is penetrated and/or temporarily removed
and protection from long-term exposure to subsurface soil is not jeopardized. To
comply with this deed restriction, the 2-foot layer of cover material (which may
consist of one or combination of "clean" site soil used as backfill, asphalt batched
material, off-site soils/aggregate and bituminous pavement) will remain over the
subsurface soil (existing 2- to 5-foot soil level) to minimize direct
contact/ingestion to the present subsurface soils. The continuity of the paved
surface need not be maintained providing the cover thickness of 2 feet is provided.
As an alternative, a continuous and maintained paved surface which would prevent
exposure to subsurface soils could be substituted for the 2-foot thick cover.
This restriction also would not apply to excavation and use that is within the scope
of any authorized response action. The deed restriction may be nullified, as approved
by the regulatory agencies, should there be future evidence showing that contaminant
levels within the 2- to 5-foot soil zone are below site surface soil cleanup levels.
3. Excavation below 2 feet at the Maintenance Yards, subseguent to completion of the
remedial action established in this ROD, will reguire:
a. Development and implementation of a Health and Safety Plan for the work area;
and
b. Development and implementation of a Sampling and Analysis Plan for management
of the excavated soils in accordance with the following:
Where reuse of soil within the Maintenance Yards is intended, sampling and
analysis of stockpiled soils excavated below 2 feet will follow criteria
detailed in this ROD for hot spot area soils. Soils with contaminants
exceeding the 500 ppm cleanup level for TPHC will be treated in a manner
consistent with this ROD. Soils with contaminants below the established
cleanup level may be returned to the excavation. Soil excavated below 2 feet
but returned to the top 2 feet (as surface soil) must also be sampled,
analyzed and, if reguired, treated for cPAH contaminants as detailed in this
ROD.
Where reuse of soil outside the Maintenance Yards is intended,
sampling/analysis and action levels for stockpiled soils excavated below 2
feet will follow criteria governed by the regulations or policies in effect
for the final disposal area.
C. Other Components of the Selected Remedy
To assure that the remedial action continues to protect human health and the environment, and to
the extent reguired by law, USEPA will review the operable unit at least once every five years
after the initiation of remedial action if any hazardous substances, pollutants or contaminants
remain at the site. USEPA will also review the operable unit before Fort Devens is proposed
for deletion from the NPL.
XI. STATUTORY DETERMINATIONS
The remedial action selected for implementation at the Maintenance Yards is consistent with
CERCLA and, to the extent practicable, the NCP. The selected remedy is protective of human
health and the environment, attains ARARs and is cost-effective. The selected remedy also
satisfies the statutory preference for treatment which permanently and significantly reduces the
mobility, toxicity or volume of hazardous substances as a principal element. Additionally, the
selected remedy utilizes alternative treatment technologies or resource recovery technologies to
the maximum extent practicable.
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A. The Selected Remedy is Protective of Human Health and the Environment
The remedy at the Maintenance Yards will permanently reduce the risks posed to human health and
the environment by eliminating, reducing or controlling exposures to human and environmental
receptors through treatment, engineering controls, and institutional controls. Specifically,
the risk presented by the Maintenance Yards is from long-term (working lifetime) direct
contact/ingestion of the surface soil containing cPAHs. Therefore, the selected remedy uses
asphalt batching to immobilize these carcinogenic contaminants, minimizing the toxic effects on
human health and the environment and the potential for off-site run-off of contaminants.
Additionally, asphalt batching soils from the hot spot areas will reduce the mobility of TPHC
contaminants present in the highest concentrations at the site. The stormwater system expansion
and stormwater flow controls will be used as engineering controls to manage increased stormwater
runoff, resulting from the application of the low-impermeable (pavement) surface. Institutional
controls are not needed to minimize human health risk, but will be utilized as a precautionary
measure to prohibit residential development, minimize the possibility of long-term (working
lifetime) exposure to subsurface soils, and to reguire management of soils resulting from
construction related activities.
Moreover, the selected remedy will achieve potential human health risk levels that attain the 10
to 10 incremental cancer risk range for cPAHs.
B. The Selected Remedy Attains ARARs
This remedy will attain all applicable or relevant and appropriate federal and state
reguirements that apply to the Site. No waivers are reguired. ARARs for the Site were
identified and discussed in the FS (Sections 1.7 and 6). Table 19, in Appendix B of this ROD,
presents a tabular summary of the ARARs for the selected remedy, including the regulatory
citation, a brief summary of the reguirement, and how it will be attained. The following is a
summary of the key ARARs and how they pertain to the selected remedy:
Location Specific
Federal Standards:
National Environmental Policy Act; [40 CFR Part 6]. This ARAR is applicable and pertains to the
protection of wetlands. It reguires that Federal agencies minimize the degradation, loss, or
destruction of wetlands, and preserve and enhance natural and beneficial values of wetlands
under Executive Orders 11990 and 11988. The wetlands adjacent to the Maintenance Yards may
currently be impacted by surface water runoff via the storm water system. The selected
alternative covers the site with pavement, thus reducing potential off-site runoff of
contaminants in surface water from soils at the Maintenance Yards to the wetlands. The remedy
will also be designed and constructed to manage the increased flow from the paved surface in a
manner that will minimize impact to adjacent wetlands.
Action Specific
State Standards:
Massachusetts Air Pollution Control Regulations: [310 CMR 6.00 - 7-00]. This ARAR is
applicable and pertains to particulate matter standards (Section 6.0) and application of toxic
air pollutant control program reguirements. Specifically, Section 6.04 provides ambient air
guality criteria such as particulate matter standards which is pertinent to the Maintenance
Yards remedial activity. As a minimum, respirable particulate matter (PM10) for treatment and
excavation activities must be maintained at an annual mean arithmetic concentration of 50 jlg/m3
and a maximum 24-hour concentration of 150 jlg/m3. Section 7.02 provides emissions limitations
from facilities and operations and reguires BACT. The emissions limits for particulate matter
and fugitive emissions at the Maintenance Yards will be managed through engineering controls
during excavation and treatment activities.
Massachusetts Hazardous Waste Management Rules (MHWMR) Identification and Listing of Hazardous
Wastes [310 CMR 30.100]. This ARAR is applicable. The wastes found at this site were
determined not to be characteristic hazardous wastes; however, waste oil is a listed hazardous
waste under this rule.
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Massachusetts Hazardous Waste Management Rules (MHWMR) Provisions for Recyclable Material and
for Waste Oil; [310 CMR 30.200] This ARAR is applicable and contains procedural and substantive
requirements for handling regulated recyclable materials. The substantive requirements include
preventing and reporting releases to the environment, proper maintenance of treatment and
control systems, and handling of regulated recyclable materials. Asphalt batching of soil on
site will comply with the substantive requirements of this regulation.
Massachusetts Hazardous Waste Management Rules (MHWMR) Waste Piles; [310 CMR 30.640 - 30.649].
This ARAR is applicable and pertains to waste pile facilities. A waste pile facility must
install a liner, provide a leachate collection system, provide a run-on/run-off control system,
comply with the groundwater monitoring requirements, perform inspections, and close the facility
properly. These requirements will be addressed in the design of an area for stockpiling of
wastes for on-site treatment.
Massachusetts Hazardous Waste Management Rules (MHWMR) Groundwater Protection; [310 CMR 30.660 -
30.679]. This ARAR is Relevant and Appropriate and pertains to groundwater monitoring that is
conducted during and following remedial actions. Concentration limits for the hazardous
constituents are specified in 310 CMR 30.667. There is no current evidence that contaminants
associated with the Maintenance Yards have adversely affected the groundwater quality. However,
groundwater monitoring will be conducted as a component of the remedy specifically to provide
assurance to the public and the regulatory agencies that the groundwater in the aquifer
underlying the facility remains unaffected by past Maintenance Yard activities and that it
has not been impacted by the remedial activities.
The following guidance will also be considered (TBCs) during implementation of the remedial
action:
Standards for Analytical Data for Remedial Response Action [WSC-300-891] This "To Be
Considered" policy describes the minimum standards for analytical data submitted to the MADEP.
All sampling plans will be designed with consideration of the analytical methods provided in
this non-promulgated advisory.
C. The Selected Remedial Action is Cost-Effective
In the Army's judgment, the selected remedy is cost effective, i.e., the remedy affords overall
effectiveness proportional to its costs. In selecting this remedy, once the Army identified
alternatives that are protective of human health and the environment and that attain, or, as
appropriate, waive ARARs, the Army evaluated the overall effectiveness of each alternative by
assessing the relevant three criteria -- long- term effectiveness and permanence; reduction in
toxicity, mobility, and volume through treatment; and short-term effectiveness, in combination.
The relationship of the overall effectiveness of this remedial alternative was determined to be
proportional to its costs. The costs of this remedial alternative are specified in Table 18.
The Army, based upon USEPA guidance, evaluates cost-effectiveness only in selecting a remedy
from among protective alternatives. Alternatives 1, 2, and 3 in the FS are all less costly than
the selected remedy. However, each of those alternatives allows the surface soils to continue
to pose an unacceptable risk for an excessive time period. This is because each of these
alternatives relies solely on institutional controls in the area where risk is demonstrated to
be outside USEPA's acceptable risk range. Since these alternatives are not sufficiently
protective, their cost-effectiveness cannot be analyzed.
Alternative 9 in the FS is the most expensive alternative and also the least cost-effective,
assuming for comparison that soils treated at the facility would be limited to Maintenance Yards
soils. Any enhanced protectiveness at the Maintenance Yards provided by Alternative 9 is not
proportional to its additional costs. Institutional controls would still be required as a
precautionary measure to prevent future conditions from developing that may result in risk to
human health or the environment. Additionally, Alternative 9 would not have the benefit of
providing greater aquifer protection as does the selected remedy through construction of the
low-permeable (asphalt batched soil) layer.
Alternatives 7 and 8 are less expensive than the selected remedy, but may actually be less cost
effective than the selected remedy. Alternative 7, bioventing, would require an estimated
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treatment time of 10 years, and based on FS treatability testing may not be effective at cPAH
reduction. Alternative 8, Landfarming, would reguire 5 to 7 years (depending upon the timing of
the closure of the Maintenance Yards). It would present a greater short-term exposure to
contaminants, and would not have the benefit of providing greater aguifer protection as does the
selected remedy.
D. The Selected Remedy Utilizes Permanent Solutions and Alternative Treatment or Resource
Recovery Technologies to the Maximum Extent Practicable
Once the Army identified those alternatives that attain or, as appropriate, waive ARARs and that
are protective of human health and the environment, the Army identified which alternative
utilizes permanent solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. This determination was made by deciding which
one of the identified alternatives provides the best balance of trade-offs among alternatives in
terms of: 1) long-term effectiveness and permanence; 2) reduction of toxicity, mobility or
volume through treatment; 3) short-term effectiveness; 4) implementability; and 5) cost. The
balancing test emphasizes long-term effectiveness and permanence and the reduction of toxicity,
mobility and volume through treatment; and considers the preference for treatment as a principal
element, the bias against off-site land disposal of untreated waste, and community and state
acceptance. The selected remedy provides the best balance of trade-offs among the alternatives.
The Army believes that the selected remedy and Alternatives 7, 8, and 9 compare similarly in
terms of long-term effectiveness and permanence, and reduction of toxicity, mobility, or volume
through treatment. The selected remedy and Alternatives 7, 8, and 9 all use treatment
technologies to permanently and irreversibly immobilize or destroy cPAHs in the surface soils.
The selected remedy does not reduce risk by destroying or removing organic contaminants as do
the other three alternatives. However, the selected remedy does immobilize the contaminants in
the asphalt batching process and the resultant material is used on-site as pavement. As a side
benefit, this low-permeable pavement layer provides greater long-term protection of groundwater.
Alternative 7 also involves construction of a pavement surface (low-permeable layer) but
reguires application of nutrients to the soil which is a potential threat to the aguifer below
the site.
The selected remedy reguires the shortest period of time (four months) for remediation, thereby
potentially impacting the surrounding community, workers and the environment for the least
duration. Alternative 7 would also have minimal impact on the community, workers and
environment because remediation would take place in-situ. However, remediation would take
approximately 10 years and would reguire application of nutrients to the soil which would be a
potential threat to the aguifer during this entire period. Alternative 8 reguires five to seven
years of remediation at the site depending upon the timing of the Maintenance Yard closure.
Alternative 9 reguires approximately three months on-site activity and up to four years for
biodegradation of contaminants at a central soil treatment facility.
The selected remedy is the easiest to implement, involving common construction practices.
Alternative 9 reguires siting and construction of an off-site soil treatment facility which
could be difficult in terms of facility siting and other regulatory issues including reuse of
treated soils in a manner compliant with current regulations. Alternatives 7 and 8 would not be
difficult to construct or operate, but pose difficulties administratively due to aguifer
protection concerns. The selected remedy is less expensive than Alternative 9 but more
expensive than Alternatives 7 and 8. As previously discussed in Paragraph C, any enhanced
protectiveness at the Maintenance Yards provided by Alternative 9 is not proportional to the
reguired additional $1,461,000 expenditures.
As described in more detail in the Responsiveness Summary, state and community comments
generally support the Army's choice of the selected remedy. Considering such support, and based
on the above analysis of statutory criteria, the Army believes that the selected remedy utilizes
permanent solutions and alternative treatment or resource recovery technologies to the maximum
extent practicable.
-------
E. The Selected Remedy Satisfies the Preference for Treatment Which Permanently and
Significantly reduces the Toxicity, Mobility or Volume of the Hazardous Substances as a
Principal Element
The principal element of the selected remedy is source control. This element addresses the
primary threat at the Maintenance Yards, which is the threat of ingestion or contact with
contaminated surface soils. The selected remedy satisfies the statutory preference for
treatment as a principal element by treating the contaminants in the surface soils and hot spot
areas, thereby providing significant reduction in the toxicity and mobility of the contaminants.
Therefore, the selected remedy satisfies the statutory preference for treatment as a principal
element.
XIII. DOCUMENTATION OF NO SIGNIFICANT CHANGES
The Army presented a proposed plan (preferred alternative) for remediation of the site on May
16, 1994. The components of the preferred alternative included:
• Excavating surface soil (top two feet across the site),
• Excavating the two hot spot areas,
• Stockpiling soils for sampling and analysis,
• Cold mix asphalt batching soils exceeding site cleanup levels,
• Backfilling excavations with stockpiled soil not found to be contaminated above
cleanup levels and with the asphalt batched material,
• Expanding the existing stormwater collection system,
• Applying a pavement wearing course,
• Performing groundwater monitoring.
• Instituting deed restrictions to either prohibit removal of the top 2-foot cover or
reguiring a physical barrier over the present subsurface soils (existing 2- to
5-foot soil level).
The selected remedy contains no significant changes from that proposed in the Proposed Plan. It
is noted however, that additional deed restrictions have been added. The additional deed
restrictions prohibit residential use and reguire sampling, analysis and management of soils
resulting from construction related excavations.
An additional change concerns the computed acreage of the Maintenance Yards. The Proposed Plan
states that the area of the Maintenance Yards is approximately 8.8 acres. A topographic survey
of the yards performed in July 1994 revealed that the total area is 8.1 acres (7.8 acres
excluding the spill containment basin area).
It is also noted that the U.S. Army Center for Health Promotion and Preventative Medicine
(USACHPPM) conducted a survey in the fall of 1994 to establish the history of radioactive
sources at Fort Devens. The locations and activities of sources, and the uses or accidents that
may have contaminated areas at Fort Devens were presented by USACHPPM in a November 7, 1994
report entitled "Industrial Radiation Historical Data Review No. 27-43-E3QX-95 Fort Devens
Massachusetts." This report identified the Cannibalization Yard and the TDA Maintenance Yard as
areas with potential radioactive contamination. Vehicles and eguipment with radium dials,
depleted uranium armor, and radioluminescent paint were once stored in the TDA Maintenance and
Cannibalization Yards before being dismantled in the Cannibalization Yard for usable parts. To
determine if any release of radioactive material occurred, a scanning survey and soil sampling
program were conducted from December 11 to 15, 1994. Scanning and sampling of surface soils
were performed in accordance with the "Final Radiological Work Plan, AOCs 44 & 52, Barnum Road
Maintenance Yards, Fort Devens, Massachusetts", dated December 14, 1994. Investigation results
are detailed in the "Final Radiological Status Report For Cannibalization Yard & TDA Maintenance
Yard, Fort Devens, Massachusetts" dated March 1995. Results show that the Cannibalization Yard
and TDA Maintenance Yard were well below the levels which pose a risk, and therefore meet the
reguirements for unrestricted use in accordance with U.S. Nuclear Regulatory Commission
guidelines. The USACHPPM data review report, the radiological work plan and the final
radiological status report can be found in the Administrative Record.
-------
XIII. STATE ROIiE
The Commonwealth of Massachusetts has reviewed the various alternatives and has concurred with
the selected remedy for the Maintenance Yards. The state has also reviewed the SI, Risk
Evaluation and FS to determine if the selected remedy is in compliance with applicable or
relevant and appropriate state environmental laws and regulations. A copy of the declaration of
concurrence is attached as Appendix D.
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BARNUM ROAD MAINTENANCE YARDS
AOCs 44 & 52
ROD SUMMARY INDEX OF APPENDICES
PAGE
1. Appendix A - Figures (Site Maps) 1
2. Appendix B - Tables (Contaminant Distributions, Costs, Etc.). 21
3. Appendix C - Responsiveness Summary 64
4. Responsiveness Summary Attachment A (Public Hearing Transcript) 80
5. Appendix D - Declaration of State Concurrence 92
6. Appendix E - Administrative Record Index 95
7. Appendix F - Glossary of Acronyms and Abbreviations 11
-------
DECLARATION FOR THE RECORD OF DECISION
BARNUM ROAD MAINTENANCE YARDS
AREAS OF CONTAMINATION 44 & 52
FORT DEVENS, MASSACHUSETTS
STATEMENT OF PURPOSE
Fort Devens is a Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)
National Priorities List site which is located in Middlesex and Worcester Counties and is within
the Towns of Ayer, Harvard, Lancaster and Shirley, Massachusetts. There are 73 Study Areas
(SAs) and Areas of Contamination (AOCs) at Fort Devens which are currently under investigation.
The Record of Decision relates to the Barnum Road Maintenance Yards (AOCs 44 & 52). The site is
situated in the northeast corner of the Main Post near the Barnum Gate (Figure 1) and
approximately one mile southwest of the Town of Ayer Route 2A/110 intersection. This Decision
Document presents the selected remedial action for the Barnum Road Maintenance Yard operable
unit, developed in accordance with the CERCLA of 1980, as amended, 42 U.S.C. §§ 9601 et seg.
and the National Oil and Hazardous Substance Pollution Contingency Plan (NCP), to the extent
practicable, as amended, 40 C.F.R. Part 300. The Fort Devens Base Realignment and Closure
(BRAG) Environmental Coordinator, the Deputy Assistant Secretary of the Army (Environmental,
Safety, and Occupational Health), and the USEPA Region I Administrator have been delegated the
authority to approve this Record of Decision.
The Commonwealth of Massachusetts has concurred with the selected remedy.
declaration of concurrence is included as Appendix D of this ROD.
A copy of the
STATEMENT OF BASIS
This decision is based on the Administrative Record which has been developed in accordance with
Section 113(k) of CERCLA. The Administrative Record is available for public review at the Fort
Devens BRAG Environmental Office, Building P12, Fort Devens, Massachusetts, and at the Ayer Town
Hall, Main Street, Ayer, Massachusetts. The Administrative Record Index (Appendix E of the ROD)
identifies each of the items comprising the administrative Record upon which the selection of
the remedial action is based.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the Maintenance Yards, if not
addressed by implementing the response action selected in this ROD, may present an imminent and
substantial endangerment to the public health or welfare or to the environment.
DESCRIPTION OF THE SELECTED REMEDY
This ROD sets forth the selected remedy for the Maintenance Yards which will address the
contaminated surface soils and soils associated with two known releases (hot spot areas) at the
Maintenance Yards.
Major Components of the Selected Remedy
Excavate surface soil (top two feet across the site),
Excavate the two hot spot areas,
Stockpile soils for sampling and analysis,
Cold mix asphalt batch soils exceeding site cleanup levels of 7 ppm (average) total
carcinogenic polynuclear aromatic hydrocarbons (cPAHs) and 500 ppm total petroleum
hydrocarbon compounds (TPHC),
Backfill excavations with uncontaminated stockpiled soil and then place the asphalt
batched material,
Apply a pavement wearing course,
Expand the existing stormwater collection system,
Perform groundwater monitoring,
As a precautionary measure, institute the following deed restrictions:
-------
1) prohibit residential development/use of the Maintenance Yards,
2) minimize the possibility of long-term (working lifetime) exposure to
subsurface soils, and
3) reguire management of soils resulting from construction related
activities.
The selected remedy involves excavating the top two feet of soil across the Maintenance Yards
and contaminated soils associated with two hot spot areas (a reported release of "mogas" [motor
vehicle gasoline] and leakage from a 1,000-gallon underground waste oil storage tank).
Excavated soil will be placed in piles at the site for sampling and analysis.
Soils which exceed site cleanup levels will be cold mix asphalt batched. Cold mix asphalt
batching is a technology that entails recycling petroleum contaminated soil into bituminous
paving or road base product at ambient temperatures. Soil with contaminant concentrations below
the cleanup criteria will be placed back in the excavation area. The asphalt batched material
will be placed over the backfill as a base/subbase pavement course for parking lot construction
at the Maintenance Yards. Asphalt batching will immobilize the contaminants exceeding cleanup
levels present in the top two feet, thus minimizing direct contact/ingestion and inhalation of
the soils having a carcinogenic risk. Excavating and asphalt batching soil from the hot spot
areas will reduce the mobility of contaminants present in the highest concentrations at the
Maintenance Yards. Placement of the asphalt batched soils onto the surface of the Maintenance
Yards will also minimize the potential migration of contaminants to the groundwater through the
construction of a low permeable pavement barrier.
The Army has chosen to add a pavement wearing course for a vehicle parking surface over the
asphalt batched material as part of the selected remedy. Addition of the wearing course will
ensure the integrity of the asphalt batched material as a parking lot base for current and
future property use.
Applying the asphalt batched material and pavement wearing course to the Maintenance Yards will
increase the amount of runoff during rain events. Therefore the selected remedy will include
expansion of the existing stormwater collection system. Potentially, a detention basin and flow
reducers will need to be incorporated into the design to minimize wetland impacts.
Sampling and analysis of groundwater from existing wells at the Maintenance Yards will be
performed yearly for a period of five years upon commencement of remedial activities.
As a precautionary measure, institutional controls in the form of deed restrictions will be
implemented to prevent potential circumstances which may result in risk of harm to health,
safety, public welfare or the environment. These restrictions will include:
1. No residential development/use of the Maintenance Yards will be permitted. The guantitative
risk evaluation and established cleanup level assume the property will remain zoned for
commercial/industrial use.
2. Removal of the 2-foot cover or an asphaltic barrier from the Maintenance Yards will be
prohibited to prevent surface soil exposure to existing subsurface soils (2-foot to 5-foot
level). This deed restriction will be implemented as a precautionary measure to minimize the
possibility of long-term (working lifetime) exposure to subsurface soils. This restriction
will not apply to excavations undertaken in connection with construction of buildings or
other structures, utilities, infrastructures or any other construction related purpose where
the cover is penetrated and/or temporarily removed and protection from long-term exposure to
subsurface soil is not jeopardized. To comply with this deed restriction, the 2-foot layer
of cover material (which may consist of one or combination of "clean" site soil used as
backfill, asphalt batched material, off-site soils/aggregate and bituminous pavement) will
remain over the subsurface soil (existing 2- to 5-foot soil level) to minimize direct
contact/ingestion to the present subsurface soils. The continuity of the paved surface need
not be maintained providing the cover thickness of 2 feet is provided. As an alternative, a
continuous and maintained paved surface which would prevent exposure to subsurface soils
could be substituted for the 2-foot thick cover.
-------
This restriction also would not apply to excavation and use that is within the scope of any
authorized response action. The deed restriction may be nullified, as approved by the
regulatory agencies, should there be future evidence showing that contaminant levels within
the 2- to 5-foot soil zone are below site surface soil cleanup levels.
Excavation below 2 feet at the Maintenance Yards, subseguent to completion of the remedial
action established in this ROD, will reguire:
a. Development and implementation of a Health and Safety Plan for the work area; and
b. Development and implementation of a Sampling and Analysis Plan for management of the
excavated soils in accordance with the following:
Where reuse of soil within the Maintenance Yards is intended, sampling and
analysis of stockpiled soils excavated below 2 feet will follow criteria detailed in
this ROD for hot spot area soils. Soils with contaminants exceeding the 500 ppm
cleanup level for TPHC will be treated in a manner consistent with this ROD. Soils
with contaminants below the established cleanup level may be returned to the
excavation. Soil excavated below 2 feet but returned to the top 2 feet (as surface
soil) must also be sampled, analyzed and, if reguired, treated for cPAH contaminants
as detailed in this ROD.
Where reuse of soil outside the Maintenance Yards is intended, sampling/analysis and
action levels for stockpiled soils excavated below 2 feet will follow criteria
governed by the regulations or policies in effect for the final disposal area.
-------
DECLARATION
The selected remedy is protective of the human health and the environment, attains federal and
state requirements that are applicable or relevant and appropriate for this remedial action, and
is cost effective. This remedy satisfies the statutory preference for remedies that utilize
treatment as a principal element to reduce the toxicity, mobility, or volume of hazardous
substances. In addition, this remedy utilizes permanent solutions and innovative treatment
technologies to the maximum extent practicable.
The foregoing represents the selection of a remedial action by the Department of the Army and
the United States Environmental Protection Agency, Region I, with the Concurrence of the
Commonwealth of Massachusetts Department of Environmental Protection. Concur and recommend for
immediate implementation:
UNITED STATES DEPARTMENT OF THE ARMY
JAMES C. CHAMBERS Date
Fort Devens
BRAG Environmental Coordinator
The foregoing represents the selection of a remedial action by the Department of the Army and
the United States Environmental Protection Agency, Region I, with the Concurrence of the
Commonwealth of Massachusetts Department of Environmental Protection. Concur and recommend for
immediate implementation:
UNITED STATES DEPARTMENT OF THE ARMY
Edward R. Nuttall Date
Colonel, U.S. Army
Installation Commander
The foregoing represents the selection of a remedial action by the Department of the Army and
the United States Environmental Protection Agency, Region I, with the concurrence of the
Commonwealth of Massachusetts Department of Environmental Protection. Concur and recommend for
immediate implementation:
U.S. ENVIRONMENTAL PROTECTION AGENCY
JOHN P. DEVILLARS Date
Regional Administrator
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RECORD OF DECISION
BARNUM ROAD MAINTENANCE YARDS
AREAS OF CONTAMINATION 44 & 52
FORT DEVENS, MASSACHUSETTS
MARCH 1995
BARNUM ROAD MAINTENANCE YARDS
AOCs 44 & 52
ROD SUMMARY
APPENDIX A
FIGURES
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BAENUM ROAD MAINTENANCE YARDS
AOCs 44 & 52
ROD SUMMARY
APPENDIX B
TABIiES
-------
TABIiE 1
AOC 44 -CANNIBALIZATION YARD
44B - 92 - 01X
ANALYTE BORING
VOLATILES (ug/g)
ETHYLBENZENE < 0.0017 < 0.0017 < 0.0017 < 0.0017
TOLUENE < .00078 < .00078 < .00078 < .00078
XYLENES < 0.0015 < 0.0015 < 0.0015 < 0.0015
44B - 92 - 02X
< 0.0017 < 0.0 0.0017
< .00078 < .00.00078
< 0.0015 < 0.00.0015
DEPTH
10
10
< 0.0017 < 0.0017 < 0.0017 < 0.0017 < 0.0017 < 0.0017 < 0.0017
< .00078 < .00078 < .00078 < .00078 < .00078 < .00078 < .00078 .00078
< 0.0015 < 0.0015 < 0.0015 < 0.0015 < 0.0015 < 0.0015 < 0.0015
SEMI VOLATILES (]lg/g)
2 -METHYLNAPHTHALENE < 0 . 2 0 0
ACENAPHTHENE
ACENAPHTHYLENE
ANTHRACENE
0.400
4.00
5.00
BIS (2-ETHYLHEXYL) PHTHALAT <3
BENZO [A] ANTHRACENE
BENZO [A] PYRENE
BENZO [B] FLOURANTHENE
BENZO [G,H, I] PERYLENE
BENZO [K] FLUORANTHENE
CARBAZOLE
CHRYSENE
DIBENZO [A, H] ANTHRACENE
DIBENZOFURAN
FLUORANTHENE
FLUORENE
20.0
30.0
20.0
20.0
20.0
2.00
20.0
5.00
0.400
50.0
1.00
< 0
< 0
0.
0
.00
0
0
0
0
.
.
100
070
300
.
2
2
3
3
2
.
3
.
.
7
.
INDENO[1,2,3,-C,D] PYRENE
NAPHTHALENE
PHENANTHRENE
PYRENE
0.600
20.0
20.0
< 0
.
3
3
700
<1
.00
.00
.00
.00
.00
500
.00
900
200
.00
300
20.
070
.00
.00
< 0
< 0
< 0.
< 0
.00
< 0
< 0
< 0
< 0
< 0
ND 0
0
< 0
< 0
0
< 0
0
< 0
< 0
0
.049
.036
033
.036
< 0.
.170
.250
.210
.250
.110
.033
.160
.210
.035
.250
.033
3.00
.037
.033
.190
< 0
< 0
< 0.
< 0
620
< 0
< 0
< 0
< 0
< 0
ND 0
< 0
< 0
< 0
0
< 0
< 0
< 0
< 0
0
.049
.036
033
.033
< 0.
.170
.250
.210
.250
.066
.003
.120
.210
.035
.085
.033
.290
.037
.033
.049
< 0
< 0
< 0.
< 0
,620
< 0
< 0
< 0
< 0
< 0
ND 0
< 0
< 0
< 0
0
< 0
< 0
< 0
< 0
0
.049
.036
033
.033
< 0
.170
.250
.210
.250
.066
.033
.120
.210
.035
.088
.033
.290
.037
.033
.089
< 0.049 < 1.0
< 0.
< 0.033 < 0.700
< 0.
.620 < 0.620
< 0.
0.033 ND 0.033 :
< 0.
< 0.210
< 0.
< 0.
< 0.
< 0.29
< 0.
< 0.
< 0.
< 0.049 < 0.200
< 0.033
< 10.0
< 0.200
< 0.620
6.00
3.00
< 0.049
< 0.033
< 3.00 < 30.0
< 0.049
< 0.033
< 0.620
0.700
< 0.300
1.10
< 6
ND 0.033 ND 0.700 ND 0.033 ND 0.200 20.0 ND 0.033 ND ND 0.300
ND 0.200
< 4.00
< 0.210
< 1.00 < 10.0
< 0.210
< 0.210
< 2
OTHER (ug/g)
TRICHLOROFLUOROMETHANE < 0.0059 < 0.0059 < 0.0059 < 0.0059 < 0.0059 0.0059
TPHC 714 76.2 < 27.9 < 27.9 < 27.9 < 2
0.0059 < 0.0059
< 0.0059 < 0.0059 < 0.0059 < 0.0059 < 0.0059
NOTES: TABLE LISTS DETECTED ANLAYTES ONLY - SEE PROJECT ANALYTE IN SI REPORT FOR SUMMARY
ND = NOT DETECTED
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TABLE 2
ORGANIC COMPOUNDS IN SOIL
AOC 52 - TDA MAINTENANCE YARD
FORT DEVENS, MASSACHUSETTS
FORT DEVENS
VOLATILES (ug/g)
ETHYLBENZENE
TOLUENE
EXYLENES
ACENAPHTHENE
ACENAPHTHYLENE
ANTHRACENE
BIS(2-ETHYLHEXY
BENZO[A]ANTHRACENE
BENZO[A]PYRENE
BENZO[B]FLUORANTHENE
BENZO[G,H]IERPYLENE
BENZO[K]FLUORANTHENE
CARBAZOLE
CHRYSENE
DIBENZO[A,H]AN
DIBENZOFURAN
FLUORANTHENE
FLUORENE
INDENO[1,2,3-C
NAPHTHALENE
PHENANTHRENE
PYRENE
<
,)PHTHALATE
1NE
<
'HENE
,ENE
'HENE
[RACENE <
<
<
D] PYRENE<
<
0.072 <
0.168 <
0.122
< 1.24 <
0.399
0.500 <
1.08 <
0.622 <
0.439
ND 0.066
0.777
0.420 <
0.070 <
1.71
0.066 <
0.669 <
0.074 <
0.400
1.00 1
0. 072
0.066
0.143
1.24
0.391
0.500
0.420
0.500
0.430
ND 0.066
0.761
0.420
0. 070
1 . 92
0.066
0.580
0.074
1.28
.00
< 0. 180 <
< 0.165 <
< 0. 165 <
< 3.10 <
< 0. 800 <
< 1.25 <
< 1. 05 <
< 1.25 <
< 0.330 <
ND 0.165
< 0. 600 <
< 1. 05 <
< 0. 175 <
< 0.340 <
< 0. 165 <
< 1.45 <
< 0. 185 <
< 0. 165 <
< 0. 165
0.036 <
0.033
0.033
0.620 <
0.170
0.250
0.210
0.250
0.066
ND 0.033
0.120
0.210
0.035 <
0.068
0.033 <
0.290 <
0.037 <
0.033
0.049
OTHER (ug/g)
TOTAL ORGANIC CARBON
TPHC
NA
48.5
NA
97.5
NOTES: TABLE LISTS DETECTED ANLAYTES ONLY - SEE PROJECT ANALYTE LIST IN SI REPORT FOR SUMMARY
ND = NOT DETECTED
NA = NOT ANALYZED
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TABLE 2
(continued)
ORGANIC COMPOUNDS IN SOIL
AOC 52 - IDA MAINTENANCE YARD
ANALYTE BORING
VOLATILES (ug/g)
ETHYLBENZENE
TOLUENE
XYLENES
ACENAPHTHENE
ACENAPHTHYLENE
ANTHRACENE
BIS(2-ETHYLHEXYL)PHTHALATE
BENZO[A]ANTHRACENE
BENZO[A]PYRENE
BENZO[B]FLUORANTHENE
BENZO[G,H,I]PERYLENE
BENZO[K]FLUORANTHENE
CARBAZOLE
CHRYSENE
DIBENZO[A,H]ANTHRACENE
DIBENZOFURAN
FLUORANTHENE
FLUORENE
INDENO[1,2,3-C,D]PYRENE
NAPHTHALENE
PHENANTHRENE
PYRENE
< 4.25 < 0.170 < 0.170 < 4.25 < 4 < 0.340
< 6.25 < 0.250 < 0.250 < 6.25 0.500
< 5.25 < 0.210 < 0.210 < 5.25 < 5
< 6.25 < 0.250 < 0.250 < 6.25 0.500
< 1.65 < 0.085 < 0.066 < 1.65 0.430
ND 0.825 ND 0.033 ND 0.033 ND 0.825 N 0.165
< 3.00 0.091 < 0.120 < 3.00 < 3 0.507
< 5.25 < 0.210 < 0.210 < 5.25 < 0.0420
< 0.875 < 0.035 < 0.035 < 0.875 < 0. < 0.070
< 1.70 0.288 < 0.068 < 1.70 < 1
< 0.825 < 0.033 < 0.033 < 0.825 < 0.8 0.066
< 7.25 < 0.290 < 0.290 < 7.25 0.580
< 0.900 < 0.037 < 0.037 < 0.900 < 0. < 0.074
< 0.825 0.092 < 0.033 < 0.825
2.18 0.282 < 0.033 < 0.825 < 0.
OTHER (ug/g)
TOTAL ORGANIC CARBON
TPHC
NA
65. 1
NA
304
NA
129
NOTES: TABLE LISTS DETECTED ANALYTES ONLY - SEE PROJECT ANALYTE LIST IN REPORT FOR SUMMARY
ND = NOT DETECTED
NA = NOT ANALYZED
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TABLE 3
INORGANIC ANALYTES IN SOIL
AOC 44 - CANNIBALIZATION YARD
FORT DEVENS, MASSACHUSETTS
GROUND DEPTH
ALUMINUM
ANTIMONY
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
NICKEL
POTASSIUM
SODIUM
VANADIUM
ZINC
NOTES: TABLE LISTS DETECTED ANALYTES
NA = NOT ANALYZED
ONLY - SEE PROJECT ANALYTE LIST SI REPORT FOR SUMMARY
-------
TABLE 4
INORGANIC ANALYTES IN SOIL
AOC 52 - TDA MAINTENANCE YARD
FORT DEVENS, MASSACHUSETTS
ALUMINUM
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
NICKEL
POTASSIUM
SODIUM
VANADIUM
ZINC
14200 5160
21.0 16.0
80.7 2
347 0. 9
< 0.700 <
1280
47.7 15.2
8.66 4.35
15. 1
16900
17. 0
8190
293
38.4
4370
296
32.1
41.3
4390
19. 0
1.0 19
39
15
.5
39 < 0.500 0
0.700 < 0
439
13.3
3 . 9
9.11
7910
8.10
2590
162
14.2
912
165
10.2
21.4
.700
386
11
3 .
9.14
6760
6.27
2130
149
12.7
858
150
8.61
19.2
30 7
.0 9
15.2
. 628 <
< 0.700
358
.5 1
65 3
7.97
7580
5.58
1990
125
10. 8
551
140
7.99
19. 8
010
.04
19
0.55
< 0
2.5
. 68
2960 5410 3390 3900 7360
14 8.21 15.0 11.2 7.11 7
19.6 14.2 19.9
0 < 0.500 < 0.500 < 0.500 < 0.500
0.700 <
304
18.3
4.54
8.14
8470
3.73
1700
104
16.7
855
192
8.97
28.4
NOTES: TABLES LISTS DETECTED
ND = NOT DETECTED
NA = NOT ANALYZED
NALYTES ONLY - SEE PROJECT ANALYTE LIST IN SI REPORT FOR SUMMARY
-------
TABLE 4 (continued)
INORGANIC ANALYTES IN SOIL
AOC 52 - TDA MAINTENANCE YARD
FORT DEVENS, MASSACHUSETTS
ALUMINUM
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
NICKEL
POTASSIUM
SODIUM
VANADIUM
ZINC
NOTES: TABLE LISTS DETECTED
NA = NOT ANALYZED
iNALYTES ONLY - SEE PROJECT ANLAYTE LIST IN SI REPORT FOR SUMMARY
-------
TABLE 5
ANALYTES IN SOIL - SUPPLEMENTAL SITE INVESTIGATION
AOC 44 - CANNIBALIZATION YARD
ANALYTE
ORGANICS
GROUND DEPTH
21
BIS(2-E-H)PHTHALATE
FLUORANTHENE
PHENANTHRENE
PYRENE
TPHC
< 0.62 < 0.62
< 0.07 < 0.07 0.07
< 0.03 < 0.03 0.03
< 0.03 < 0.03 0.03
121 < 29.5 29.6
< 0.62 1.4
< 0.07 < 0.07
< 0.03 < 0.03
< 0.03 < 0.03
< 29.5 < 33.1
INORGANICS
ALUMINUM
ANTIMONY
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
NICKEL
POTASSIUM
SODIUM
VANADIUM
ZINC
15000
NA
21
42.5
0
2.00
1400
31
NA
8.39
15000
34 .4
5600
300
14 .0
1700
131
28.7
35.5
347
NA
NA
NA
NOTES: TABLE LISTS DETECTED ANALYTES ONLY - SEE PROJECT ANALYTE LIST IN SI REPORT (ABB-ES, 1993)
NA = NA ANALYZED
-------
TABLE 6
ANALYTES IN GROUNDWATER - ROUND 1 (June 1993) AND ROUND 2 (September 1993)
AOC 44 GROUNDWATER - SUPPLEMENTAL SITE INVESTIGATION
FORT DEVENS, MASSACHUSETTS
G3M-93-11X
filtered
ORGANICS (ug/L)
BIS (2-ETHYLHEXYL)
TETRACHLOROETHENE
TOLUENE
TPHC
INORGANICS (ug/L)
ALUMINUM
ANTIMONY
ARSENIC
BARIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
NICKEL
POTASSIUM
SODIUM
VANADIUM
ZINC
PHTHALATE
6870
3.03
10.5
39.6
14700
14 .7
25.0
8.09
9100
4.25
3480
291
34 .3
2370
10800
11.0
21 .1
22
<1.6
<0.5
< 178
6310
<3.0
49.1
44 .4
13000
10.4
<25.0
16.7
13200
14 .9
3030
510
<34 .3
3710
24500
14 .9
27.8
< 4 .80
<1.6
<0.5
< 178
41600
4.2
157
250
13900
74.9
70.0
113
86300
103
13500
9500
140
9330
16900
73.1
157
<
16
<
9
7
7
2
<2
4
31
2
1
5
16
2
7
ANIONS/ CAT IONS (ug/L)
BICARBONATE
CHLORIDE
SULFATE
NITRATE/NITRITE
ALKALINITY
OTHER (mg/L)
TSS
NA
NA
NA
NA
NA
206
NA
NA
NA
NA
NA
1110
NA
NA
NA
NA
NA
569
NOTES:
TABLE LISTS DETECTED ANALYTES ONLY - SEE PROJECT ANALYTE LIST SI REPORT (A 1993)
NA = Not Analyzed
-------
TABIiE 7
SUMMARY OF CONTAMINATES OF CONCERN IN SURFACE SOIL
AOCs 44 & 52 - MAINTENANCE YARDS
FORT DEVENS, MASSACHUSETTS
Analyte Detected Concentration [a]
Average Maximum
Organics (ug/g)
Frequency of Analyte
Detection
Inorganics (ug/g)
ethylbenzene
toluene
xylenes
2-methylnaphthalene
acenaphthene
acenapthylene
anthracene
benzo(a)anthracene
benzo(a)pyrene
benzo(b)fluoranthene
benzo(g,h,i)perylene
benzo(k)fluoranthene
carbazole
chrysene
dibenzo(a,h)anthracene
dibenzofuran
fluoranthene
fluorene
indeno(1,2,3-c,d)pyrene
naphthalene
phenanthrene
pyrene
0.
0.
0049
0016
0.01355
2
1
6.7
.238
.207
3.38
8.69
10.
9.
6.
6.
3.
,97
,03
,82
,01
,54
0.0049
0.0023
0.022
6.7
6.0
4.0
20.0
40.0
30.
30.
20.
30.
20.
,0
,0
,0
,0
,0
1/15
2/15
2/15
1/15
3/15
8/15
9/15
9/15
8.71
3.67
16.5
4.45
6.95
13.5
10.4
2.8
7.21
50.0
10.0
100.0
20.0
20.0
100.0
60.0
arsenic
barium
beryllium
cadmium
chromium 15/15
copper
iron 18900 15/15
lead 15/15
7/15 magnesium
9/15 manganese 15/15
8/15 nickel
11/15 potasSi 15/15
7/15 sodium
12/15 vanadium
5.0 2/15 zinc 15/15
3/15
13/15 Notes:
5/15 [a] Surface soil s station 44B-92-01X to 44B-92-05X,
20.0 8/15
3/15
12/15
14/15
52B-92-01X to 52B-92-09X, and G3M-92-04X.
-------
TABLE 8
SUMMARY OF CONTAMINANTS OF CONCERN SUBSURFACE SOIL
AOCs 44 5 52 - MAINTENANCE YARDS
FORT DEVENS, MASSACHUSETTS
Analyte
Organics (ug/ g)
acenaphthylene
anthracene
bis (2-ethylhexyl ) phthalate
benzo (a) anthracene
benzo (a) pyrene
benzo (b) fluoranthene
benzo (g,h, i)perylene
benzo ( k) fluoranthene
carbazole
chrysene
di benzo ( a, h) anthracene
dibenzof uran
fluoranthene
f luorene
0. 177 0.3
0.272 0.7 4/31
1. 04 1.1
0. 928 2. 0 3/31
1.37 2.0
1.49 3.0
1.81 3.0
0.460 2.0
0.302 0.5
0.943 3.0 9/31
0.90 0.90
0.20 0.20 1/31
1.24 7.0 15/31
0.30 0.30 1/31
Inorganics (ug/ g)
3/31 arsenic
barium
2/31 berylli
chromiun
2/31 copper
5/31 iron
2/31 lead
11/31 magnesi
2/31 mangane
nickel
1/31 pottasi
sodium
vanadium
zinc
indeno(l,2,3-cd)pyrene
-------
TABIiE 9
DIRECT CONTACT WITH AND INCIDENTAL INGESTION OF SURFACE AND SUBSURFACE SOI
USEPA REGION I B(a)P APPROACH FOR PAHS
RECEPTOR: CONSTRUCTION WORKER
AOCs 44 AND 52 - AVERAGE CONCENTRATIONS
FORT DEVENS, MA
EXPOSURE PARAMETERS
PARAMETER
CONCENTRATION SOIL
INGESTION RATE
FRACTION INGESTED
SOIL ADHERENCE FACTOR
SURFACE AREA EXPOSED
CONVERSION FACTOR
BODY WEIGHT
EXPOSURE FREQUENCY
EXPOSURE DURATION
AVERAGING TIME
INTAKE-INGESTION=
CANCER AT
NONCANCER AT
SYMBOL
CS
IR
FI
SAF
SA
CF
BW
EF
ED
VALUE U
Average m
480
100%
1
3,295
0.000001
70
5 days/W'
12
EQUATIONS
UNITS SOURCE
ing/kg CANCE
ing/day USEPA, 199
mg/cm2 USEPA, 199
cm2/day USEPA, 198
kg/mg
kg USEPA, 1989a INTAKE-INGESTION=
>rkweek PRO. JUDGEMENT
workweek(s) PRO. JUDGE
CS X IR X RAF X FI X CF X EF X ED
CS X IR X RAF X FT X CF X EF X ED
70 years USEPA, 1989a RISK)
12 workweek(s) USEPA, 1989a
BW x AT x 365 days/yr
USEPA, 1991 "Human Health Evaluation Manual, Supplemental Guidance: Stand INTAKE-DERMAL =
Exposure Factors". (HQ)
CS x SA x SAF x RAF x CF x EF x ED
USEPA, 1992. Dermal Exposure Assessment: Principles and Applications, In EPA/600/8-91/011B, January 1992.
INTAKE-DERMAL= CS x SA x SAF x RAF x CF x EF x ED
USEPA, 1989a. RAGs, Part A.
USEPA, 1989b. Exposure Factors Handbook.
(CA RISK) BW x AT x 365 days/yr
(1) Arms and Hands noncarcinogenic effects: AT = ED
-------
TABIiE 9, continued C
DIRECT CONTACT WITH AND INCIDENTAL INGESTION OF SURFACE AND SUBSURFACE SOI
USEPA REGION 1 B(a)P APPROACH FOR PAHS
RECEPTOR: CONSTRUCTION WORKER
AOCs 44 AND 52 - AVERAGE CONCENTRATIONS
FORT DEVENS, MA
CARCINOGENIC EFFECTS
SOIL INGESTION INTAKE
COMPOUND CONCENTRATION RAF
(mg/kg)
Bis (2-ethyhexyl)phthalate 1.941
Benzo (a) anthracene 2.078
Benzo (a) pyrene 2.241
Benzo (b) fluoranthene 2.318
Benzo (k) fluoranthene 1.658
Carbazole 0.621
Chrysene 2.581
Diben ( a, h, ) anthracene 0.782
Indeno(l, 2, 3-cd) pyrene 2.001
Arsenic 12.36
Beryllium 0.514
Lead 10.188
I RISK 2E-06
DERMAL
INGESTION
(mg/kg-day)
1 3.1E-08
1 3.3E-08
1 3.6E-08
1 3.7E-08
1 2.7E-08
1 l.OE-08
1 4.2E-08
1 1.3E-08
1 3.2E-07
1 2.0E-09
1 8.3E-09
0.5 8.2E-08
SUMMARY
2E-06 4E-06
(mg/:
0.
0.2
0.2
0.2
0.2
1
0.2
0.09
0.2
0.03
0.35
NA
(mg/kg-(mg/kg-day)-1
RISK
-------
TABIiE 9, continued CON
DIRECT CONTACT WITH AND INCIDENTAL INGESTION OF SURFACE AND SUBSURFACE SOI
USEPA REGION I B(a)P APPROACH FOR PAHS
RECEPTOR: CONSTRUCTION WORKER
AOCs 44 AND 52 - AVERAGE CONCENTRATIONS
FORT DEVENS, MA
NONCARCINOGENIC EFFECTS
SOIL INGESTION INTAKE DERMAL I
COMPOUND CONCENTRATION RAF INGESTION RAF D
(mg/kg) (mg/kg-day) (mg/kg-day) (mg/kg-day) INGESTION DERMAL QUOTIENT
1.2E-09 2.8E-09
1.8E-09 4.0E-09
3.7E-06 6.4E-06
6.3E-05 1.1E-04
4.7E-04 8.2E-04
Ethylbenzene
Toluene
Xylenes
2-Mehtylnaphthalene
Acenaphthene
Acenaphthyl ene
Anthracene
0.000936
0.000441
0.00129
0.
0.
0,
235
0,
742
Bis (2-ethylhexyl)phthalate
Benzo (a) anthracene
Benzo (a) pyrene
Benzo (b) f luoranthene
Benzo (g,h, i) perylene
Benzo (k) f luoranthene
Carbazole
Chrysene
Dibenz (a,h) anthracene
Dibenzofuran
Fluorothene
Fluorene
Indeno (1,2, 3-cd) pyrene
Naphthalene
Phenanthrene
Pyrene
Arsenic
Barium
2.
2.
0.
5.
0.
0.
3.
3.
12
24.
078
2,
2,
1.
1.
0,
581
0,
327
044
564
2,
554
658
405
.36
907
.267
.297
1.941
.241
.318
.839
.658
.621
.782
.001
1
1
1
1
1
0
0
1
1
1
0
1
1
1
1
0.
1
.91
0.
0.
0.
0.
1
.91
0.
NA
0.
.91
6.4E-09
3.0E-09
8.8E-09
1.
1.6E-06
,91
5.1E-06
1.
1.
,91
,91
,91
,91
1.
,91
3.5E-05
3.9E-06
,91
3.8E-06
2.
2.3E-05
8.5E-05
1.7E-04
8E-06
1.
3E-05
3E-05
1.
1.
1.
1.
4.
6E-05
4.
1.
3E-05
0.2
0.12
0.12
0.2
9E-06
0.29
4E-05
4E-05
IE-OS
OE-05
3E-06
9E-06
NA
0.2
0.2
2E-05
0.1
0.2
0.03
0.35
2.5E-2
7.3E-4
0.1
2.2E-0
0
l.OE-
0.02
0.18
0
0
0
0
1
0.18
0
4.7E-
5.3E-0
0
2.6E-
0.18
3.2E-0
1.7E-0
4.1E-0
1.5E-09
2.2E-09
.6 2.7E-06
0.04 4.6E-05
0.04 3.5E-04
NA
.4 9.7E-06
0.04 3.1E-04
.3 7.8E-05
.0003 2.
.07 2.4E-03
8E-01
1.3E-05 2.3E-05
4.2E-04 7.4E-04
1.1E-04 1.8E-04
5.8E-02 3.4E-01
5.9E-03 8.3E-03
-------
TABIiE 9, continued
DIRECT CONTACT WITH INCIDENTAL INGESTION OF SURFACE AND SUSURFACE SOIL - U REGION 1 B(a)P APPROACH FOR PAHS
RECEPTOR: CONSTRUCTION WORKER
AOCs 44 and 52 - AVERAGE CONCENTRATIONS
FORT DEVENS, MA
NONCARCINOGENIC EFFECTS
SOIL
COMPOUND
(mg/kg)
Beryllium
Cadmium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Sodium
Vanadium
Zinc
INGESTION INTAKE
CONCENTRATION RAF
(mg/kg-day)
DERMAL INTAKE REFERENCE HAZARD HAZARD TOTAL
INGESTION RAF
(mg/kg-day) (mg/kg-day) INGESTION DERMAL QUOTIENT
0.
17.
8.
8547.
10.
15.
155.
10.
26.
0
635
192
885
391
189
2504
299
1008
042
942
532
.514 1
1
1
1
1
0.5
.574 1
154.293
1
.659 1
1
1
1
4.
1.
6.
5.
3.
1
1.
1.
7.
1.
3.5E-06
,4E-06
,2E-04
. IE-OS
, 9E-02
,5E-05
1.7E-02
1.
, OE-04
6.9E-03
, 1E-03
,5E-05
,8E-04
0
0
0
0
0.
.14
.09
.35
.35
006
0
4
7
1
1
2
0
1E-03
0
0
0
0
.35
.35
.35
.02
2
0
2
1
2
35 8.5E-7.0E-04
2E-06 4.4E-03
3E-05 5.9E-03
5E-04
4E-01
9E-06
35 4.1E-
0.35 1.1E-02
5E-04 5.2E-03
35 1.7E-
6E-03
1.8E-04 1.1E-02
1.7E-03 2.4E-03
4.2E-03 8.5E-03
3.6E-03 9.5E-03
2.5E-02 3.6E-02
1.3E-02 1.8E-02
2.6E-02 3.6E-02
SUMMARY HAZARD INDEX
0.33
0.14
0.47
-------
TABIiE 10 CONS
DIRECT CONTACT WITH AND INCIDENTAL INGESTION OF SURFACE AND SUBSURFACE SOIL
USEPA REGION I B(a)P APPROACH FOR PAHS
RECEPTOR: CONSTRUCTION WORKER
AOCs 44 AND 52 - MAXIMUM CONCENTRATIONS
FORT DEVENS, MA
EXPOSURE PARAMETERS EQUATIONS
PARAMETER SYMBOL VALUE UNITS SOURCE
CONCENTRATION SOIL CS Maximum mg/kg
INGESTION RATE IR 480 ing/day USEPA, 1991
FRACTION INGESTED FI 100%
HAZARD QUOTIENT = INTAKE (mg/kg-day) / REFERENCE DOSE (mg/kg-day)
SOIL ADHERENCE FACTOR SAF 1 mg/cm2 USEPA, 1992
SURFACE AREA EXPOSED SA 3,295 cm2/day USEPA, 1989b (1)
(INTAKE INGESTION) + (INTAKE-DERMAL)
CONVERSION FACTOR CF 0.000001 kg/mg
BODY WEIGHT BW 70 kg USEPA, 1989a
INTAKE-INGESTION= CS X IR X RAF X FI X CF X EF X ED
EXPOSURE FREQUENCY EF 5 days/workweek PRO. JUDGEMENT
EXPOSURE DURATION ED 12 workweek(s) PRO. JUDGEMENT
INTAKE-INGESTION= CS X IR X RAF X FI X CF X EF X ED
AVERAGING TIME
(CANCER RISK) BW x AT x 365 days/yr
CANCER AT 70 years USEPA, 1989a
NONCANCER AT 12 workweek(s) USEPA, 1989a
USEPA, 1991 "Human Health Evaluation Manual, Supplemental Guidance: Stan
INTAKE-DERMAL= CS x SA x SAF x RAF x CF x EF x ED
Exposure Factors". (HQ
USEPA, 1992. Dermal Exposure Assessment: Principles and Applications, In
EPA/600/8-91/011B, January 1992.
INTAKE-DERMAL= CS x SA x SAF x RAF x CF x EF x ED
USEPA, 1989a. RAGs, Part A. (CAN RISK) BW x AT x 365 days/yr
USEPA, 1989b. Exposure Factors Handbook. (1) Arms and Hands noncarcinogenic effects: AT = ED
-------
TABIiE 10, continued
DIRECT CONTACT WITH INCIDENTAL OF SURFACE AND SUBSURFACE ANS SUBSURFACE SO
USEPA REGION I B(a)P APPROACH FOR PAHS
RECEPTOR: CONSTRUCTION WORKER
AOCs 44 and 52 - MAXIMUM CONCENTRATIONS
FORT DEVENS, MA
CARCINOGENIC EFFECTS
SOIL
COMPOUND
Bis(2-ethylhexyl)phthalate
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Carbazole
Chrysene
Dibenz(a,h)anthracene
Indeno(1,2,3-cd)pyrene
Arsenic
Beryllium
Lead
SUMMARY CANCER RISK 2E-05 3E-05 5E-05
INGESTION
"CENTRATION
;g)
20
30
30
30
20
50
5
20
29
1.15
53
INTAKE DERMAL I
RAF INGESTION
(mg/kg-day) -1
7.75 1 1.2E-07
1 3.2E-07 0.2 4.4E-
1 4.8E-07 0.2
1 4.8E-07 0.2
1 4.8E-07 0.2
1 3.2E-07 1
1 8.1E-07 0.2 1.1E-
1 8.1E-08 0.09
1 3.2E-07 0.2
1 4.7E-07 0.03 9.6E-
1 1.9E-08
0.5 4.3E-07 NA
-------
TABIiE 10, continued
DIRECT CONTACT WITH AND INCIDENTAL INGESTION OF SURFACE AND SUBSURFACE SOI
USEPA REGION I B(a)P APPROACH FOR PAHS
RECEPTOR: CONSTRUCTION WORKER
AOCs 44 AND 52 - MAXIMUM CONCENTRATIONS
FORT DEVENS, MA
NONCARCINOGENIC EFFECTS
SOIL INGESTION INTAKE DERMAL INTAKE
COMPOUND CONCENTRATION RAF INGESTION RAF DOSE
(mg/kg) (mg/kg-day) (mg/kg-day) (mg/k
INGESTION DERMAL QUOTIENT
1
4
3
Ethylbenzene 0.0049 1
Toluene 0.0023 1
Xylenes 0.022 1
2-Methylnaphthalene 6 1
.OE-03 7.1E-04 1.7E-03
Acenaphthene 6 1
Acenaphthylene 4 0.91
Anthracene 20 1
.6E-05 9.1E-05 1.4E-04
Bis (2-ethylhexyl)phthalate 7.75
Benzo (a) anthracene 20 0.91
. 1E-03 4.2E-03 7.4E-03
Benzo (a) pyrene 30 0.91
Benzo (b) fluoranthene 30 0.91
3.4E-08 0.2 4.6E-
1.6E-08 0.12 1.3E-
1.5E-07 0.12 1.2E-
4.1E-05 0.1
4.1E-05 0.2 5.6E-
2.5E-05 0.18
1.4E-04 0.29 2.7E-
1 5.3E-05 0.02
1.2E-04 0.18 1.7E-
1.9E-04 0.18
1.9E-04 0.18
Benzo(g,h,i)perylene 30 0.91 1.9E-04 0.18
4.7E-03 6.4E-03 1.1E-02
Benzo(k)fluoranthene 30 0.91 1.9E-04 0.18
4.7E-03 6.4E-03 1.1E-02
Carbazole 20 1 1.4E-04 1
4.6E-07 8.0E-07
-------
Chrysene 50 0.91 3.1E-04 0.18 4.2E-
Dibenz(a,h)anthracene 5 0.91 3.1E-05 0.08
7.8E-04 4.7E-04 1.3E-03
1
3
1
Dibenzofuran
Fluor anthene
.7E-03 2.4E-03
Fluorene
Indeno(l,2,3-cd)
Naphthalene
.4E-03 2.4E-03
Phenanthrene
.6E-02 2.1E-02
Pyrene
Arsenic
Barium
10
100
4.1E-03
20
pyrene
20
5.8E-03
100
3.7E-02
60
29
95.3
NA
1
1
20 0.91
1
0.91
1
1
1
6.
1.
1.
6.
4.
2.
6.
NA
9E-04 0.2
4E-04 0.2
1.2E-04 0.18
4E-04 0.1
2E-04 0.18
1E-04 0.2
OE-04 0.03
5E-04 0.35
NA
9.4E-
1.9E-
9.4E-
8.5E-
5.6E-
4.1E-
1.6E-
-------
TABIiE 10, continued
DIRECT CONTACT WITH AND INCIDENTAL INGESTION OF SURFACE AND SUBSURFACE SOI
USEPA REGION I B(a)P APPROACH FOR PAHS
RECEPTOR: CONSTRUCTION WORKER
AOCs 44 AND 52 - MAXIMUM CONCENTRATIONS
FORT DEVENS, MA
NONCARCINOGENIC EFFECTS
SOIL INGESTION INTAKE
REFERENCE HAZARD HAZARD TOTAL
DERMAL
INTAKE
COMPOUND CONCENTRATION
INGESTION DERMAL
(mg/kg)
QUOTIENT
RAF INGESTION RAF DERMAL
(mg/kg-day) (mg/kg-day) (mg
Beryllium
1.6E-03
Cadmium
6.1E-02
Chromium
1.15
3.8E-03 5.4E-03
8.85 1
5.8E-02 1.2E-01
58.7 1
1 7.9E-06 0.35 1.9E-0
6.1E-05 0.14 5.8E-05
4.0E-04 0.09 2.5E-04
2.0E-02
1.2E-02
3.3E-02
Copper 20.6
Iron 18900
Lead 53
Magnesium 9210
Manganese 313
2.1E-02 5.2E-02 7.3E-02
Nickel 41.8
1.4E-02 3.4E-02 4.9E-02
1
1
5
1
1
1
1
1
.4E-04
.3E-01
.8E-04
6.
2.
3E-02
1E-03
0.
0.
0.
35
35
006
0
0
.35
.35
3.
3.
,4E-04
. 1E-01
1.
1.
5.
5E-0
5E-0
2E-0
2.9E-04
0.35
6.9E-04
Potassium 4820
Sodium 316
Vanadium 34.9
3.4E-02 8.2E-02 1.2E-01
Zinc 92.9
3.3E-02
2.2E-03
2.4E-04
6.4E-04
0.35
0.35
0.35
0.02
7.9E-0
5.2E-03
5.7E-04
8.7E-05
SUMMARY HAZARD INDEX
-------
TABIiE 11 WORK-DIRECT CONTACT WITH AND INCIDENTAL INGESTION OF SURFACE SOIL - USEPA REGIO
APPROACH FOR PAHS
RECEPTOR: WORKER
AOCs 44 AND 52 - AVERAGE CONCENTRATIONS
FORT DEVENS, MA
EXPOSURE PARAMETERS E
PARAMETER SYMBOL VALUE UNITS SOURCES CANCER RISK = INTAKE (mg/kg-day) x CANCER SLOPE FACTOR (mg/kg-day) -1
CONCENTRATION SOIL CS Average mg/kg USEPA, 1991
HAZARD
QUOTIENT = INTAKE (mg/kg-day) / REFERENCE DOSE (mg/kg-day)
IR
INGESTION RATE
FRACTION INGESTED FI
SOIL ADHERENCE FACTOR SAF
SURFACE AREA EXPOSED SA
CONVERSION FACTOR CF
BODY WEIGHT BW
EXPOSURE FREQUENCY EF
EXPOSURE DURATION ED
AVERAGING TIME
CANCER AT
NONCANCER AT
50 mg/day
100%
1 mg/cm2 USEPA, 1992
3,295 cm2/day USEPA, 1989b (1) = (INTAKE-INGESTION) + (INTAKE DERMAL)
0.000001 kg/mg
70 kg USPEA, 1989a INTAKE-INGESTION= CS x IR x RAF x FI x CF x EF x ED
250 days/year USEPA, 1991
25 years USEPA, 1991
70 years USEPA, 1989a
25 years USEPA, 1991
USEPA, 1991. "Human Health Evaluation Manual, Supplemental Guidance: Sta NTAKE-DERMAL=
Exposure Factors".
USEPA, 1992. Dermal Exposure Assessment: Principles and Applications, In
EPA/600/8-91/011B, January 1992.
USEPA, 1989a. RAGs, PART A.
USEPA, 1989b. Exposure Factors Handbook. (1) Arms and Hands noncarcinogenic: AT + ED
CS x SA x SAF x RAF x CF x EF x ED
-------
TABIiE 11, continued
DIRECT CONTACT WITH AND INCIDENTAL INGESTION OF SURFACE SOIL - USEPA REGIO
APPROACH FOR PAHS
RECEPTOR: WORKER
AOCs 44 AND 52 - AVERAGING CONCENTRATIONS
FORT DEVENS, MA
CARCINOGENIC EFFECTS
SOIL
INGESTION
INTAKE
DERMAL
COMPOUND
(mg/kg)
(mg/kg-day) -1
CONCENTRATION
RISK
RAF
INGESTION
Bis(2-ethylhexyl)phthalate
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Carbazole
Chrysene
Dibenz(a,h)anthracene
indeno(1,2,3-cd)pyrene
Arsenic
4.8E-06 1.8
Beryllium
Lead
5.74
ND
5.
6.
4.
1.
7.17
13.
4.4E-06
96
19.05
99
09
59
79
(mg/kg-day)
(mg/kg-da
1
1
1.
1
1
1
1
. OE-06
1.
1.
8.
1.
0.02
OE-06
1E-06
OE-07
3E-01
0
0
0
0.2
.2
.2
.2
1
1-3E-06
0.2
1.
5,
0,
.64
.03
E
.71
1
S.7E-06
1
1
2,
1
2.9E-07
8.8E-07
.4E-06 0.03
1.3E-05
1.2E-07
0
0
.09
0.2
.35
0.5 1.7E-06
NA
CANCER RISK
5E-05
6E-04
SUMMARY
7E-04
-------
TABIiE 11, continued
DIRECT CONTACT WITH AND INCIDENTAL INGESTION OF SURFACE SOIL - USEPA REGIO
APPROACH FOR PAHS
RECEPTOR: WORKER
AOCs 44 AND 52 - AVERAGE CONCENTRATIONS
FORT DEVENS, MA
NONCARCINOGENIC EFFECTS
SOIL
INGESTION
INTAKE DERMAL
INTAKE
REFE
COMPOUND
CONCENTRATION
RAF
INGESTION
RAF
DERMAL
(mg/kg-day)
(mg/kg)
INGESTION
DERMAL
(mg/kg-day)
QUOTIENT
(mg/kg-day)
0.78
Ethylbenzene 0.0011
Toluene 0.00055
Xylenes 0.0025
2-Methylnaphthlene 0.63
Acenaphthene 0. 6
AcenaphtHylene
Anthracene 2.14
Bis(2-ethylhexyl)phthalate
Benzo(a)anthracene 5.75
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i)perylene
Benzo(k)fluoranthene
Carbazole
Chrysene 7.17
Dibenzo(a,h)anthracene
Dibenzofuran 0.89
Fluoranthene 14.39
Fluorene 1.63
Indeno(1,2,3-cd)pyrene
Naphthalene 1.57
Phenanthrene 10.86
Pyrene 9.74
Arsenic 13.96
Barium 38.69
ND
5.99
6.09
4.65
4.59
1.79
1.64
5.03
1
1
1
0.91
0.91
0.91
0.91
0.91
0.91
0.91
NA
1
1
1
0.91
1
1
1
0.91
0.91
5,
1.
3,
2,
1.
2,
3,
7,
8,
7,
4,
4,
6,
1.
. 4E-10
2.
.2E-09
. 1E-07
. 9E-07
3.
. OE-06
. 6E-06
2.
2.
2.
2.
8.
.2E-06
7.
.OE-06
. OE-07
2.
.7E-07
.8E-06
.8E-06
.8E-06
. 9E-05
7E-10
5E-07
7E-06
7E-06
1E-06
OE-06
8E-07
3E-07
NA
2E-06
0.2
0.12
0.1
0.2
0.29
0.02
0.18
0.18
0.2
0.2
0.1
0.18
0.2
0.03
0.35
0.
0.
0.
0.
0.
0.
0.
0.
,12
,18
,18
,18
,18
,18
1
,08
,18
-------
WORK-A-6
TABIiE 11, continued
DIRECT CONTACT WITH AND INCIDENTAL INGESTION OF SURFACE SOIL - USEPA REGIO
APPROACH FOR PAHS
RECEPTOR: WORKER
AOCs 44 AND 52 - AVERAGE CONCENTRATIONS
FORT DEVENS, MA
NONCARCINOGENIC EFFECTS
SOIL INGESTION INTAKE DERMAL INTAKE
COMPOUND CONCENTRATIONS RAF INGESTION RAF DERM
DOSE QUOTIENT QUOTIENT HAZARD
(mg/kg)
Beryllium
6.9E-05 1.6E-03
Cadmium
6.1E-04 5.6E-03
Chromium
6.8E-04 4.0E-03 4,
Copper
Iron
Lead
Magnesium
Manganese
9.4E-04 2.2E-02 2,
Nickel
5.5E-04 1.3E-02 1.
Potassium
Sodium
Vanadium
1.2E-03 2.9E-02
Zinc
6.3E-05 8.3E-05 1.
0.71
1.7E-03
1.24
6.2E-03
27.83
.7E-03
11.11
11615
19.05
4205
192
.3E-02
22.55
.3E-02
1695
176
17.81
3.0E-02
38.63
.5E-04
(mg/kg-day)
1
1 6.
1 1.
1 5.
1 5.
0.5 4.
1
1
1 1.
1
1 8.
1 8.
1 1.
3.5E-07
1E-07
4E-05
4E-06
7E-03
7E-06
2.1E-03
9.4E-05
IE-OS
8.3E-04
6E-05
7E-06
9E-05
(mg/kg-day)
0.35
0.14
0.09
0.35
0.35
0.006
0.35
0.35
0.35
0.35
0.35
0.35
0.02
5,
8,
1.
1.
3,
2,
2,
2,
2,
(mg/k
8.
. 6E-06
. IE-OS
.3E-04
.3E-01
.7E-06
4.
2.
.5E-04
1.
. OE-03
. OE-04
.5E-05
INDEX
0.03
0.14
0.16
SUMMARY HAZARD
-------
TABIiE 12 WOR
DIRECT CONTACT WITH AND INCIDENTAL INGESTION OF SURFACE SOIL - USEPA REGIO
APPROACH FOR PAHS
RECEPTOR: WORKER
AOCs 44 AND 52 - MAXIMUM CONCENTRATIONS
FORT DEVENS, MA
EXPOSURE PARAMETERS EQUATIONS
PARAMETER SYMBOL VALUE UNITS SOURCE
CONCENTRATION SOIL CS Maximum mg/kg
CANCER RISK = INTAKE (mg/kg-day) x CANCER SLOPE FACTOR (mg/kg-day) -1
INGESTION RATE IR 50 mg/day USEPA, 1991
FRACTION INGESTED FI 100% HAZ
SOIL ADHERENCE FACTOR SAF 1 mg/cm2 USEPA, 1992
SURFACE AREA EXPOSED SA 3,295 cm2/day USEPA, 1989b (1)
CONVERSION FACTOR CF 0.000001 kg/mg
BODY WEIGHT BW 70 kg USEPA, 1989a
INTAKE-INGESTION= CS X IR X RAF X FI X CF X EF X ED
EXPOSURE FREQUENCY EF 250 days/year USEPA, 1991
EXPOSURE DURATION ED 25 years USEPA, 1991
AVERAGING TIME
CANCER AT 70 years USEPA, 1989a
NONCANCER AT 25 years UASPA, 1991
USEPA, 1991. "Human Health Evaluation Manual, Supplemental Guidance: Sta
INTAKE-DERMAL= CS X SA X SAF X RAF X CF X EF X ED
Exposure Factors".
USEPA, 1992. Dermal Exposure Assessment: Principles and Application, Int
EPA/600/8-91/01/011B, January 1992.
USEPA, 1989a. RAGs, Part A.
USEPA, 1989b. Exposure Factors Handbook. (1) Arms and Hands
noncarcinogenic effects: AT = ED
-------
TABIiE 12, continued
DIRECT CONTACT WITH AND INCIDENTAL INGESTION OF SURFACE SOIL - USEPA REGIO
APPROACH FOR PAHS
RECEPTOR: WORKER
AOCs 44 AND 52 - MAXIMUM CONCENTRATIONS
FORT DEVENS, MA
CARCINOGENIC EFFECTS
SOIL
INGESTION
COMPOUND CONCENTRATION
7.3 3
0.02 7
7.3 6
7.3 2
(mg/kg)
Bis (2-ethylhexyl)phthalate
Benzo (a) anthracene
Benzo (a) pyrene
.8E-05 5.0E-04
Benzo (b) f luoranthene
Benzo (k) f luoranthene
Carbazole
.OE-08 4.6E-06
Chrysene
.4E-05 8.4E-04
Dibenz (a,h) anthracene
Indeno (1,2, 3-cd) pyrene
.6E-05 3.4E-04
Arsenic
1.8 9
4.3 8
CANCER
.1E-06 1.8E-05
Beryllium
.6E-07 2.0E-05
Lead
RISK 3E-04
ND
40
30
5.4E-04
30
30
20
4.7E-06
50
9.0E-04
5
20
3.6E-04
29
2.7E-05
1.15
2.1E-05
73
3E-03
INTAKE DERMAL INTAKE
RAF INGESTION RAF DE
(mg/kg-day) (mg/kg-day)
1 0.02
1 7.0E-06 0.2
1 5.2E-06
1 5.2E-06
1 5.2E-06
1 3.5E-06
1 8.7E-06 0.2
1 8.7E-07 0
1 3.5E-06
1 5.1E-06 0.03
1 2.0E-07 0
0.5 6.4E-06 NA
SUMMARY
4E-03
-------
TABIiE 12, continued WORK-A-8
07-Jun-93
DIRECT CONTACT WITH AND INCIDENTAL INGESTION OF SURFACE SOIL - USEPA REGIO
PAHS
RECEPTOR: WORKER
ACOs 44 AND 52 - MAXIMUM CONCENTRATIONS
FORT DEVENS, MA
NONCARCINOGENIC EFFECTS
SOIL
COMPOUND CONCENTRATION
(mg/kg-day)
(mg/kg)
INGESTION DERMAL
INGESTION INTAKE DERMAL
RAF INGESTION RAF
(mg/kg-day)
QUOTIENT
INTAKE
DERMAL D
(mg/kg-day)
Ethylbenzene 0.0049
2.4E-08 3.2E-07 3.4E-07
Toluene 0.0023
Xylenes 0.022
2-Methylnaphthalene
7.3E-05 4.8E-04 5.6E-04
Acenaphthene 6
Acenaphthylene
Anthracene 20
3.3E-05 6.2E-04 6.6E-04
Bis(2-ehthylhexyl)phthalate
Benzo(a)anthracene 40
4.5E-04 5.8E-03 6.2E-03
Benzo(a)pyrene
Benzo(b)fluoranthene
3.3E-04 4.4E-03 4.7E-03
Benzo(g,h,i)perylene
2.2E-04 2.9E-03 3.1E-03
Benzo(k)fluoranthene
3.3E-04 4.4E-03 4.7E-03
Carbazole
Chrysene 50
Dibenz(a,h)anthracene
5.6E-05 3.2E-04 3.8E-04
Dibenzofuran 10
Fluoroanthene 100
Fluorene 20
Indeno(1,2,3-cd)pyrene
Naphthalene 20
2.4E-04 1.6E-03 1.9E-03
Phenanthrene 100
1.1E-03 1.5E-02 1.6E-02
Pyrene 60
Arsenic 29
Barium 95.3
0.91
2.4E-09
1.1E-09
1.1E-08
2.9E-06
0.2 3.2E-
0.12 8.9E-
0.12 8.5E-
0.1 1.9E-
2.9E-06 0.2 3.9E-05
1.8E-06 0.18 2.3E-
9.8E-06 0.29 1.9E-04
ND
0,
30
30
20
30
20
0,
5
20
0,
1
.91
0.91
0.91
0.91
0.91
1
.91
0.91
NA
1
1
0.91
1
.91
1
1
1.8E-05
1.3E-05
1.3E-05
8.9E-06
1.3E-05
9.8E-06
2.2E-05
2.2E-06
NA
4.9E-05
9.8E-06
8.9E-06
9.8E-06
4.5E-05
2.9E-05
1.4E-05
0.02
0.18
0.18
0.2
0.2
0.1
0.18
0.2
0.03
2.
0.
0.
0.
0.
1
2.
0.
6.
1.
0.
6.
5.
3.
2.
,3E-04
,18 1.
,18 1.
,18 1.
,18 1.
6.
, 9E-04
,08 1.
,4E-04
,3E-04
,18 1.
, 4E-05
,8E-04
, 9E-04
, 8E-05
7E-
7E-
2E-
7E-
4E-
3E-
N
2E-
-------
TABIiE 12, continued
WORK-A-8 07-Jun-93
DIRECT CONTACT WITH AND INCIDENTAL INGESTION OF SURFACE SOIL - USEPA REGIO
APPROACH FOR PAHS
RECEPTOR: WORKER
AOCs 44 AND 52 - MAXIMUM CONCENTRATIONS
FORT DEVENS, MA
NONCARCINOGENIC EFFECTS
COMPOUND
DOSE QUOTIENT
SOIL INGESTION INTAKE DERMAL INTAKE
RAF INGESTION RAF DERMA
(mg/kg-day) (mg/kg-day) (mg/kg
CONCENTRATION
QUOTIENT HAZARD
INGESTION
(mg/kg)
DERMAL
QUOTIENT
Beryllium
Cadmium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Sodium
Vanadium
Zinc
1.5E-04 2.0E-04
8.85
58.7
20.6
18900
73
41.8
316
34.9
92.9
1.15
9210
313
4820
3.5E-04
1 5.6E-07
4.3E-06
2.9E-05
l.OE-05
9.2E-03
1.8E-05
1 4.5E-03
1 1.5E-04
2.0E-05
1 2.4E-03
1.5E-05
1.7E-05
4.5E-05
0.14
0.09
0.35
0.35
0.006
0.35
0.35
0.35
0.02
0.35
0.35
0.35
0.35
1
4.0E-0
1.7E-0
2,
2,
1,
4,
3,
3,
. 3E-0
. 1E-0
. 4E-0
1
3
.7E-0
5
. 6E-0
. 9E-0
6.0E-0
INDEX
0.07
0.36
SUMMARY HAZARD
0.42
-------
TABIiE 13
SOIL CONTAMINANT RELEASE ANALYSIS - FUGITIVE DUST
BASED ON NATIONAL AMBIENT AIR QUALITY STANDARD (NAAQS)
FOR RESPIRABLE PARTICLES (PM10) (1)
AOCs 44 AND 52 - AVERAGE SOIL CONCENTRATIONS
FORT DEVENS, MA
CONTAMINANT
Carcinogens
SOIL FUGITIVE DUST FUGITIVE DUST
CONCENTRATION NAAQS CONCENTRATION (2)
(mg/kg) (ug/m3) (mg/m3)
Bis(2-ethylhexyl)phthalate
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Carbazole
Chrysene
Dibenz(a,h)anthracene
Indeno(1,2,3-cd)pyrene
Arsenic
Beryllium
Lead
Cadmium
Chromium VI (3)
Nickel
.941
.078
.241
.318
1.658
0.621
2.581
0.782
2.001
12.36
0.514
10.188
0.635
1.719
15.299
50
50
50
50
50
50
50
50
50
50
50
50
50
50
50
9.71E-08
1.04E-07
1.12E-07
1.16E-07
8.29E-08
3.11E-08
1.29E-07
3.91E-08
l.OOE-07
6.18E-07
2.57E-08
5.09E-07
3.18E-08
8.60E-08
7.65E-07
Noncarcinogens
Ethylbenzene 0.000936
Toluene 0.000441
Xylenes 0.00129
2-Methylnaphthalene 0.267
Acenaphthene 0.235
Acenaphthylene 0.297
Anthracene 0.742
Benzo(g,h,i)perylene 1.839
Dibenzofuran 0.327
Fluoranthene 5.044
Fluorene 0.564
Naphthalene 0.554
Phenanthrene 3.658
Pyrene 3.405
Barium 24.907
Copper 8.885
Chromium III (3) 15.473
Iron 8547.391
50
50
50
50
50
50
50
50
50
50
50
50
50
50
50
50
50
50
4.68E-11
2.21E-11
6.45E-11
1.34E-08
1.18E-08
1.49E-08
3.71E-08
9.20E-08
1.64E-08
2.52E-07
2.82E-08
2.77E-08
1.83E-07
1.70E-07
1.25E-06
4.44E-07
7.74E-07
4.27E-04
-------
TABIiE 13, continued
SOIL CONTAMINANT RELEASE ANALYSIS - FUGITIVE DUST
BASED ON NATIONAL AMBIENT AIR QUALITY STANDARD (NAAQS)
FOR RESPIRABLE PARTICLES (PM10) (1)
AOCs 44 AND 52 - AVERAGE SOIL CONCENTRATIONS
FORT DEVENS, MA
CONTAMINANT
Magnesium
Manganese
Potassium
Sodium
Vanadium
Zinc
SOIL
CONCENTRATION
(mg/kg)
2504.574 50
154.293 50
1008.659 50
155.042 50
10.942 50
26.532 50
FUGITIVE DUST FUGITIVE DUST
NAAQS CONCENTRATION (2)
(ug/m3) (mg/m3)
1.25E-04
7.71E-06
5.04E-05
7.75E-06
5.47E-07
1.33E-06
(1) The National Ambient Air Quality Standard for respirable particulates
(PM10) is 50 ug/m3 (annual arithmetic mean concentration)
(2) Fugitive Dust Concentration (mg/m3) = [Soil Concentration (mg/kg) x
NAAQS for Fugitive Dust (mg/m3)]/l x 109 ug/kg
(3) The total chromium concentration (17.192 mg/kg) was divided into 90%
10% chromium VI (a carcinogen via inhalation).
-------
TABIiE 14 DST-FTD1
INHALATION EXPOSUBE TO DUST - NAAQS OF 50 UG/M 3 (PM10)
RECEPTOR: CONSTRUCTION WORKER
AOCs 44 AND 52 - AVERAGE SOIL CONCENTRATIONS
FORT DEVENS, MA
EXPOSURE PARAMETERS EQUATIONS
PARAMETER SYMBOL VALUE UNITS SOURCE
CONCENTRATION AIR CA mg/m3 Modeled
RISK = INTAKE (mg/kg-day) x CANCER SLOPE FACTOR (mg/kg-day) -1
INHALATION RATE IR 2.5 m3/hour USEPA, 1991a
BODY WEIGHT BW 70 kg USEPA, 1989a INTAKE =
RAF X ET X EF X ED
EXPOSURE TIME ET 8 hours/day USEPA, 1991a BW x
days/year
EXPOSURE FREQUENCY EF 5 days/workweek PRO. JUDGEMENT
EXPOSURE DURATION ED 12 weeks PRO. JUDGEMENT
HAZARD
QUOTIENT = INTAKE (mg/kg-day)/REFERENCE DOSE (mg/kg-day)
AVERAGING TIME
CANCER AT 70 years USEPA, 1989a
AT 12 weeks USEPA, 1989a* INTAKE = CA x
x RAF x ET x EF x ED
USEPA, 1991a. " STANDARD DEFAULT EXPOSURE FACTORS"
USEPA, 1989a RISK ASSESSMENT GUIDANCE FOR SUPERFUND, PART A.
* For
noncarcinogenic effects: AT = ED
-------
TABIiE 14, continued
INHALATION EXPOSURE TO DUST - NAAQS OF 50 UG/M 3 (PM10)
RECEPTOR: CONSTRUCTION WORKER
AOCs 44 AND 52 - AVERAGING SOIL CONCENTRATIONS
FORT DEVENS, MA
CARCINOGENIC EFFECTS
COMPOUND
Bis(2-ethylhexyl)phthalate
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Carbazole
Chrysene
Dibenz(a,h)anthracene
Indeno(1,2,3-cd)pyrene
Arsenic
Beryllium
Cadmium
Chromium VI
Nickel
Lead
AIR
CONG.
(mg/m3)
9
1
1
1
8
3
1
3
1
6
2
3
8
7
5
.71E-08
.04E-07
.12E-07
.16E-07
.29E-08
.HE-OS
.29E-07
.91E-08
.OOE-07
.18E-07
.57E-08
.18E-08
. 60E-08
. 65E-07
.09E-07
INHALATION
RAF
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
INTAKE CANCER SLOPE
(mg/kg-day)
(mg/kg-day) -1
6,
7,
7,
7,
5,
2,
8,
2,
6,
4,
1,
2,
5,
5,
3,
.5E-11
. OE-11
.5E-11
. 8E-11
. 6E-11
. 1E-11
.7E-11
. 6E-11
.7E-11
. 1E-10
.7E-11
. 1E-11
. 8E-11
. 1E-10
. 4E-10
1.
6.
6.
6.
6.
2.
6.
6.
6.
5.
8.
6.
4.
8.
NA
40E-02
10E+00
10E+00
10E+00
10E+00
OOE-02
10E+00
10E+00
10E+00
OOE+01
40E+00
10E+00
10E+01
40E-01
FACTOR
4,
5,
2,
1,
2,
4,
.3
.3
.1
.3
.4
.3
SUMMARY CANCER RISK
3E-C
-------
TABIiE 14, continued DST-FTD1
INHALATION EXPOSURE TO DUST - NAAQS OF 50 UG/M 3 (PM10)
RECEPTOR: CONSTRUCTION WORKER
AOCs 44 AND 52 - AVERAGE SOIL CONCENTRATIONS
FORT DEVENS, MA
03-
NONCARCINOGENIC EFFECTS
SUBCHRONIC
SUBCHRONIC
AIR
Bis(2-ethylhexyl)phthalate
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Carbazole
Chrysene
Dibenz(a,h)anthracene
Indeno(1,2,3-cd)pyrene
Arsenic
Beryllium
Lead
Ethylbenzene
Toluene
Xylenes
2-Methytlnaphthalene
Acenaphthene
Acenaphthylene
Anthracene
Benzo(g,h,i)perylene
Dibenzofuran
Fluoranthene
Fluorene
Naphthalene
Phenanthrene
Pyrene
1
1
8
3
3
2
5
4
2
1.
1
9
2
2
2
1
CONG.
(mg/iti3)
9.71E-08
1.04E-07
.12E-07
.16E-07
.29E-08
.HE-OS
1.29E-07
.91E-08
l.OOE-07
6.18E-07
.57E-08
.09E-07
.68E-11
.21E-11
6.45E-11
34E-08
1.18E-08
.49E-08
3.71E-08
.20E-08
1.64E-08
.52E-07
.82E-08
.77E-08
1.83E-07
.70E-07
RAF
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
3
3
2
8
1
1
1
1
7
1
1
6
1
3.
1
4
1
2
1
7
8
7
1
4
(mg/kg-day)
(mg/kg-day)
2.8E-0
3
.2E-08
.3E-08
.4E-08
.9E-09
3
.IE-OS
2
1.
.3E-09
.5E-07
.3E-11
.3E-12
1
8E-09
3
.2E-09
1
.6E-08
4
.2E-08
.1E-09
.9E-09
5
.9E-08
8
.OE-08
ND
.7E-08
.9E-08
8E-07
ND
.8E-11
.4E-09
.IE-OS
.7E-09
.2E-08
0.04
0.04
0.04
0.04
0
0.005
0.29
0.11
0.04
0.04
0.04
ND
0.4
0.4
0.04
0.3
DOSE
0.04
0.04
0.04
.0003
4.6E
5.7E
0.086
0.6
3
1.8E
2.0E
2.0E
0.04
1.6E
Q
7.4E
9.2E
5.9E
2. IE
5.6E
3.5E
1.3E
-------
TABIiE 14, continued
INHALATION EXPOSURE TO DUST - NAAQS OF 50 UG/M 3 (PM10)
RECEPTOR: CONSTRUCTION WORKER
AOCs 44 AND 52 - AVERAGE SOIL CONCENTRATIONS
FORT DEVENS, MA
NONCARCINOGENIC EFFECTS
SUBCHRONIC SUBCHRONIC
AIR INHALATION INTAKE REFERENCE
COMPOUND CONG. RAF (mg/kg-day) DOSE
(mg/iti3) (mg/kg-day)
Barium
Cadmium
Chromium VI
Chromium III
Copper
Iron
Magnesium
Manganese
Nickel
Potassium
Sodium
Vanadium
Zinc
1.
3,
8,
7,
4,
4,
1.
7,
7,
5,
7,
5,
1.
.25E-06
.18E-08
. 60E-08
.74E-07
.44E-07
.27E-04
.25E-04
.71E-06
. 65E-07
.04E-05
.75E-06
. 47E-07
.33E-06
1
1
1
1
1
1
1
1
1
1
1
1
1
3.6E-07
9.1E-09
2.5E-08
2.2E-07
1.3E-07 ND
1.2E-04 ND
3.6E-05 ND
2.2E-06
2.2E-07
1.4E-05 ND
2.2E-06 ND
1.6E-07
3.8E-07
0.001
0.001
0.0000057
0.0000057
0.14
0.02 1
0.007
0.3 1
3.6E-04
9.1E-06
4.3E-03
3.9E-02
1.6
.IE-OS
2.2E-05
.3E-06
SUMMARY HAZARD INDEX
4E-02
-------
TABIiE 15
SOIL CONTAMINANT RELEASE ANALYSIS - FUGITIVE DUST
BASED ON NATIONAL AMBIENT AIR QUALITY STANDARD (NAAQS)
FOR TOTAL RESPIRABLE PARTICLES - 24 HOUR MAXIMUM/ONCE PER YEAR (1)
AOCs 44 AND 52 - AVERAGE SOIL CONCENTRATIONS
FORT DEVENS, MA
CONTAMINANT
Carcinogens
SOIL
CONCENTRATION
(mg/kg)
Bis(2-ethylhexyl)phthalate 1.941
Benzo(a)anthracene 2.078
Benzo(a)pyrene 2.241
Benzo(b)fluoranthene 2.318
Benzo(k)fluoranthene 1.658
Carbazole 0.621
Chrysene 2.581
Dibenz(a,h)anthracene 0.782
Indeno(l,2,3-cd)pyrene 2.001
Arsenic 12.36
Beryllium 0.514
Lead 10.188
Cadmium 0.635
Chromium VI (3) 1.719
Nickel 15.299
Noncarcinogens
Ethylbenzene 0.000936
Toluene 0.000441
Xylenes 0.00129
2-Methylnaphthalene 0.267
Acenaphthene 0.235
Acenaphthylene 0.297
Anthracene 0.742
Benzo(g,h,i)perylene 1.839
Dibenzofuran 0.327
Fluoranthene 5.044
Fluorene 0.564
Naphthalene 0.544
Phenanthrene 3.658
Pyrene 3.405
Barium 24.907
Copper 8.885
Chromium III (3) 15.473
Iron 8547.391
FUGITIVE DUST
NAAQS
(ug/m3)
150
150
150
150
150
150
150
150
150
150
150
150
150
150
150
150
150
150
150
150
150
150
150
150
150
150
150
150
150
150
150
150
150
FUGITIVE DUST
CONCENTRATION (2)
(mg/m3)
2.91
3.12E-07
3.36E-07
3.48E-07
2.49E-07
9.32E-08
3.87E-07
1.17E-07
3.00E-07
1.85E-06
7.71E-08
1.53E-06
9.53E-08
2.58E-07
2.29E-06
1.40E-10
6.62E-11
1.94E-10
4.01E-08
3.53E-08
4.46E-08
1.11E-07
2.76E-07
4.91E-08
7.57E-07
8.46E-08
8.31E-08
5.49E-07
5.11E-07
3.74E-06
1.33E-06
2.32E-06
1.28E-03
-------
TABIiE 15, continued
SOIL CONTAMINANT RELEASE ANALYSIS - FUGITIVE DUST
BASED ON NATIONAL AMBIENT AIR QUALITY STANDARD (NAAQS)
FOR TOTAL RESPIRABLE PARTICLES - 24 HOUR MftXIMUM/ONCE PER YEAR (
AOCs 44 AND 52 - AVERAGE SOIL CONCENTRATIONS
FORT DEVENS, MA
CONTAMINANT
Magnesium
Manganese
Potassium
Sodium
Vanadium
Zinc
SOIL
CONCENTRATION
(mg/kg)
2504.574
154.293
1008.659
155.042
10.942
26.532
FUGITIVE DUST FUG
150
150
150
150
150
150
NAAQS CC
(ug/m3)
3.76E-04
2.31E-05
1.51E-
2.33E-05
1.64E-06
3.98E-06
FUGITIVE DUST
CONCENTRATION (2)
(mg/m3)
(1) The National Ambient Air Quality Standard for the concentration of tot
in a 24-hour period not to be exceeded more than once per year is 150 ug/m
(2) Fugitive Dust Concentration (mg/m3) = [Soil Concentration (mg,kg) x
NAAQS for Fugitive Dust (mg/m3)]/l x 109 ug/kg
(3) The total chromium concentration (17.192 mg/kg) was divided into 90% c
10% chromium VI (a carcinogen via inhalation).
-------
TABIiE 16
INHALATION EXPOSURE TO DUST - NAAQS OF 150 UGM UG/M 3 (24 HOUR MAXIMUM - N
BE EXCEEDED MORE THAN ONCE PER YEAR)
RECEPTOR: CONSTRUCTION WORKER
AOCs 44 AND 52 - AVERAGE SOIL CONCENTRATIONS
FORT DEVENS, MA
EXPOSURE PARAMETERS EQUATIONS
PARAMETER SYMBOL VALUE UNITS SOURCE
CONCENTRATION AIR CA mg/m3 Modeled CAN
INTAKE (mg/kg-day) x CANCER SLOPE FCTOR (mg/kg-day) -1
INHALATION RATE IR 2.5 m3/hour USEPA, 1991a
BODY WEIGHT BW 70 kg USEPA, 1989a INTAKE =
X ET X EF X ED
EXPOSURE TIME ET 8 hours/day USEPA, 1991a
days/year
EXPOSURE FREQUENCY EF 5 days/workweek PRO. JUDGEMENT
EXPOSURE DURATION ED 12 weeks PRO. JUDGEMENT
AVERAGING TIME HAZARD
QUOTIENT = INTAKE (mg/kg-day) / REFERENCE DOSE (mg/kg-day)
CANCER AT 70 years USEPA, 1989a
AT 12 weeks USEPA, 1989a * INTAKE = CA
ET X EF X ED
USEPA, 1991a "STANDARD DEFAULT EXPOSURE FACTORS"
USEPA, 1989a RISK ASSESSMENT GUIDANCE FOR SUPERFUND, PART A.
* For
noncarcinogenic effects: AT = ED
-------
TABIiE 16, continued
INHALATION EXPOSURE TO DUST - NAAQS OF 150 UG/M 3 (24 HOUR MAXIMUM - NOT T
EXCEEDED MORE THAN ONCE PER YEAR)
RECEPTOR: CONSTRUCTION WORKER
AOCs 44 AND 52 - AVERAGE SOIL CONCENTRATIONS
FORT DEVENS, MA
CARCINOGENIC EFFECTS
COMPOUND
AIR INHALATION
CONG. RAF
(mg/iti3)
INTAKE CANCER SLO
(mg/kg-day) FACTO
(mg/kg-day) -1
Bis(2-ethylhexyl)phthalate
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Carbazole
Chrysene
Dibenz(a,h)anthracene
Indeno(1,2,3-cd)pyrene
Arsenic
Beryllium
Cadmium
Chromium VI
Nickel
Lead
at
3.
3.
1.
9.
2
2.
1.
e 2.91E-07
12E-07
3.36E-07
3.48E-07
2.49E-07
9.32E-08
87E-07
1.17E-07
3.00E-07
85E-06
7.71E-08
53E-08
.58E-07
29E-06
53E-06
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
2
1
6
2.
.1E-10
2.
2.
1.
6.
.6E-10
7.
2.
.2E-09
5.
.4E-11
OE-10
3E-10
3E-10
7E-10
3E-10
9E-11
OE-10
2E-11
1.7E-10
1
1
.5E-09
.OE-09
NA
1.40
6.10E+00
6.10
6.10
6.10
2.00
6.10E+00
6.10
6.10
5.00E+01
8.40
6.10E+00
4.10E+01
8.40E-01
1
1
1
1
6
4
3.
7
1.
.4E-09
.3E-12
.6E-09
.2E-09
.2E-08
.3E-10
9E-10
.1E-09
3E-09
SUMMARY CANCER RISK
-------
TABIiE 16, continued
INHALATION EXPOSURE TO DUST - NAAQS OF 150 UG/M 3 (24 HOUR MAXIMUM - NOT T
EXCEEDED MORE THAN ONCE PER YEAR)
RECEPTOR: CONSTRUCTION WORKER
AOCs 44 AND 52 - AVERAGE SOIL CONCENTRATIONS
FORT DEVENS, MA
NONCARCINOGENIC EFFECTS
COMPOUND
AIR
CONG.
(mg/m3)
INHALATION
SUBCHRONIC
INTAKE
SUBCHRONIC
REFERENCE HAZ
RAF (mg/kg-day)
(mg/kg-day)
DOSE
Bis(2-ethylhexyl)phthalate
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Carbazole
Chrysene
Dibenz(a,h)anthracene
Indeno(1,2,3-cd)pyrene
Arsenic
Beryllium
Lead
Ethylbenzene
Toluene
Xylenes
2-Methylnaphthalene
Acenaphthene
Acenaphthylene
Anthracene
Benzo(g,h,i)perylene
Dibenzofuran
Fluoranthene
Fluorene
Naphthalene
Phenanthrene
Pyrene
.la
3.
3.
1.
1.
1.
6.
1.
3.
1.
4.
7.
8.
8.
5.
5.
.te 2.91E-07
12E-07
3.36E-07
3.48E-07
2.49E-07
9.32E-08
87E-07
1.17E-07
3.00E-07
85E-06
7.71E-08
53E-06
40E-10
62E-11
94E-10
4.01E-10
53E-08
4.46E-08
11E-07
2.76E-07
91E-08
57E-07
46E-08
31E-08
49E-07
11E-07
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
8
1
5
4
4
1
5
1
3
1
2
2
1
1
1 8.
.9E-08
1 9.
1 9.
1 7.
1 2.
.1E-07
1 3.
1 8.
.3E-07
1 2.
.4E-07
.OE-11
.9E-11
.5E-11
1 1.
.OE-08
1 1.
.2E-08
1 7.
.4E-08
2
.4E-08
.4E-08
.6E-07
.5E-07
3E-08
6E-08
9E-08
IE-OS
7E-08
3E-08
6E-08
0.04
ND
0.04
0
0
0
0
0
0
.02
.04
.04
.04
.04
.04
0.0003
2E-08
ND
IE-OS
3E-08
9E-08
ND
.2E-07
0.29
0.11
0.086
0.6
3
0.4
0.04
0.04
0.3
0.
0
0
0
005
.04
.04
.04
0.4
-------
TABIiE 16, continued
INHALATION EXPOSURE TO DUST - NAAQS OF 150 UG/M 3 (24 HOUR MAXIMUM - NOT T
EXCEEDED MORE THAN ONCE PER YEAR)
RECEPTOR: CONSTRUCTION WORKER
AOCs 44 AND 52 - AVERAGE SOIL CONCENTRATIONS
FORT DEVENS, MA
NONCARCINOGENIC EFFECTS
SUBCHRONIC
SUBCHRONIC
COMPOUND
Barium
Cadmium
Chromium VI
AIR INHALATION
CONG . RAF
(mg/m3)
3.74E-06
9.53E-08
2.58E-07
Chromium III 2.32E-06
Copper
Iron
Magnesium
Manganese
Nickel
Potassium
Sodium
Vanadium
Zinc
1.33E-06
1.28E-03
3.76E-04
2.31E-05
2.29E-06
1.51E-04
2.33E-05
1.64E-06
3.98E-06
1
1
1
1
1
1
1
1
1
1
INTAKE
REFERENCE
HAZA
(mg/kg-day)
(mg/kg-day)
DOSE QUOTIE
1.1E-06
2.7E-08
7.4E-08
6.6E-07
3.8E-07 ND
3.7E-04 ND
1 1.1E-04 ND
1 6.6E-06
6.5E-07
1 4.3E-05 ND
6.7E-06 ND
4.7E-07
1.1E-06
0.001 1.1E
0.001 2.7E
0.0000057
0.0000057 1.2E
0.14
0.02 3.3E
0.007
0.3
6.7E
3.8E
SUMMARY HAZARD INDEX
-------
FEASIBILITY STUDY)
TABLE 17
REMEDIAL ALTERNATIVE DEVELOPMENT (AS DEFIN
AOCs 44 & 52 - MAINTENANCE YARDS
RESPONSE ACTION/TECHNOLOGY
1
9 10 11
M C
CMC M C M C
M
ALTERNATIVE(a)
345 6
CM CMC M C
NO ACTION
LIMITED ACTION
Environmental Monitoring
Access Controls (Fencing)
Institutional Controls (Deeds)
CONTAINMENT
Asphalt Capping
COLLECTION/REMOVAL
Excavation
IN-SITU TREATMENT
Bieventing
Landfarming
X
X
X
X
X
X(b) X
X(b) X(c) X
X X
TREATMENT
Screening
Composting
On-Site Asphalt Batching
Thermal Desorption
DISPOSAL
On-Base
Off-Base Landfill
Alternative
in the FS)
Description (
indicates the alter
retained for detailed analysis
(1) No Action - No Remedial Work; Only Environmental Monitoring
(2) Fencing/Asphalt Batch Hot Spot Areas
(3) Capping Site/Asphalt Batch Hot Spot Areas
(4) Capping Site/Bieventing Hot Spot Areas
(5) Asphalt Batch Site/Asphalt Batch Hot Spot Areas
(6) Asphalt Batch Site/Biovent Hot Spot Areas
(7) Bioventing Site and Hot Spot Areas
(8) Landfarming Site/Excavating And Landfarming Hot Spot Areas
(9) Treatment of Site & Spot Areas at a Central Soil Treatment Facili
(10) Thermal Desorption of Site and Hot Spot Areas
(11) Excavate Site and Hot Spot Areas and Dispose Off-Site
(a) NOTE: C = Action taken on Cannibalization Yard Mogas and Leaking Unde
Spot Areas)
M = Action taken on entire Maintenance Yards
X = Indicates use of a Technology for the Alternative
(b) Excavation reguired for stormwater system expansion
(c) Excavation reguired for installing bioventing system
(d) Disposal of screened pavement and stone
(e) Batching performed at central treatment facility
-------
TABIiE 18
SELECTED REMEDY
COST ESTIMATE
ALTERNATIVE 5: ASPHALT BATCH SITE/ASPHALT BATCH HOT SPOT AREAS
AOCS 44 AND 52 - MAINTENANCE YARDS
FORT DEVENS, MASSACHUSETTS
ITEM COST PRESENT WORTH
Capital Costs
Asphalt Batch Site and Hot Spot Areas
Excavation $ 134,000
Asphalt Batching $1,072,000
Analytical $ 116,000
Site Restoration (includes pavement $ 327,000
wearing course) $1,649,000 $1,649,000
Expansion of Stormwater Collection System $145,000 $1
(see Table 6-7)
Air Monitoring $71,000 $71,000
Total Capitol Costs $1,865,000 $1,865,000
Annual Operation and Maintenance Costs
Groundwater Monitoring (See Table 6-3) $19,000 $72,000
Total Operation and Maintenance Cost $19,000 $72,000
TOTAL PRESENT WORTH COST $1,937,000
NOTE:
Costs include 25% contingency. Costs rounded to nearest $1,000.
1 Present worth based on 10% interest rate and duration of 5 years.
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TABIiE 19
SYNOPSIS OF FED
ALTERNATIVE 5: ASPHALT BATCHING
BATCHING HOT SPOT AREAS
AOCS 44 AND 5
FORT DEVENS, MA
LOCATION
AUTHORITY CHARACTERISTICS REQUIREMENT ST
ARAR
AND ARAR TYPE
Federal Wetland National Environmental Policy Applicable
Federal agencies minimize the Wetlands adjacent to AOCs 44 and 52 ma
Regulatory Act; [40 CFR Part 6] degradatio
destruction of wetlands, and impacted by surface water runoff via the storm
Authority preserve and
enhance natural and beneficial values system. This alternative covers the s
Location-Specific of wetlands under
Executive Orders 11990 and thus reducing potential off-site runoff of
11988.
State Air Massachusetts Air Pollution Applicab
standards and reguirements for air The emissions limits for particulate matt
Regulatory Control Regulation; [310 pollution
Commonwealth. emissions will be manage through engineering controls
Reguirements CMR 6.00 - 7.00] Specifically, S
provides ambient air during excavation and treatment activities.
Action-Specific guality criteri
such as particulate matter standards
which is pertinent
to AOCs 44 and 52 activity. As a
minimum,
respirable particulate matter (PM10) for
treatment and
excavation activities must be
maintained at an
annual mean arithmetic
concentration of
50 ]lg/m3 and maximum 2 4-hour
concentration of
150 y.g/m3. Section 7.02 provides
emissions
limitatations from facilities and operations
and reguires
BACT. Additionally, the
Massachusetts
toxic air pollutant (TAP) control
program
reguirements will be considered in limiting
fugitive emissions (VOCs)
and total suspended
particulates
during treatment and excavation
activities.
Soil Massachusetts Hazardous Applicable Waste oil
hazardous waste under The wastes found at this site were determined not to
Waste Management Rules this rule and i
therefore subject to 310 CMR characteristic hazardous wastes; however, w
(MHWMR) Identification and 30.000 (i.
Massachusetts Hazardous Waste listed hazardous waste under this rule.
Action-Specific Listing of Hazardous Wastes
Rules).
[310 CMR 30.100]
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TABIiE 6-8 (continued)
SYNOPSIS OF LOCATION-SPECIFIC
FEDERAL AND STATE ARARS
ALTERNATIVE 5: ASPHALT BATCHING
SITE/ASPHALT BATCHING HOT SPOT AREAS
AOCS 44 AND 52 SOILS
FORT DEVENS, MASSACHUSETTS
LOCATION
AUTHORITY CHARACTERISTIC REQUIREMENT STA
AND ARAR TYPE
State Soil MHWMR Provisions for Applicable This
contains procedural and substantive Asphalt batcing of soil on site will ocmp
Regulatory Recyclable Materials and for regui
regulated recyclable substantive reguirements of this regulation.
Reguirement Waste Oil [310 CMR 30.200] materials.
reguirements include
Action-Specific preventing and
reporting releases to the
environment,
proper maintenance of treatment and
control systems,
ans handling of regulated
recyclable
materials.
Soil MHWMR - Waste Piles; [310 Applicable A waste pi
install a liner, provide a These reguirements will be addressed in the design o
CMR 30.640 - 30.649] leachate
collection system, provide a run-on/run-off an area for stockpiling of wastes
control system,
comply with the groundwater
Action-Specific monitoring
reguirements, perform inspections, and
close the facility
properly.
Ground- MHWMR Groundwater Relevant and
monitoring should be conducted Although cleanup of groundwater, if re
water Protection; [310 CMR 30.660 Appropriate durin
remedial actions. handled as a separate operable unit, groundwater
- 30.679] Concentration
limits for the hazardous constituents monitoring will be conducted as a compo
Action-Specific are specified i
310 CMR 30.667. remedy.
All Standards for Analytical Data To Be This polic
minimum standards for All sampling plans will be designed with conside
for Remedial Response Considered analytical data
the Department. the analytical methods provided in this policy.
Action [WSC-300-89]
Chemical-Specific
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BAENUM ROAD MAINTENANCE YARDS
AOCs 44 & 52
ROD SUMMARY
APPENDIX C
RESPONSIVENESS SUMMARY
RESPONSIVENESS SUMMARY
Barnum Road Maintenance Yards - AOCs 44 & 52
INTRODUCTION
The United States Department of the Army (Army) held a 30-day comment period from May 25 to June
24, 1994. This comment period provided an opportunity for interested parties to comment on the
Proposed Plan, the Feasibility Study (FS) and other documents (included in the Administrative
Record), which have been developed to address the cleanup of the unsaturated soils at the
Barnum Road Maintenance Yards - Areas of Contamination (AOCs) 44 & 52 at Fort Devens,
Massachusetts. The Proposed Plan Specifically addresses cleanup of the surface soils and two
subsurface "hot spot" areas. The FS examined and evaluated various options (referred to as
remedial alternatives), which address human health risk from exposure to these soils and
potential migration of substances present in the soil at AOCs 44 & 52. The Army identified its
preferred alternative for AOCs 44 & 52 in the Proposed Plan issued on May 16, 1994. All
supporting documentation for the decision regarding AOCs 44 & 52. It was made is plain the
Administrative Record for review. The Administrative Record is a collection of all the
documents considered by the Army in choosing the remedy for AOCs 44 & 52. It was made available
at the Fort Devens Base Realignment and Closure (BRAG) Environmental Office, Building P12, Fort
Devens, and at the Ayer Town Hall, Main Street, Ayer. An index to the Administrative Record was
made available at the United States Environmental Protection Agency (USEPA) Records Center, 90
Canal Street, Boston MA and is provided as Appendix E to the Record of Decision.
The purpose of this Responsiveness Summary is to document Army responses to the guestions and
comments raised during the public comment period on the FS, Proposed Plan, and other documents
in the Administrative Record. The Army and USEPA reviewed and considered the comments prior to
selecting the remedy for AOCs 44 & 52 which is documented in this Record of Decision.
The comments received by the community and local governments are summarized and responded to in
this Responsiveness Summary. Comments from the public were received from a merchant and two town
officials from the town of Ayer and a representative of the Fort Devens Reuse Center. Comments
were also received from the Massachusetts Department of Environmental Protection (MADEP).
Comments generally supported the Army's choice of the selected remedy. Concern was also
expressed over the proximity of AOCs 44 & 52 to the Grove Pond drinking water wells.
This Responsiveness Summary is organized into the following sections:
I. Overview of Remedial Alternatives Considered in the FS Including the Selected Remedy
- This section briefly outlines the remedial alternatives evaluated in detail in
the FS and the Proposed Plan, including the Army's selected remedy.
II. Background on Community Involvement - This section provides a brief history of
community involvement and Army initiatives in apprising the community of Site
activities.
III. Summary of Comments Received During the Public Comment Period and Army Responses -
This section provides Army responses to the verbal and written comments received
from the public and not formally responded to during the public meeting. A
transcript of the public meeting consisting of all comments received during this
meeting and the Army's responses to these comments are provided in Attachment A of
this Responsiveness Summary.
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I. Overview of Remedial Alternatives Considered in the Feasibility Study Including the
Selected Remedy
Eleven alternatives were initially developed in the FS Report. Of the eleven alternatives, seven
were retained in the FS screening step and were evaluated in detail. The seven alternatives
are:
• Alternative 1: No Action (as required by the National Contingency Plan)
The No Action Alternative includes sampling of groundwater monitoring wells and
stormwater catch basins located within and downgradient of the Maintenance Yards for
up to five years. The No Action Alternative does not involve remedial actions to
control migration of substances or institutional controls to prevent exposure to
affected soils within the Maintenance Yards.
• Alternative 2: Fencing/Asphalt Batching Hot Spot Areas
This alternative includes preventing access by maintaining fencing around the site
that would limit potential exposure pathways. Deed and land use restrictions would
be implemented to ensure that the fence remained intact in the future. Excavating
and asphalt batching the hot spot area soils using an on-site cold-mix process would
reduce the volume of compounds present in the highest concentrations at the AOCs.
Asphalt batched material from the hot spots would be used as paving base material at
the site. Sampling and analysis of groundwater, stormwater and sediments within or
downgradient of the Maintenance Yards would also be performed to monitor for
off-site migration of compounds.
• Alternative 3: Capping Site/Asphalt Batching Hot Spot Areas
This alternative entails excavating and asphalt batching the hot spot area soils,
expanding the existing stormwater collection system including construction of
detention pond(s), capping the entire site with asphalt pavement, and groundwater
monitoring. Deed and land use restrictions would be implemented to ensure that the
cap remained intact in the future to minimize exposure to surface soils. Excavating
and asphalt batching hot spot area soils in the Cannibilization Yard would reduce
the volume of compounds present in the highest concentrations at the AOCs. Asphalt
batched material from the hot spots would be used as paving base material at the
site. Sampling and analysis of groundwater within or downgradient of the
Maintenance Yards would also be performed to monitor for a migration of compounds to
the groundwater.
The Army's Selected Remedy is Alternative 5.
• Alternative 5: Asphalt Batching Site/Asphalt Batching Hot Spot Areas
Alternative 5 involves excavating the top two feet of soil across the site and the
two hot spot areas; placing excavated soils in piles at the site for sampling and
analysis; cold mix asphalt batching these soils which exceed (do not meet) site
cleanup levels; backfilling site excavations with stockpiled soil having compound
concentrations below cleanup levels, followed by placement of the cold mix asphalt
batched material; expanding the existing stormwater collection system including
construction of detention pond(s); applying a pavement wearing course for a vehicle
parking surface over the Maintenance Yards; and performing groundwater monitoring.
Alternative 5 will immobilize the petroleum substances in the top two feet of soil
which exceed (do not meet) cleanup levels, thus minimizing direct contact/ingestion
and inhalation of the soils. Excavating and asphalt batching hot spot areas in the
Cannibalization Yard will reduce the mobility of organic compounds present in the
highest concentrations at the site. Additionally, Alternative 5 minimizes the
potential of petroleum substances migrating off-site.
The proposed pavement wearing course is not a required component of the Alternative
5 that is evaluated in the FS Report. The Army has chosen to add this component
to Alternative 5 as part of the preferred alternative to ensure the integrity of the
asphalt batched material as a parking lot base for current and future property use.
Also, as discussed in the ROD, deed restrictions will be instituted to prohibit
residential development, minimize the possibility of long-term (working lifetime)
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exposure to subsurface soils, and require management of soils resulting from
construction related activities.
• Alternative 7: Bioventing Site and Hot Spot Areas
This alternative involves bioventing the entire site and the hot spot areas, and
performing groundwater monitoring. This alternative includes initial nutrient
injection in the areas by tractor and installation of approximately 20 bioventing
wells, with associated piping, blower, and humidifier. An asphalt pavement cap
would be installed over the entire area of the AOCs to prevent short circuiting of
air. Bioventing would reduce the compounds present in the top two feet, thus
minimizing direct contact/ingestion and inhalation of the surface soils.
Additionally, the concentration of the compounds would be reduced in depths down to
approximately 10 feet over the site area. Sampling and analysis of groundwater
within or downgradient of the Maintenance Yards would also be performed to monitor
for any migration of substances to the groundwater. As detailed in the ROD, a deed
restriction would be instituted to prohibit residential development within the
Maintenance Yards.
• Alternative 8: Landfarming Site/Excavating and Landfarming Hot Spot Areas
This alternative includes mechanically screening out the asphalt pavement pieces
from surface soil, landfarming the entire area of the AOCs, excavating and
landfarming the hot spot area soils that exceed do not meet) cleanup levels, and
performing groundwater monitoring. The landfarming process involves applying
nutrients and moisture to the soil. The soil is tilled using disk plows or
rototillers to mix and aerate the soil which encourages naturally occurring soil
bacteria to degrade and stabilize the petroleum compounds. Landfarming will reduce
the compounds present in the top two feet of soil, thus minimizing direct contact/
ingestion and inhalation of the soils. Additionally, the concentration of compounds
could be reduced in depths below 2 feet over the site area by applying excess
nutrients and water to the soil surface. Deed restrictions would also be applied as
described in Alternative 5.
Alternative 9: Treatment of Site and Hot Spot Area Soils at a Central Soil
Treatment Facility
Alternative 9 entails excavating the top two feet of soil across the site and the
two hot spot areas; placing excavated soils in piles at the site for sampling and
analysis; transporting soils which exceed (do not meet) site cleanup levels to a
central soil treatment facility on base; and performing groundwater monitoring at
the Maintenance Yards. As a pre-treatment process, surface soil in areas of the
site containing bituminous pavement pieces would be screened mechanically to remove
large sized fragments. The treatment methods to be used at the central soil
treatment facility would be windrow composting and cold mix asphalt batching.
Alternative 9 would reduce the compounds present in the top two feet of soil and hot
spot areas excavated. Deed restrictions would also be applied as described in
Alternative 5.
It will take approximately four months to clean-up the site once construction activities on-site
have started.
II. Background on Community Involvement
Throughout the Site's history, community concern and involvement has generally centered around
the fact that the Maintenance Yards are located in close proximity to the town of Ayer Grove
Pond wells. The Army has kept the community and other interested parties apprized of site
activities through regular and freguent informational meetings, fact sheets, press releases and
public meetings.
The Army released a community relations plan in February 1992, that had been submitted earlier
for public review, outlining a program to address community concerns, and to keep citizens
informed about and involved in activities during remedial activities. As part of this plan, the
Army established a Technical Review Committee (TRC) in early 1992. The TRC, as required by SARA
Section 211 and Army Regulation 200-1, includes representatives from USEPA, USAEC, Fort Devens,
MADEP, local officials and the community. The committee generally met quarterly (until January
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1994, when it was replaced by the Restoration Advisory Board [RAB]) to review and provide
technical comments on work products, schedules, work plans and proposed activities for the SAs
at Fort Devens. The SI and FS Reports, Proposed Plan and other related support documents were
all submitted to the TRC for their review and comment. Additionally, AOCs 44 & 52 activity was
specifically discussed at TRC meetings held March 24, 1992, January 5, 1993, August 2, 1993 and
January 26, 1994.
As part of the Army's commitment to involving the affected communities, a RAB is formed when an
installation closure involves transfer of property to the community. The RAB was formed in
February 1994 to add members of the Citizen's Advisory Committee (CAC) with current TRC members.
The CAC was previously established to address Massachusetts Environmental Policy Act
(MEPA)/Environmental Assessment issues concerning the reuse of property at Fort Devens. The RAB
consists of 28 members (15 original TRC members plus 13 new members) who are representatives
from the Army, USEPA Region I, MADEP, local governments and citizens of the local communities.
It meets monthly and provides advice to the installation and regulatory agencies on Fort Devens
cleanup programs. Specific responsibilities include: addressing cleanup issues such as land
use and cleanup goals; reviewing plans and documents; identifying proposed reguirements and
priorities; and conducting regular meetings which are open to the public. The proposed plan for
AOCs 44 & 52 was presented at the June 2, 1994 RAB meeting.
On May 16, 1994, the Army issued a fact sheet to more than 100 citizens and organizations,
providing the public with a brief explanation of the preferred alternative for cleanup of the
Maintenance Yards. It described the opportunities for public participation, and provided
details on the public comment period and public meetings to be held.
On May 16, the Army issued a press release concerning the proposed cleanup at the Maintenance
Yards, to the Lowell Sun, Worcester Telegram, Fitchburg-Leominster Sentinel & Enterprise,
Harvard Post, Public Spirit (Ayer) and Fort Devens Dispatch. During the week of June 6, 1994,
the Army published a public notice concerning the Proposed Plan and public hearing in the Public
Spirit, the Fitchburg-Leominster Sentinel & Enterprise, the Lowell Sun, and the Fort Devens
Dispatch. The Army also made the plan available to the public at the information repositories
located at the libraries in Ayer, Shirley, Lancaster, Harvard and at Fort Devens.
On May 24, 1994, the Army held an informal informational meeting at Fort Devens to discuss the
results of the field investigation and the cleanup alternatives presented in the FS and to
present the Army's Proposed Plan. This meeting also provided the opportunity for open
discussion concerning the proposed cleanup. From May 25 to June 24, 1994, the Army held a 30-day
public comment period to accept public comments on the alternatives presented in the FS and the
Proposed Plan and on other documents released to the public. On June 15, 1994 the Army held a
formal public meeting at Fort Devens to discuss the Proposed Plan and to accept any verbal
comments from the public. A transcript of this meeting and the comments and the Army's response
to comments are included in this responsiveness summary.
All supporting documentation for the decision regarding the Maintenance Yards is placed in the
Administrative Record for review. The Administrative Record is a collection of all the
documents considered by the Army in choosing the remedy for the Maintenance Yards. On May 27,
1994 the Army made the Administrative Record available for public review at the Fort Devens BRAG
Environmental Office, and at the Ayer Town Hall, Ayer, Massachusetts. An index to the
Administrative Record was available at the USEPA Records Center, 90 Canal Street, Boston,
Massachusetts and is provided as Appendix E.
III. Summary of Comments Received During the Public Comment Period and Army Responses
Comments la through Id: The current chairman of the Ayer Board of Selectmen expressed her
belief that proper notification was not received by the town of Ayer regarding the Proposed Plan
for remediation of the Barnum Road Maintenance Yards. Also, she had heard that to save money
there was a change in plans for cleanup of the site from what was proposed many months ago, or
maybe a year ago. The chairman specifically stressed the importance of the town's involvement
due to the recent vote by the people of Ayer to reconstruct a well at Grove Pond downgradient of
the Maintenance Yards. Specific guestions relating to the above general concerns were:
Comment la: How many feet from the Grove Pond well is this hot spot that you're talking about?
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Army Response: During the public hearing the Army responded that it was over 2,000 feet but an
exact figure was not available. A more precise distance between the Grove Pond wells and the
Maintenance Yards is approximately 2,200 feet. The proposed cleanup of the Maintenance Yards,
as detailed in the FS and Proposed Plan, focuses on surface soils (0 to 2 feet below ground
surface) which have been affected by releases of gasoline, motor oil, and other automotive
fluids and includes two "hot spots": 1) surface and subsurface (below 2 feet) soils associated
with a reported release of "mogas" (motor vehicle gasoline) in 1985, and 2) subsurface soils
associated with leakage from a 1,000-gallon underground waste oil storage tank which was removed
in May 1992.
Comment Ib: Were you aware when you [selected the remedy] that the Grove Pond wells were going
to be reused?
Army Response: The Army was aware that the town of Ayer was considering returning its potable
water supply wells on Grove Pond to regular service. Protection of this aguifer was a major
consideration in developing remedial alternatives, proposing a preferred alternative for public
comment, and selecting the remedy. The FS and Proposed Plan discuss the potential redevelopment
of these wells and delineate the Zone II area of influence (zone of contribution to the wells
under the most severe pumping and recharge conditions that can be anticipated realistically).
AOCs 44 & 52 are located within this Zone II area as defined in a report prepared for the town
of Ayer entitled "Town of Ayer, Massachusetts Grove Pond Wells Hydrogeologic Investigation and
Zone II Aguifer Mapping" by the town of Ayer's consultant, Camp, Dresser & McKee, Inc. (1993).
Comment Ic: How much conversation has there been with the town of Ayer about what you have
contemplated doing, and who have you been talking to in Ayer?
Army Response: Section II of this Responsiveness Summary describes the Army's actions taken to
inform the public about the environmental restoration of the Maintenance Yards. The SI and FS
Reports, Proposed Plan and other related support documents were all submitted to the TRC for
review and comment. TRC members from the town of Ayer have included the former and current
Superintendent of Public Works, and Nashoba Associated Boards of Health, Environmental Health
Division representative. The Fact Sheet (issued to the public to describe the preferred
alternative and opportunities for public participation in the cleanup plan) was mailed to more
than 100 citizens and organizations. Included in this mailing were the following officials
and/or affiliations for the town of Ayer: the above TRC members, the Executive Director of the
Ayer Chamber of Commerce, the Ayer Board of Health, the Chairman of the Board of Selectmen, the
Executive Secretary, the Conservation Commission, the Water Bylaw Commission Chairperson, the
Joint Boards of Selectmen, and six other citizens/merchants of the town of Ayer.
Comment Id: The town needs an explanation of why there has been a change [in plans for cleanup
of the site from what was proposed many months ago or maybe a year ago].
Army Response: At least two other remedial alternatives detailed in the FS Report were
evaluated as a possible preferred alternative and then changed or eliminated in favor of another
alternative, prior to officially issuing the final Proposed Plan to the public. At one time in
the evaluation process, Alternative 8 - Landfarming the Site and Excavating and Landfarming Hot
Spot Areas, was considered a possible preferred alternative. This alternative was eliminated
principally due to the proximity of the Grove Pond water supply wells and recommendation by the
MADEP Central Regional Office Water Supply Section. Landfarming reguires applying nutrients to
the soil and there was concern of nitrate/nitrites and phosphates migrating to the groundwater.
Later in the evaluation and review process, Alternative 9 - Treatment of Site and Hot Spot Area
Soils at a Central Soil Treatment Facility was considered a possible preferred alternative.
This alternative was also eventually eliminated because of the difficulty in reusing
compost-treated soils at AOCs 44 & 52 or elsewhere at Fort Devens in a manner that would be
considered adeguately regulated in accordance with the Massachusetts Contingency Plan (MCP).
Alternative 5 - Asphalt Batching the Site and Asphalt Batching the Hot Spot Areas was eventually
selected as the preferred alternative in the final Proposed Plan which was issued to the public
in May 1994. Alternative 5 was considered to be more protective by forming a low-permeable
(asphalt batched) layer, thus further protecting the groundwater from the potential migration
of compound 3 and further preventing any possible exposure to affected subsurface soil (if any).
Alternative 5 is less expensive than Alternative 9, but more expensive than Alternative 8.
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Comment 2: The MADEP Central Regional Office Fort Devens Section Chief expressed that the MADEP
believes that Alternative 5 is the most protective of the proposed alternatives. She added that
the MADEP would like to state that it is their understanding that the Army will excavate any
"grossly contaminated" soil encountered, besides the top two feet and the two hot spot areas.
They would like to make sure that these include areas where previous sampling has shown that
soil below 2 feet contained compounds above the cleanup levels, especially in the spill
containment pad area.
Army Response: The Army proposes to excavate any highly affected soil encountered in addition
to the top two feet of soil and the two hot spot areas as the MADEP has reguested. This was
stated in the Final Excavated Soils Management Plan (ESMP) dated May 1994 (Page 2-4). Except
for the two hot spot areas, previous sampling below 2 feet has not shown soil to be affected
above established cleanup levels.
SI samples collected from 15 borings at depths of 5 to 7 feet and 10 to 12 feet revealed total
petroleum hydrocarbon compound (TPHC) concentrations that meet the cleanup level (500 ppm). The
cleanup level for carcinogenic polynuclear aromatic hydrocarbons (cPAHs) (an average total cPAH
concentration of 7 ppm) was derived based on a surface soil exposure scenario and is not
applicable to subsurface soils. Risk evaluation for subsurface soils indicate that human health
risks are within the acceptable USEPA target risk range. However, even if the cPAH cleanup
concentration for surface soil was applied to the subsurface soil, only one of 31 subsurface
soil samples exceeds (does not meet) the cleanup level of 7 ppm (16.4 ppm from boring 44B-92-01X
at the 5- to 7-foot depth). The average concentration of total cPAHs is below 7 ppm.
Exploratory test pits were excavated for construction of a concrete spill-containment basin in
the southeast corner of the TDA Maintenance Yard, in July 1991. These initial test pits
revealed zones of contaminated soil below the surface (TPHC was found at 420 to 700 ]lg/g
concentrations in surface soil samples). However, following removal of approximately 1,200 tons
of soil for construction of the basin, confirmation samples collected from the proposed basin's
subgrade at the bottom of the excavation contained TPHC concentrations ranging from nondetect
to only 7 ppm.
Comment 3: The MADEP also reguested that the Army review their spill management plan with the
DOL to ensure, that prior to remediation, there is a good management plan for spills and that
the spill containment pad is utilized to minimize the likelihood of further impacting soils.
This concern is raised due to the MADEP's interpretation that there were new spills detected
during the supplemental site investigations last year.
Army Response: The Army will review the spill management plan to ensure that approved
procedures are being followed. However, the MADEP's comment warrants clarification. The
"spills" referred to in the MADEP's comment was actually one drip spot, of the size commonly
found in public parking areas or residence driveways and far less than the MADEP reportable
guantity of 10 gallons.
Comment 4: The Environmental Outreach Coordinator for the Fort Devens Reuse Center asked what
the general depth of groundwater is at the site and generally how far have the contaminants
migrated through the soil in the yard?
Army Response: The approximate depth of the water table is 26 to 28 feet. Groundwater sampling
conducted in July 1992, October 1992, June 1993, and September 1993 in the area, shows no
evidence that substances found in the soils of the Maintenance Yards have migrated to the
groundwater table and are affecting groundwater guality.
Based on the SI soil sampling results, the average TPHC concentrations across the site at the 0-
to 2-foot, 5- to 7-foot and 10- to 12-foot ranges are 315 ppm, 52 ppm and 33 ppm respectively.
Maximum TPHC concentrations are 1210 ppm, 170 ppm and 119 ppm respectively. These values
exclude the TPHC concentrations at boring 44B-92-06X (that may be associated with the mogas
spill) and TPHC concentrations associated with the waste oil underground storage tank (UST).
Excluding these two areas, TPHC concentrations that exceed (do not meet) the 500 ppm target
level are found only in the top 2-foot sampling level. Average cPAH concentrations across the
site at the 0- to 2-foot, 5- to 7-foot and 10-to 12-foot ranges are 31 ppm, 2 ppm, and 0.2 ppm.
Maximum cPAH concentrations are 220 ppm, 16.4 ppm and 1.5 ppm respectively. Risk evaluations
indicate that human health risks exceed the acceptable USEPA Superfund target risk range only
-------
from exposure to cPAHs in the top 2 feet of soil.
TPHC concentrations exceed (do not meet) the 500 ppm cleanup level below 2 feet in the hot spot
areas. TPHC concentrations were detected at 1560 ppm down to the 10- to 12-foot range in boring
44B-92-06X (mogas spill hot spot area). Soil samples collected from the sidewalls (9 feet below
ground surface [bgs]) of overexcavated soils surrounding the removed waste oil UST, revealed
TPHC concentrations ranging from 1,110 to 2,740 ppm. However TPHC was detected in only two of 16
additional samples collected from supplemental SI borings in the UST area. Concentrations were
121 ppm (10 feet bgs) and 38 ppm (5 feet bgs) which meet the cleanup level. Subsurface soils in
both hot spot areas will be excavated to remove TPHC contaminated soils that exceed (do not
meet) the cleanup level.
Comment 5: The current chairman of the Ayer Board of Selectmen asked if the groundwater
monitoring wells sampled included the town of Ayer Grove Pond well. She also asked if it is
important that the Grove Pond well also be sampled.
Army Response: During the public hearing the Army responded that the Grove Pond wells have been
sampled by USEPA but not concurrently with the Army's sampling efforts at AOCs 44 & 52. (The
specifics of these sampling events were not recalled during the meeting). Specifically, both
Grove Pond wells were sampled between 7/3/90 and 8/21/91. Tetrachloroethene, a cleaning
solvent, was detected in one sample from Well #2 in 1991 at a concentration of 1.2 ]lg/l which
is below (better than) state and federal Maximum Contaminant Levels (MCLs) for drinking water.
No tetrachloroethene has been detected in AOCs 44 & 52 soils. Sampling of the Grove Pond wells
was also performed by the town of Ayer's consultant in 1992. Sampling was conducted in
conjunction with the extended pumping tests to examine the guality of water produced by the
wells in accordance with Massachusetts Drinking Water Regulations. There were no volatile
organics, pesticides or semivolatile organics detected during this sampling event. As with any
drinking water supply, the MADEP will reguire the town of Ayer to sample the Grove Pond wells if
they are to be used as a potable water source.
Comment 6: The current Superintendent of the town of Ayer Department of Public Works also
expressed his concern about the cleanup, since AOCs 44 & 52 are located within the Zone II for
the Grove Pond drinking water wells. He stated that wells have historically served the town of
Ayer as the main source of drinking water but over the last few years have not been used except
for emergency situations because of high iron and manganese content in the water. The
Superintendent stated that this situation is about to change due to plans for construction of a
new filter plant. Once this plant is constructed, Ayer proposes to pump 1 million gallons per
day (mgd) from the Grove Pond well source. He stated that the proposed cleanup of the Barnum
Road Maintenance Yards sounds adeguate, provided a strong monitoring program is in place and
that if a problem develops, guick remedial action will be taken.
Army Response: The Proposed Plan includes sampling groundwater for a period of five years
following remediation of the soils at the Barnum Road Maintenance Yards. Details of this
monitoring program will be specified in the forthcoming remedial design. The Army does not
expect that the groundwater will ever be impacted by the past Maintenance Yards activities,
after soil remediation. In addition to soil treatment by asphalt batching, the Proposed Plan
provides greater aguifer protection through the construction of the low-permeable pavement
barrier at the site. However, should groundwater become affected, Alternative 5 does not impede
the ability to guickly conduct further remedial actions.
Comment 7: A merchant in the town of Ayer stated that the Army needs to start addressing
contamination in Plow Shop Pond. He has not heard much lately on this issue and would like to
keep informed.
Army Response: The Army has made Plow Shop Pond a separate operable unit from the remediation
being performed at the Barnum Road Maintenance Yards. Sites are broken into separate operable
units so that the substances present at each site can be more comprehensively addressed.
Additional analytical sampling in Plow Shop Pond is proposed this summer. The sampling is being
performed to investigate water guality of the pond and to evaluate potential remedial
alternatives. Current and proposed activities at Plow Shop Pond will follow the remedial
investigation and feasibility study (RI/FS) process established by the USEPA Superfund program
which encourages public involvement. The Army will be keeping the community and other
interested parties apprized of Plow Shop Pond activities through TRC meetings, public
-------
informational meetings, fact sheets, press releases and public hearings as was done for the
Barnum Road Maintenance Yards.
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ATTACHMENT A
PUBLIC HEARING TRANSCRIPT
1 Volume I
2 Pages 1 to 11
3
4
5 FORMAL PUBLIC HEARING
6 FINAL PROPOSED PLAN
7
BARNUM ROAD MAINTENANCE YARDS
8 AOCs 44 & 52
9 FORT DEVENS, MASSACHUSETTS
10
11
12
13 Held at:
Fort Devens, Massachusetts
14 Wednesday, June 15, 1994
15
(Robin Gross, Registered Professional Reporter)
16
17
18
]_g * * * *
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21
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24
DORIS 0. WONG ASSOCIATES
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1 PROCEEDINGS
2 MR. CHAMBERS: It's now about 7:30, I'd
3 like to commence the formal public comment period.
4 My name is James Chambers, I'm the BRAG
5 Environmental Coordinator here at Fort Devens. As I
6 say, the public comment period began May 25, 1994,
7 and ends June 24, 1994. Comments may be either made
8 this evening or submitted in writing to the
9 following address, and I'll announce that right
10 now: Send that to AFZD-BEC, Post Office Box 1, Fort
11 Devens, Massachusetts, 01433. And you may call me
12 also at area code 508-796-3114.
13 Comments received during this period will
14 be responded to in a document known as a
15 Responsiveness Summary that we anticipate will issue
16 on or before August 9, depending on the number of
17 comments we receive. We anticipate a draft Record
18 of Decision being made at that time, with a final
19 Record of Decision being made on September 12.
20 And with that, I'd like to invite public
21 comment. If you submit on cards, I will read
22 those. Once again, if you submit it on cards,
23 please write your name and your affiliation; and if
24 you elect to stand and make your announcement,
DORIS 0. WONG ASSOCIATES
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1 please announce your name and your affiliation.
2 MS. HAMEL: Do you want me to start? I'm
3 Pauline Hamel. I'm chairman of the Ayer Board of
4 Selectmen. My problem with this is I don't believe
5 proper notification was received by the town of the
6 work that's going to be done in that yard, and our
7 concern is that last night at town meeting the
8 people of the Town of Ayer voted to I guess you
9 might say reconstruct a well that's at the bottom of
10 this site. This is going to be our major water
11 supply for the Town of Ayer. It was our major water
12 supply several years ago; then we went to wells at
13 Spectacle Pond, which is on the other side of town,
14 but found they're not sufficient to our needs.
15 After considerable consultation with other
16 people by our DPW superintendent it was decided that
17 we would go back to the Grove Pond wells, to
18 reconstruct and put a considerable amount of money
19 with the future construction, even after the initial
20 work on the wells to clear the magnesium and
21 whatever else is in there; that there will be
22 additional capacity later on, and it will be built
23 so that we can use it for many, many years because
24 of the aguifer that runs under that.
DORIS 0. WONG ASSOCIATES
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1 My problem is this: Many months ago, when
2 Mr. Doney was head of the Reuse Center, he
3 informed me that there was an extensive cleanup
4 proposed for this particular area. It was not the
5 cleanup, as he described it to me, it was not the
6 cleanup that has recently been described to me.
7 Only accidentally did I find out about this
8 cleanup. We were interviewing, strangely enough,
9 for Mr. Doney's position at the Reuse Center about
10 three weeks ago when a gentleman made a remark about
11 a change that the government had in the cleanup of
12 this particular area. And when Eric Knapp, who
13 represents Massachusetts Land Bank, said to him,
14 "Where did you get that information? That's not
15 public knowledge," I just listened; he would not
16 state.
17 The next day I tried to find out more
18 information, and all I was told was that I didn't
19 have to worry about it; it was and had changed, but
20 I didn't have to worry, that it was a procedure,
21 process for cleaning that was acceptable to the
22 Massachusetts Land Bank. We are naturally not the
23 Massachusetts Land Bank, we are the town, and we
24 have to look for many years to that for a water
DORIS 0. WONG ASSOCIATES
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1 source.
2 I would like to ask one question here
3 before I go further, perhaps you can tell me: How
4 many feet from the Grove Pond well is this hot spot
5 that you're talking about?
6 CAPTAIN PEASE: It's over 2,000 feet. I'm
7 not sure of the exact figure.
8 MS. HAMEL: Were you aware when you did
9 that that the Grove Pond wells were going to be
10 reused? How much conversation has there been with
11 the Town of Ayer about what you have contemplated
12 doing, and who have you been talking to in Ayer?
13 MR. CHAMBERS: We'll respond to that in the
14 responsiveness summary.
15 MS. HAMEL: All right. These are my
16 questions. My concern, naturally, is that all of a
17 sudden there's a change in the plans for the cleanup
18 of that area. I know nothing about -- it certainly
19 isn't within my knowledge to know whether this is a
20 good or a bad plan. I was told of a meeting that
21 was to take place in Sudbury which I attended last
22 Friday at which some people were present,
23 and they explained to me that they thought it was
24 probably a better plan than the initial one, but I'm
DORIS 0. WONG ASSOCIATES
-------
1 certainly not convinced that it is.
2 And due to the fact that millions of
3 dollars were voted on last night to build this well
4 at Grove Pond, I think the Town of Ayer and the
5 people there need some explanation as to why the
6 extensive cleanup that was proposed may months ago,
7 maybe a year ago, is no longer planned. I was told
8 it was to save money. Whether that's true or not, I
9 don't know. But I certainly feel the town needs an
10 explanation as to why there has been a change.
11 And also I'd like to know who here has been
12 talking to people in the Town of Ayer, and who those
13 people are, and why we didn't receive -- I certainly
14 didn't know anything about a March 25 meeting, and
15 only by accident did I learn about it, because these
16 people who I saw on Friday told me about this
17 meeting tonight. And then I had to call around
18 today to find out -- I'm sorry that I didn't write
19 down the time and the place, and I had to call
20 around today several places to find out about the
21 time and the place. So I think that's a disservice
22 to the town, really.
23 As an individual who's elected to watch out
24 for the welfare of the people in the town, I feel
DORIS 0. WONG ASSOCIATES
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1 that the military certainly has not fulfilled its
2 obligation to the Town of Ayer in advising it what
3 is being done down there or above our contemplated
4 wells. That's all I have to say.
5 MS. WELSH: My name is Lynne Welsh, I'm
6 from the Massachusetts Department of Environmental
7 Protection, and I will be submitting written
8 comments during the comment period but I wanted to
9 take this opportunity to state that we have viewed
10 the plan which recommends Alternative 5, with
11 cleanup levels of 7 parts per million of
12 carcinogenic PAHs and 500 parts per million TPH, and
13 believe that this is the most protective of the
14 proposed alternatives.
15 As we have stated to you and a group of
16 other people last Friday, we do have two concerns
17 which we have talked to the Army about and just
18 wanted to state that our understanding is that
19 besides the excavation of the top two feet and the
20 hot spots there also be excavation of grossly
21 contaminated soil. And we'd like to make sure that
22 these include the areas where previous sampling has
23 shown that soil was contaminated above the cleanup
24 levels in areas below two feet, especially the
DORIS 0. WONG ASSOCIATES
-------
1 cleanup levels in the spill containment pad; that if
2 these are grossly contaminated, they should be
3 excavated also.
4 During the investigation which the Army was
5 doing last year, the supplemental investigation,
6 sampling by ABB showed new spills in the yards, and
7 we'd like the Army to review their spill management
8 plan with the DOL, Division of Labor -- whoever runs
9 the TDA yards -- to make sure that during the time
10 when study and when the design is going on that
11 there's a good management plan out there for the
12 spills and that the spill containment pad is
13 utilized so there's less likelihood of more grossly
14 contaminated soils that need to be remediated.
15 Thank you.
16 MR. CHAMBERS: More comments?
17 MS. KOHN: My name is Judith Kohn, K-o-h-n,
18 and I am the Environmental Outreach Coordinator for
19 the Fort Devens Reuse Center. I just have a general
20 guestion: What's the general depth of groundwater
21 in this site, 44, 52?
22 CAPTAIN PEASE: 26 feet.
23 MS. KOHN: I guess a follow-up guestion to
24 that, how far generally have the contaminants
DORIS 0. WONG ASSOCIATES
-------
1 migrated through the soil in the yard?
2 MR. CHAMBERS: We'll respond to that in the
3 responsiveness summary.
4 MS. KOHN: Thank you. That's all I have.
5 MR. CHAMBERS: More comments?
6 MS. HAMEL: I have one additional one that
7 I'd like to ask. You mentioned that there were
8 eight wells checked. Was one of them the Grove Pond
9 well?
10 CAPTAIN PEASE: That was sampled but not
11 concurrently. That was sampled at another time by
12 — I'm going to have use the EPA for help. The EPA
13 sampled or that area? By someone?
14 MS. HAMEL: It's not important that well be
15 checked that well.
16 MR. CHAMBERS: We'll respond to that in the
17 responsiveness summary.
18 (Pause)
19 MS. HAMEL: Can I ask one other guestion?
20 Does the Army still use their well which is right
21 besides Ayer's Grove Pond well? There's a well that
22 sits right beside the Grove Pond well or, you know,
23 it's relatively close, it's just down, I don't know,
24 I have no idea 2,000 feet or 200 feet, but it's
DORIS 0. WONG ASSOCIATES
-------
1 right adjacent to the Grove Pond well, and does the
2 Army still use that well?
3 CAPTAIN PEASE: Yes, the Army uses that
4 well.
5 MS. HAMEL: Has that well been tested?
6 CAPTAIN PEASE: Yes, it has.
7 MR. CHAMBERS: Okay. I'd like to ask once
8 again if there are more comments. Okay. With that,
9 we'd like to close this public comment meeting.
10 Thank you.
11 (Whereupon, the proceedings were
12 closed at 7:46 p.m.)
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22
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24
DORIS 0. WONG ASSOCIATES
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1 CERTIFICATE
2 I, Robin Gross, Registered Professional
3 Reporter, do hereby certify that the foregoing
4 transcript, Volume I, is a true and accurate
5 transcription of my stenographic notes taken on
6 Wednesday, June 15, 1994.
7
9
10 Robin Gross
11 Registerd Professional Reporter
12
13
14
15
16
17
18
19
20
21
22
23
24
DORIS 0. WONG ASSOCIATES
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BARNUM ROAD MAINTENANCE YARDS
AOCs 44 & 52
ROD SUMMARY
APPENDIX D
DECLARATION OF STATE CONCURRENCE
![]() Commonwealth of Massachusetts
Executive Office of Environmental Affairs
Department of
Environmental Protection
Central Regional Office
William F. Weld
Governor
Trudy Coxe
Secretary, EQEA
Thomas B. Powers
Acting Commissioner
March 7, 1995
Mr. John De Villars
Regional Administrator
U.S. Environmental Protection Agency
Region I
JFK Federal Building
Boston, MA 02203
RE: Barnum Road Maintenance Yards (BRMY), AOCs 44 and 52, Fort
Devens, MA, ROD Concurrence
Dear Mr. De Villars:
The Massachusetts Department of Environmental Protection (MADEP) has reviewed the preferred
remedial alternative recommended by the Army and the EPA for the final cleanup of the Barnum
Road Maintenance Yards, the core provisions of which are summarized below. The MADEP has worked
closely with the Army and EPA in the development of the preferred alternative and is pleased to
concur with the Army's choice of the remedial alternative.
The MADEP has evaluated the preferred alternative for consistency with M.G.L. c. 21E (21E) and
the Massachusetts Contingency Plan (MCP). The remedial alternative addresses the entire BRMY as
one operable unit and includes the following components:
• Excavate the top two feet of surface soil across the site;
• Excavate the two hot spot areas;
• Stockpile soils for sampling analysis;
• Cold mix asphalt batch soils exceeding site cleanup levels;
• Backfill excavations with uncontaminated stockpiled soil and with asphalt batched
material;
• Apply a pavement wearing course
• Expand the existing stormwater collection system;
• Perform groundwater monitoring;
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ROD Concurrence
Fort Devens, MA
March 7, 1995
Page 2
• As a precautionary measure, institute deed restrictions to preclude receptor contact with
subsurface soils. These deed restrictions include:
1) prohibit residential monitoring;
2) minimize the possibility of long term (working lifetime) exposure to subsurface soils,
3) reguire management of soils resulting from future construction related activities that
may temporarily disturb the cap.
The MADEP's concurrence with the preferred remedial alternative is based upon the expectation
that it will result in a permanent solution as defined in 2IE and the MCP and that contaminant
concentrations achieved during the implementation of the remedial alternative will meet the MCP
standards.
The MADEP would like to thank EPA, in particular the Fort Devens Remedial Project Manager, Jim
Byrne, for their efforts to ensure that the reguirements of the MADEP were met in the selection
of the remedial alternative. We look forward to continuing to work with EPA in the
implementation of the remedial alternative. If you have any guestions, please contact Lynne
Welsh at (508) 792-7653, ext. 3851.
Sincerely,
Cornelius O'Leary
Regional Director
MADEP, CERO
cc: Fort Devens Mailing List (Cover Letter Only)
Edward Kunce, MADEP
Jay Naparstek, MADEP
Informational Repositories
Jim Byrne, EPA
Charles George, AEC
Mark Applebee, ACOE
Judy Kohn, Mass Land Bank
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BAENUM ROAD MAINTENANCE YARDS
AOCs 44 & 52
ROD SUMMARY
APPENDIX E
ADMINISTRATIVE RECORD INDEX
Fort Devens
Group 3, 5, & 6 Sites
Administrative Record File for
Fort Devens Barnum Road Maintenance Yard
Areas of Concern 44/52
Index
Prepared for
New England Division
Corps of Engineers
by
ABB ENVIRONMENTAL SERVICES, INC.
107 Audubon Road, Wakefield, Massachusetts 01880 (617) 245-6606
Introduction
This document is the Index to the Administrative Record File for the Fo
Devens Barnum Road Maintenance Yard - Areas of Concern (AOCs) 44/52.
Section I of the Index cites site-specific documents and Section II cites
documents used by U.S. Army staff in selecting a response action at the si
Some documents in this Administrative Record File Index have been cited bu
physically included. If a document has been cross-referenced to another
Administrative Record File Index, the available corresponding comments and
responses have been cross-referenced as well.
The Administrative Record File is available for public review at EPA
Region I's Office in Boston, Massachusetts, at the Fort Devens Environment
Management Office, Fort Devens, Massachusetts, and at the Ayer Town Hall,
1 Main Street, Ayer, Massachusetts. Supplemental/Addendum volumes may be
added to this Administrative Record File. Questions concerning the
Administrative Record should be addressed to the Fort Devens Base Realignm
and Closure Office (BRAG).
The Administrative Record is reguired by the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act (SARA).
Section I
Site-Specific Documents
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ADMINISTRATIVE RECORD FIIiE INDEX
Fort Devens Barnum Road Maintenance Yard
Fort Devens Barnum Road Maintenance Yard
Areas of Concern 44/52
Compiled: March 1995
1.0 Pre-Remedial
Cross Reference: The following Reports, Comments, and Responses to
Comments (entries 1 through 6) are filed and cited as entries 1 thro
in minor break 1.2 Preliminary Assessment of the Fort Devens Group 1
Administrative Record File Index.
Reports
1. "Final Master Environmental Plan for Fort Devens," Argonne
National Laboratory (April 1992).
2. "Preliminary Zone II Analysis for the Production Wells at Fort
Devens, MA, Draft Report", ETA Inc. (January 1994) .
Comments
3. Comments Dated May 1, 1992 from Walter Rolf, Montachusett
Regional Planning Commission on the April 1992 "Final Master
Environmental Plan for Fort Devens," Argonne National Laboratory
4. Comments Dated May 7, 1992 from James P. Byrne, EPA Region I
on the April 1992 "Final Master Environmental Plan for Fort
Devens," Argonne National Laboratory.
5. Comments Dated May 23, 1994 from D. Lynne Welsh,
Commonwealth of Massachusetts Department of Environmental
Protection on the January 1994 "Preliminary Zone II Analysis for
the Production Wells at Fort Devens, MA, Draft Report", ETA Inc.
Responses to Comments
6. Response Dated June 29, 1992 from Carrol J. Howard, Fort Devens
to the May 7, 1992 Comments from James P. Byrne, EPA Region I.
Reports
1.3 Site Inspection
Cross-Reference: The following Reports, Comments, Responses to
Comments, Responses to Responses to Comments, and Meeting Notes
(entries 1 through 25) are filed and cited as entry numbers 1 throug
minor break 1.3 Site Inspection Reports of the Fort Devens Groups 3,
6 Sites Administrative Record Index.
Reports
1. "Final Task Order (Site Investigation) Work Plan," ABB
Environmental Services, Inc. (September 1992).
2. "SI Data Packages," ABB Environmental Services, Inc. (December
1992).
3. "Final Site Investigation Report - Groups 3, 5, & 6, Fort Devens
Massachusetts," ABB Environmental Services, Inc. (April 1993).
4. "Supplemental Site Investigation - Groups 3, 5, and 6, Fort Deve
Massachusetts, Task Order Work Plan," ABB Environmental
Services, Inc. (rev. July 1993).
5. "Supplemental Site Investigation - Data Package," ABB
Environmental Services, Inc. (September 1993).
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Comments
6. Comments Dated April 15, 1992 from D. Lynne Chappell,
Commonwealth of Massachusetts Department of Environmental
Protection on the March 1992 "Draft SI Work Plan for Groups 3, 5
& 6," ABB Environmental Services, Inc.
7. Comments Dated May 1, 1992 from James P. Byrne, EPA Region I
on the "Draft SI Work Plan for Groups 3, 5, & 6, and Project
Operations Plan" ABB Environmental Services, Inc.
8. Comments Dated July 21, 1992 from D. Lynne Chappell,
Commonwealth of Massachusetts Department of Environmental
Protection on the June 1992 "Draft Final Work Plan for Groups 3,
5, & 6," ABB Environmental Services, Inc.
9. Comments Dated July 28, 1992 from James P. Byrne, EPA Region I
on the June 1992 "Draft Final Work Plan for Groups 3, 5, & 6,"
ABB Environmental Services, Inc
10. Comments Dated October 26, 1992 from D. Lynne Chappell,
Commonwealth of Massachusetts Department of Environmental
Protection on the September 1992 "Final Task Order (Site
Investigation) Work Plan," ABB Environmental Services, Inc.
11. Comments Dated October 29, 1992 from James P. Byrne, EPA
Region I on the September 1992 "Final Task Order (Site
Investigation) Work Plan," ABB Environmental Services, Inc.
12. Comments Dated January 19, 1993 from James P. Byrne, EPA
Region I on the December 1992 "SI Data Packages," ABB
Environmental Services, Inc.
13. Comments Dated February 3, 1993 from D. Lynne Chappell,
Commonwealth of Massachusetts Department of Environmental
Protection on the December 1992 "SI Data Packages," ABB
Environmental Services, Inc.
14. Comments Dated May 6, 1993 from James P. Byrne, EPA Region I
on the April 1993 "Final SI Report, Fort Devens Site Investigati
Groups 3, 5, and 6," ABB Environmental Services, Inc.
15. Comments Dated May 20, 1993 from D. Lynne Chappell,
Commonwealth of Massachusetts Department of Environmental
Protection on the April 1993 "Final SI Report, Fort Devens Site
Investigation, Groups 3, 5, and 6," ABB Environmental Services,
16. Comments Dated August 26, 1993 from D. Lynne Chappell,
Commonwealth of Massachusetts Department of Environmental
Protection on the July 1993 "Final Work Plan for the Supplemental
Site Investigation, Groups 3, 5, & 6," ABB Environmental Service Inc.
17. Comments Dated October 25, 1993 from D. Lynne Welsh,
Commonwealth of Massachusetts Department of Environmental
Protection on the September 1993 "Supplemental SI Data Package
for Fort Devens SI Groups 3, 5, & 6," ABB Environmental Services
Inc.
18. Comments Dated November 8, 1993 from James P. Byrne, EPA
Region I on the September 1993 "Supplemental SI Data Package for
Fort Devens SI Groups 3, 5, & 6," ABB Environmental Services, Inc.
Responses to Comments
19. Responses Dated June 4, 1992 from U.S. Army Toxic and
Hazardous Materials Agency on the April 15, 1992 Comments from
D. Lynne Chappell, Commonwealth of Massachusetts Department
of Environmental Protection and the May 1, 1992 Comments from
James P. Byrne, EPA Region I.
20. Responses Dated September 24, 1992 from U.S. Army Toxic and
Hazardous Materials Agency on the July 21, 1992 Comments from
D. Lynne Chappell, Commonwealth of Massachusetts Department
of Environmental Protection and the July 28, 1992 Comments from
James P. Byrne, EPA Region I.
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21. Responses Dated July 7, 1993 from U.S. Army Environmental
Center on the May 6, 1993 Comments from James P. Byrne, EPA
Region I and the May 20, 1993 Comments from D. Lynne Chappell,
Commonwealth of Massachusetts Department of Environmental
Protection.
Responses to Responses to Comments
22. Responses Dated July 28, 1992 from James P. Byrne, EPA Region I
on the June 4, 1992 Comments from U.S. Army Toxic and
Hazardous Materials Agency.
23. Responses Dated August 26, 1993 from D. Lynne Chappell-Welsh,
Commonwealth of Massachusetts Department of Environmental
Protection on the July 7, 1993 Comments from U.S. Army
Environmental Center.
Meeting Notes
24. Meeting Notes, ABB Environmental Services, Inc., EPA Region I,
Commonwealth of Massachusetts Department of Environmental
Protection, Fort Devens Environmental Management Office, U.S.
Army Environmental Center, and COM Federal Programs Corp.
(January 20, 1993). Concerning SI Data Package.
25. Meeting Notes, ABB Environmental Services, Inc., EPA Region I,
Commonwealth of Massachusetts Department of Environmental
Protection, Fort Devens Environmental Management Office, U.S.
Army Environmental Center, and COM Federal Programs Corp.
(September 27, 1993). Concerning Supplemental SI Data Package.
2.0 Removal Response
2.2 Removal Response Reports
1. "Post-Removal Report Underground Storage Tank Closure, 1,000
Gallon Waste Oil UST No. 0058, Building 3713, Fort Devens,
Massachusetts," ATEC Environmental Consultants (October 1993).
2.3 Sampling and Analysis Data
1. "Technical Report Related to the Field Screening of Soil Samples
the Site of the Proposed Spill Containment Basin, Project No. EQ
1902109P, Fort Devens, Massachusetts," Lincoln Environmental, In
(February 1992).
2.4 Pollution Reports (POLREPs)
1. Memorandum from R. Spelfogel, U.S. Dept. of the Army to File
(May 1, 1985). Concerning inspection of Cannibalization Point -
TDA Maintenance Yard, Fort Devens.
3.0 Remedial Investigation (RI)
3.2 Sampling and Analysis Data
1. Cross-Reference: "Method for Determining Backgrowd
Concentrations - Inorganic Analytes in Soil and Groundwater - Fo
Devens," ABB Environmental Services, Inc. (January 20, 1993)
[Filed and cited as entry nwmber 1 in minor break 32 Sampling an
Analysis Data of the Fort Devens Group 1A Sites Administrative
Record Index].
3.4 Interim Deliverables
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Reports
Cross Reference: "Final Ground Water Flow Model at Fort
Devens," Engineering Technologies Associates, Inc. (May 24, 1993
[Filed and cited as entry number 1 in minor break 3.4 Interim
Deliverables of the Fort Devens Group 1A Sites Administrative
Record Index].
Cross Reference: "Final Projects Operations Plan - Volume I of
III," ABB Environmental Services, Inc. (December 1992). [Filed
and cited as entry number 2 in minor break 3.4 Interim Deliverab
of the Fort Devens Group 2 & 7 Administrative Record File Index]
Cross Reference: "Final Projects Operations Plan - Volume II of
- Appendix A: Health and Safety Plan," ABB Environmental
Services, Inc. (December 1992). [Filed and cited as entry numbe
in minor break 3.4 Interim Deliverables of the Fort Devens Group
& 7 Administrative Record File Index].
Cross Reference: "Final Projects Operations Plan - Volume III o
III - Appendix B: Laboratory QA Plan; Appendix C:
USATHAMA-Certified Analytical Methods," ABB Environmental
Services, Inc. (December 1992). [Filed and cited as entry numbe
in minor break 3.4 Interim Deliverables of the Fort Devens Group
& 7 Administrative Record File Index].
Comments
Cross Reference: Comments Dated January 12, 1993 from James P.
Byrne, EPA Region I on the December 1992 "Final Projects
Operations Plan," ABB Environmental Services, Inc. [Filed and
cited as entry number 5 in minor break 3.4 Interim Deliverables
the Fort Devens Group 2 & 7 Administrative Record File Index].
Cross Reference: Comments Dated February 1, 1993 from James P.
Byrne, USEPA Region I and D. Lynne Chappell, Commonwealth of
Massachusetts Department of Environmental Protection on the
October 30, 1992 "Draft Final Ground Water Flow Model at Fort
Devens," Engineering Technologies Associates, Inc. [Filed and ci
as entry number 2 in minor break 3.4 Interim Deliverables of the
Fort Devens Group 1A Sites Administrative Record File Index].
Cross Reference: Comments Dated February 17, 1993 from D.
Lynne Chappell, Commonwealth of Massachusetts Department of
Environmental Protection on the December 1992 Final Project
Operations Plan," ABB Environmental Services, Inc. [Filed and
cited as entry number 7 in minor break 3.4 Interim Deliverables
the Fort Devens Group 2 & 7 Administrative Record File Index.
3.5 Applicable or Relevant and Appropriate Reguirements (ARARs)
Cross-Reference: The following reports (entries 1 and 2) are filed a
cited as entries 1 and 2 in minor break 3.5 Applicable or Relevant an
Appropriate Reguirements of the Fort Devens Groups 3, 5, & 6 Sites
Administrative Record Index.
Reports
"Draft Applicable or Relevant and Appropriate Reguirements
(ARARs) for CERCLA Remedial Actions," U.S. Army Toxic and
Hazardous Materials Agency (June 1992).
"Draft Assessment of Location-Specific Applicable or Relevant an
Appropriate Reguirements (ARARs) for Fort Devens,
Massachusetts," U.S. Army Toxic and Hazardous Materials Agency
(September 1992).
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4.0 Feasibility Study (FS)
4.4 Interim Deliverables
Reports
1. "Feasibility Evaluation Bioremediation of Maintenance Yard Soils
Biological Treatability Study Report," ABB Environmental Service
Inc. (September 1993).
2. "Final Siting Study Report for Central Soil Treatment Facility,"
Environmental Services, Inc. (January 1994).
Comments
3. Comments Dated November 5, 1993 from D. Lynne Welsh,
Commonwealth of Massachusetts Department of Environmental
Protection on the September 1993 "Feasibility Evaluation
Bioremediation of Maintenance Yard Soils, Biological Treatabilit
Study Report," ABB Environmental Services, Inc.
4. Comments Dated December 27, 1993 from James P. Byrne, EPA
Region I on the November 1993 "Draft General Management
Procedures, Excavated Waste Site Soils, Draft Siting Study Repor
for Central Soil Treatment Facility and the Feasibility Study Re
for Unsaturated Soils at the Maintenance Yards (New Alternative
9)" ABB Environmental Services, Inc.
5. Comments Dated January 13, 1994 from Molly Elder,
Commonwealth of Massachusetts Department of Environmental
Protection on the November 1993 "Draft Siting Study Report for
Central Soil Treatment Facility," ABB Environmental Services, In
6. Comments Dated March 11, 1994 from D. Lynne Welsh,
Commonwealth of Massachusetts Department of Environmental
Protection on the September 1993 "Feasibility Evaluation
Bioremediation of Maintenance Yard Soils, Biological Treatabilit
Study Report," ABB Environmental Services, Inc.
Responses to Comments
7. U.S. Army Environmental Center Responses to Comments on the
following documents: Feasibility Study Report, Biological
Treatability Study Report, Feasibility Study Report - New
Alternative 9, Draft General Management Procedures Excavated
Waste Site Soils, and Draft Siting Study Report, dated January 2 1994.
8. U.S. Army Environmental Center Responses to Comments on the
following documents: Final Feasibility Study Report, Draft Prop
Plan, Revised Draft Proposed Plan, Draft Excavated Soils
Management Plan, Final General Management Procedures
Excavated Waste Site Soils, and Biological Treatability Study
Report, dated May 1994.
4.6 Feasibility Study (FS) Reports
Reports
1. "Final Feasibility Study Report for Unsaturated Soils at the
Maintenance Yards (Areas of Contamination 44 and 52) Fort
Devens," ABB Environmental Services, Inc. (January 1994).
2. "Final Feasibility Study Addendum for Unsaturated Soils at
Maintenance Yards AOCs 44/52, Fort Devens, Massachusetts," ABB
Environmental Services, Inc. (May 1994).
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Comments
3. Comments Dated July 9 and July 15, 1993 from James P. Byrne,
EPA Region I on the June 1993 "Draft Focused Feasibility Study
Report on AOCs 44 & 52, " ABB Environmental Services, Inc.
4. Comments Dated July 29, 1993 from D. Lynne Chappell
Commonwealth of Massachusetts Department of Environmental
Protection on the June 1993 "Draft Focused Feasibility Study Rep
AOCs 44 & 52," ABB Environmental Services, Inc.
5. Comments Dated October 13, 1993 from D. Lynne Welsh,
Commonwealth of Massachusetts Department of Environmental
Protection on the August 1993 "Feasibility Study Report for
Unsaturated Soils at Maintenance Yards AOCs 44/52, Fort Devens,
Massachusetts," ABB Environmental Services, Inc.
6. Comments Dated December 16, 1993 from Molly J. Elder,
Commonwealth of Massachusetts Department of Environmental
Protection on the November 1993 "Feasibility Study Report for
Unsaturated Soils at Maintenance Yards AOCs 44/52, Fort Devens,
Massachusetts," ABB Environmental Services, Inc.
7. Cross-Reference: Comments Dated December 27, 1993 from James
P. Byrne, EPA Region I on the November 1993 "Draft General
Management Procedures, Excavated Waste Site Soils, Draft Siting
Study Report for Central Soil Treatment Facility and Feasibility
Study Report for Unsaturated Soils at Maintenance Yards - New
Alternative 9," ABB Environmental Services, Inc. These comments
are filed and cited as a part of entry number 4 in the comments
section 4.4 Interim Deliverables of this minor break.
Comments Dated February 28, 1994 from James P. Byrne, EPA
Region I on the "Draft Proposed Plan and Final Feasibility Study
for AOCs 44 & 52 (TDA Yard)," ABB Environmental Services, Inc.
9. Comments Dated March 11, 1994 from D. Lynne Welsh,
Commonwealth of Massachusetts Department of Environmental
Protection on the January 1994 "Final Feasibility Study Report,
Devens Feasibility Study AOCs 44 & 52," ABB Environmental
Services, Inc.
Responses to Comments
10. U. S. Army Environmental Center Responses to Comments on the
following documents: Fort Devens Focused Feasibility Study (FFS
for AOCs 44 and 52; Draft Feasibility Study Work Plan, FFS Initi
Screening Document; and Supplemental Field Investigations and
Data Gathering Maintenance Yard Soils Work Plan, dated June 25, 1993.
11. U. S. Army Environmental Center Responses to Comments on the
following document: Draft Feasibility Study Report AOCs 44 and
Fort Devens, dated August 27, 1993.
12. Cross-Reference: U. S. Army Environmental Center Responses to
Comments on the following documents: Feasibility Study Report;
Biological Treatability Study Report; Feasibility Study Report -
Alternative 9; Draft General Management Procedures Excavated
Waste Site Soils; and Draft Siting Study Report, dated January 2
1994. [These Responses to Comments are filed and cited as a par
of entry number 7 in the Responses to Comments section 4.4 in th
minor break].
13. U. S. Army Environmental Center Responses to Comments on the
following documents: Final Feasibility Study Report, Draft Prop
Plan, Revised Draft Proposed Plan, Draft Excavated Soils
Management Plan, Final General Management Procedures
Excavated Waste Site Soils, and Biological Treatability Study
Report, dated May 1994.
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4.7 Work Plans and Progress Reports
Reports
1. "Final Focused Feasibility Study Work Plan," ABB Environmental
Services, Inc. (June 1993).
2. "Final Excavated Soils Management Plan for AOCs 44 & 52," ABB
Environmental Services, Inc (May 1994).
Comments
3. Comments Dated June 8, 1993 from James P. Byrne, EPA Region I
on the June 1993 "Fort Devens Supplemental Field Investigations
and Data Gathering Maintenance Yard Soils; Fort Devens Focused
Feasibility Study Work Plan; Fort Devens Focused Feasibility Stud
Initial Screening Document," ABB Environmental Services, Inc.
4. Comments Dated June 9, 1993 from D. Lynne Chappell,
Commonwealth of Massachusetts Department of Environmental
Protection on the Draft Feasibility Study Work Plan," ABB
Environmental Services, Inc.
5. Comments Dated June 10, 1993 from D. Lynne Chappell,
Commonwealth of Massachusetts Department of Environmental
Protection on the "Supplemental Field Investigations and Data
Gathering, Maintenance Yards Soils, AOCs 44 & 52," ABB
Environmental Services, Inc.
6. Comments Dated June 15, 1993 from James P. Byrne, EPA
Region I on the June 1993 "Treatability Study Work Plan,
Supplemental Field Investigations and Data Gathering Maintenance
Yard Soils, Fort Devens," ABB Environmental Services, Inc.
7. Comments Dated March 11, 1994 from D. Lynne Chappell,
Commonwealth of Massachusetts Department of Environmental
Protection on the January 1994 "Draft Excavated Soils Management
Plan, AOCs 44 and 52," ABB Environmental Services, Inc.
Responses to Comments
8. Cross-Reference: U. S. Army Environmental Center Responses to
Comments on the following documents: Fort Devens Focused
Feasibility Study (FFS) for AOCs 44 and 52; Draft Feasibility Stu
Work Plan, FFS Initial Screening Document; Supplemental Field
Investigations and Data Gathering Maintenance Yard Soils Work
Plan, dated June 25, 1993. [These Responses to Comments are file
and cited as a part of entry # 10 in section 4.6].
9. Cross-Reference: U. S. Army Environmental Center Responses to
Comments on the following documents: Final Feasibility Study
Report; Draft Proposed Plan; Revised Draft Proposed Plan; Draft
Excavated Soils Management Plan; Final General Management
Procedures Excavated Waste Site Soils and Biological Treatability
Study Report, dated May 1994. [These Responses to Comments are
filed and cited as a part of entry number 8 in minor break 4.4
Interim Deliverables of the Fort Devens AOC 44/52 Administrative
Record File Index].
4.9 Proposed Plans for Selected Remedial Action
1. Cover letter from James C. Chambers, BRAG Environmental
Coordinator to James P. Byrne, EPA Region I (April 11, 1994) .
Concerning transmittal of a new draft Proposed Plan, and including
rationale for change in the Army's preferred alternative.
2. "Final Proposed Plan, Fort Devens Barnum Road Maintenance
Yards, AOCs 44 & 52," ABB Environmental Services, Inc. (May 1994).
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Comments
3. Cross-Reference: Comments Dated February 28, 1994 from James
P. Byrne, EPA Region I on the January 1994 "Draft Proposed Plan,
Fort Devens Barnum Road Maintenance Yards, AOCs 44 & 52,"
ABB Environmental Services, Inc. These Comments are filed and
cited as a part of entry number 8 in the Comments section 4.6 of
this minor break].
4. Comments Dated March 11, 1994 from D. Lynne Welsh,
Commonwealth of Massachusetts Department of Environmental
Protection on the January 1994 "Draft Proposed Plan, Fort Devens
Barnum Road Maintenance Yards, AOCs 44 & 52," ABB
Environmental Services, Inc.
5. Comments Dated March 18, 1994 from D. Lynne Welsh,
Commonwealth of Massachusetts Department of Environmental
Protection on the January 1994 "Draft Proposed Plan, Fort Devens
Barnum Road Maintenance Yards, AOCs 44 & 52," ABB
Environmental Services, Inc.
6. Comments Dated May 5, 1994 from D. Lynne Welsh,
Commonwealth of Massachusetts Department of Environmental
Protection on the April 1994 "Revised Draft Proposed Plan for
Barnum Road Maintenance Yards, AOCs 44 & 52," ABB
Environmental Services, Inc.
7. Comments Dated May 9, 1994 from James P. Byrne, EPA Region I
on the April 1994 "Revised Draft Proposed Plan for Barnum Road
Maintenance Yards, AOCs 44 & 52," ABB Environmental Services, Inc.
Responses to Comments
8. Cross-Reference: U. S. Army Environmental Center Responses to
Comments on the following documents: Final Feasibility Study
Report; Draft Proposed Plan; Revised Draft Proposed Plan; Draft
Excavated Soils Management Plan; Final General Management
Procedures Excavated Waste Site Soils; and Biological Treatability
Study Report, dated May 1994 [These Responses to Comments are
filed and cited as a part of entry number 8 in the Responses to
Comments section 4.4 of this minor break].
9. Cross-Reference: U. S. Army Environmental Center Responses to
Comments on the following documents: Fort Devens Focused
Feasibility Study (FFS) for AOCs 44 and 52; Draft Feasibility Stu
Work Plan, FFS Initial Screening Document; Supplemental Field
Investigations and Data Gathering Maintenance Yard Soils Work
Plan, dated June 25, 1993. [These Responses to Comments are file
and cited as a part of entry number 10 in the Responses to
Comments section 4.6 of this minor break].
5.0 Record of Decision (ROD)
5.4 Record of Decision
Reports
1. "Revised Draft Record of Decision Barnum Road Maintenance
Yards, Fort Devens, Massachusetts, ABB Environmental Services,
Inc. (September 7, 1994).
2. "Record of Decision Barnum Road Maintenance Yards, Fort
Devens, Massachusetts, ABB Environmental Services, Inc.
(September 13, 1994).
3. "Record of Decision Barnum Road Maintenance Yards, Fort
Devens, Massachusetts (Final)," ABB Environmental Services, Inc.
(March 1995).
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Comments
4. Comments Dated August 19, 1994 from James P. Byrne, USEPA
Region I on the August 1994 "Draft Record of Decision Barnum
Road Maintenance Yards, Fort Devens, Massachusetts," ABB
Environmental Services, Inc.
5. Comments Dated August 25, 1994 from D. Lynne Welsh,
Commonwealth of Massachusetts Department of Environmental
Protection on the August 1994 "Draft Record of Decision Barnum
Road Maintenance Yards, Fort Devens, Massachusetts," ABB
Environmental Services, Inc.
6. Comments Dated September 16, 1994 from John Regan,
Commonwealth of Massachusetts Department of Environmental
Protection on the review of the activity and use limitation (AUL)
7. Comments Dated September 16, 1994 from Cornelius O'Leary,
Commonwealth of Massachusetts Department of Environmental
Protection on the Barnum Road Maintenance Yards (AOCs 44 &
52), Fort Devens, Massachusetts, ROD Concurrence.
8. Comments Dated February 17, 1995 from James P. Byrne, USEPA
on the Draft Radiological Report for the Cannibalization Yard and
TDA Maintenance Yard and the Proposed Section XII
(Documentation of No Significant Changes) Revisions to the
Barnum Road Maintenance Yards Record of Decision.
Responses to Comments
9. Responses Dated September 7, 1994 from U.S. Army Environmental
Center on the following document: Draft Record of Decision,
Barnum Road Maintenance Yards, Fort Devens, Massachusetts.
5.5 Work Plans and Progress Reports
Reports
1. "Draft Radiological Survey Work Plan, Area of Contamination
(AOCs) 44 & 52, Barnum Road Maintenance Yards, Fort Devens,
Massachusetts," ABB Environmental Services, Inc. (October 1994).
2. "Final Radiological Survey Work Plan, Area of Contamination
(AOCs) 44 & 52, Barnum Road Maintenance Yards, Fort Devens,
Massachusetts, ABB Environmental Services, Inc. (December 1994).
3. "Draft Radiological Status Report for Cannibalization Yard and
TDA Maintenance Yard, Area of Contamination 44 & 52, Fort
Devens, Massachusetts,. ABB Environmental Services, Inc.
(February 1995).
4. "Final Radiological Status Report for Cannibalization Yard and
TDA Maintenance Yard, Area of Contamination 44 & 52, Fort
Devens, Massachusetts," ABB Enviromental Services, Inc. (March 1995)
Comments
5. Comments Dated November 15, 1994 from James P. Byrne,
USEPA, on the "Draft Radiological Survey Work Plan for the
Barnum Road Maintenance Yard," ABB Environmental Services, Inc.
6. Comments Dated November 16, 1994 from D. Lynne Welsh,
Commonwealth of Massachusetts Department of Environmental
Services on the October 1994 "Draft Radiological Survey Work Plan
Areas of Contamination (AOCs) 44 & 52, Barnum Road
Maintenance Yards, Fort Devens, MA," ABB Environmental
Services, Inc.
7. Comments Dated November 29, 1994 from D. Lynne Welsh,
Commonwealth of Massachusetts Department of Environmental
Protection on the October 1994 "Draft Radiological Survey Work
-------
Plan, Areas of Contamination (AOCs) 44 & 52, Barnum Road
Maintenance Yards, Fort Devens, Massachusetts," ABB
Environmental Services, Inc.
8. Comments Dated December 16, 1994 from James P. Byrne, USEPA,
on the Final Radiological Survey Work Plan and Response to
Comments for the Barnum Road Maintenance Yards, (ABB
Environmental Services, Inc.).
9. Comments Dated December 27, 1994 from D. Lynne Welsh,
Commonwealth of Massachusetts Department of Environmental
Protection on the Draft Radiological Survey Work Plan, Areas of
Contamination (AOC) 44 & 52, and Final Radiological Work Plan,
Areas of Contamination (AOCs) 44 & 52, Fort Devens,
Massachusetts.
10. Cross Reference: Comments Dated February 17, 1995 from James
P. Byrne, USEPA, on the Draft Radiological Report for the
Cannibalization Yard and TDA Maintenance Yard and the
Proposed Section XII (Documentation of No Significant Changes)
Revisions to the Barnum Road Maintenance Yards Record of
Decision. [Filed and cited as entry number 8 in minor break 5.4
Record of Decision in this index.]
11. Comments Dated March 3, 1995 from D. Lynne Welsh,
Commonwealth of Massachusetts Department of Environmental
Protection the February 1995 "Draft Radiological Status Report fo
Cannibalization Yard and TDA Maintenance Yard, Areas of
Contamination 44 & 52, Fort Devens, Massachusetts," (ABB
Environmental Services, Inc.).
Responses to Comments
12. Responses Dated December 13, 1994 from U.S. Army
Environmental Center on the following document: Draft
Radiological Survey Work Plan, Areas of Contamination (AOCs) 44
& 52, Fort Devens, Massachusetts.
13. Responses Dated March 1995 from U.S. Army Environmental
Center on the following document: Draft Radiological Status
Report for Cannibalization Yard and TDA Maintenance Yard,
Areas of Contamination 44 & 52, Fort Devens, Massachusetts.
Responses to Responses to Comments
14. Cross Reference: Comments Dated December 16, 1994 from James
P. Byrne, USEPA, on the Final Radiological Survey Work Plan and
Response to Comments for the Barnum Road Maintenance Yards,
(ABB Environmental Services, Inc.). [Filed and cited as entry
number 8 in minor break 5.5 Work Plans and Progress Reports in
this index.]
10.0 Enforcement
10.16 Federal Facility Agreements
1. Cross-Reference: "Final Federal Facility Agreement Under
CERCLA Section 120," EPA Region I and U.S. Department of
the Army (November 15, 1991) with attached map [Filed and
cited as entry number 1 in minor break 10.16 Federal Facili
Agreements of the Fort Devens Group 1A Sites Administrative
Record Indexl.
13.0 Community Relations
13.2 Community Relations Plans
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1. Cross-Reference: "Final Community Relations Plan," Ecology
and Environment, Inc. (February 1992) [Filed and cited as
number 1 in minor break 13.2 Community Relations Plans of t
Fort Devens Group 1A Sites Administrative Record Index].
13.5 Fact Sheets
1. Barnum Road Maintenance Yards Fact Sheet, Fort Devens,
Massachusetts," ABB Environmental Services, Inc. (May 1994)
13.11 Technical Review Committee Documents
Cross-Reference: The following documents cited below as entries
number 1 through 8 are filed and cited as entries number 1 throug
minor break 13.11 Technical Review Committee Documents of the For
Devens Group 1A Sites Administrative Record Index.
1. Technical Review Committee Meeting Agenda and Summary
(March 21, 1991).
2. Technical Review Committee Meeting Agenda and Summary
(June 27,1991) .
3. Technical Review Committee Meeting Agenda and Summary
(September 17, 1991) .
4. Technical Review Committee Meeting Agenda and Summary
(December 11, 1991).
5. Technical Review Committee Meeting Agenda and Summary
(March 24, 1992).
6. Technical Review Committee Meeting Agenda and Summary
(June 23, 1992) .
7. Technical Review Committee Meeting Agenda and Summary
(September 29, 1992) .
8. Technical Review Committee Meeting Agenda and Summary
(January 5, 1993).
17.0 Site Management Records
17.6 Site Management Plans
Cross-Reference: The following Reports, Comments, and Responses
Comments (entries 1 through 9) are filed and cited in minor break
Site Management Records of the Groups 3, 5, & 6 Administrative Re
Index unless otherwise noted below.
Reports
"Final Quality Assurance Project Plan," Ecology and
Environment, Inc. (November 1991).
"General Management Procedures, Excavated Waste Site Soils,
Fort Devens, Massachusetts," ABB Environmental Services, In
(January 1994).
Comments
Cross Reference: Comments from James P. Byrne, EPA Region
I on the November 1991 "Final Quality Assurance Project Pla
Ecology and Environment, Inc. [These Comments are filed an
cited as a part of entry number 8 in the Responses to Comme
section of this minor break].
Comments Dated December 16, 1993 from Molly J. Elder,
Commonwealth of Massachusetts Department of Environmental
Protection on the November 1993 "Draft General Management
Procedures, Excavated Waste Site Soils, Fort Devens,
-------
Massachusetts," ABB Environmental Services, Inc.
5. Comments Dated December 27, 1993 from James P. Byrne, EPA
Region I on the November 1993 "Draft General Management
Procedures, Excavated Waste Site Soils, Fort Devens,
Massachusetts," ABB Environmental Services, Inc. [Filed and
cited as entry number 4 in minor break 4.4 Interim Delivera
of the AOCs 44/52 Administrative Record Index.]
6. Comments Dated March 11, 1994 from D. Lynne Welsh,
Commonwealth of Massachusetts Department of Environmental
Protection on the January 1994 "General Management
Procedures, Excavated Waste Site Soils, Fort Devens,
Massachusetts," ABB Environmental Services, Inc.
Responses to Comments
7. Cross-Reference: U. S. Army Environmental Center Responses
Comments on the following documents: Feasibility Study Rep
Biological Treatability Study Report; Feasibility Study Rep
New Alternative 9; Draft General Management Procedures
Excavated Waste Site Soils; and Draft Siting Study Report,
January 25, 1994. [These Responses to Comments are filed a
cited as a part of entry number 7 in the Responses to Comme
section of minor break 4.4 Interim Deliverables of the AOCs
44/52 Administrative Record Index.]
8. Response from Fort Devens to Comments from James P. Byrne,
EPA Region I on the November 1991 "Final Quality Assurance
Project Plan," Ecology and Environment, Inc.
9. Cross-Reference: U.S. Army Environmental Center Responses
Comments for the following documents: Final Feasibility St
Report; Draft Proposed Plan; Revised Draft Proposed Plan;
Draft Excavated Soils Management Plan; Final General
Management Procedures Excavated Waste Site Soils; and
Biological Treatability Study Report, dated May 1994. [The
Responses to Comments are filed and cited as entry number 8
the Responses to Comments section of minor break 4.4 Inter!
Deliverables of the AOCs 44/52 Administrative Record Index.
17.9 Site Safety Plans
Cross Reference: The following documents (entries 1 through 3) a
and cited in minor break 17.9 Site Safety Plans of the Fort Deven
1A Administrative Record File Index unless otherwise noted below.
Reports
1. "Final Health and Safety Plan," Ecology and Environment, In
(November 1991).
Comments
2. Cross Reference: Comments from James P. Byrne, EPA Region
I on the November 1991 "Final Health and Safety Plan," Ecol
and Environment, Inc. [These Comments are filed and cited
part of entry number 8 in minor break 17.6 Site Management
Plans of the Group 1A Sites Administrative Record File Inde
Responses to Comments
3. Response from Fort Devens to Comments from James P. Byrne,
EPA Region I on the November 1991 "Final Health and Safety
Plan," Ecology and Environment, Inc.
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Section II
GUIDANCE DOCUMENTS
The following guidance documents were relied upon during the Fort
cleanup. These documents may be reviewed, by appointment only, a
Environmental Management Office at Fort Devens, Massachusetts.
1. Occupational Safety and Health Administration (OSHA) . Haza
Waste Operation and Emergency Response (Final Rule, 29 CFR
1910, Federal Register. Volume 54, Number 42) March 6, 198
2. USATHAMA Geotechnical Reguirements for Drilling Monitoring
Data Acguisition, and Reports, March 1987.
3. USATHAMA. IRDMIS User's Manual, Version 4.2, April 1991.
4. USATHAMA. USATHAMA Quality Assurance Program: PAM-41,
January 1990.
5. USATHAMA Draft Underground Storage Tank Removal Protocol
Fort Devens, Massachusetts, December 4, 1992.
6. U.S. Environmental Protection Agency. Guidance for Prepara
Combined Work/Quality Assurance Project Plans for Environme
Monitoring: OWRS QA-1, May 1984.
7. U.S. Environmental Protection Agency. Office of Research a
Development Interim Guidelines and Specifications for Prepa
Assurance Project Plans: QAMS-005/80, 1983.
8. U.S. Environmental Protection Agency. Office of Emergency
Remedial Response. Interim Final Guidance for Conducting R
Investigations and Feasibility Studies Under CERCLA, (OSWER
Directive 9355.3-01, EPA/540/3-89/004, 1986.
9. U.S. Environmental Protection Agency. Test Methods for Eva
Solid Waste: EPA SW-846 Third Edition, September 1986.
10. U.S. Environmental Protection Agency. Office of Emergency
Remedial Response. Risk Assessment Guidance for Superfund,
Volume I, Human Health Evaluation Manual (Part A) , (EPA/540
002), 1989.
11. U.S. Environmental Protection Agency. Hazardous Waste Mana
System; Identification and Listing of Hazardous Waste: Tox
Characteristic Revisions, (Final Rule, 40 CFR Part 261 et a
Register Part V), June 29, 1990.
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BAENUM ROAD MAINTENANCE YARDS
AOCs 44 & 52
ROD SUMMARY
APPENDIX F
GLOSSARY OF ACRONYMS AND ABBREVIATIONS
ABB-ES
AOCs
ARAR
AREE
B2EHP
B(a)P
bgs
BRAG
BTEX
CAC
CERCLA
CMR
cPAHs
cy
DoD
EPCs
FS
GC/FID
HEAST
HI
IAG
IRIS
IRP
m3
MADEP
MCL
MCP
MEPA
MEP
mg/1
MHWMR
NAAQS
NPL
NCP
NDIR
O&M
PA
PAH
PAL
PCB
PCL
PID
ppm
RAB
RfD
ROD
RTS
SA
SARA
SI
SSI
SVOC
TCLP
TDA
ABB Environmental Services, Inc.
Areas of Contamination
Applicable or Relevant and Appropriate Requirements
Area Requiring Environmental Evaluation
bis(2-ethylhexyl)phthalate
benzo(a)pyrene
below ground surface
Base Realignment and Closure Act
benzene, toluene, ethylbenzene, and xylene
Citizen's Advisory Committee
Comprehensive Environmental Response, Compensation, and
Liability Act
Code of Massachusetts Regulations
carcinogenic polynuclear aromatic hydrocarbons
cubic yard
Department of Defense
Exposure Point Concentrations
Feasibility Study
gas chromatograph/flame ionization detector
Health Effects Assessment Summary Tables
Hazard Index
Federal Facilities Interagency Agreement
Integration Risk Information System
Installation Restoration Program
cubic meter
Massachusetts Department of Environmental
Protection
Maximum Contaminant Level
Massachusetts Contingency Plan
Massachusetts Environmental Policy Act
Master Environmental Plan
milligrams per liter
Massachusetts Hazardous Waste Management Rules
National Ambient Air Quality Standard
National Priority List
National Contingency Plan
Non-dispersive Infrared
Operation and Maintenance
Preliminary Assessment
polynuclear aromatic hydrocarbon
Project Analyte List
polychlorinated biphenyl
protective contaminant level
Photoionization Detector
parts per million
Restoration Advisory Board
Reference Dose
Record of Decision
Regional Training Site
Study Area
Superfund Amendments and Reauthorization Act of 1986
Site Investigations
Supplemental Site Investigation
semivolatile organic compound
Toxicity Characteristic Leachate Procedure
Table of Distribution and Allowances
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TEF Toxic Equivalency Factor
TPHC total petroleum hydrocarbon compound
TRC Technical Review Committee
TSP total suspended particulate
TSS total suspended solids
]lg/l micrograms per liter
USAEC United States Army Environmental Center
USAEHA United States Army Environmental Hygiene Agency
USEPA United States Environmental Protection Agency
UST underground storage tank
VOC volatile organic compound
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