EPA/ROD/R01-95/113
                                    1995
EPA Superfund
     Record of Decision:
     FORT DEVENS
     EPA ID: MA7210025154
     OU01
     FORT DEVENS, MA
     09/26/1995

-------
                                                                  5
                                                          FORT DEVENS
                                                     FEASIBILITY STUDY
                                                    FOR GROUP 1A SITES
                                   RECORD OF DECISION
                        SHEPLEY'S HILL LANDFILL OPERABLE UNIT
                              FORT DEVENS, MASSACHUSETTS
                               IN ACCORDANCE WITH U.S. ARMY REGULATION 290-2,
                          THIS DOCUMENT K INTENDED BY THE UJS. ARMY TO COMPLY WITH THE
                                NATIONAL ENVIRONMENTAL POLICY ACT OF 19(9.
                                      SEPTEMBER 1995
                                      PRINTED ON RECYCLED PAPER
AEC Form <>5, 1  Feb 93 replaces THAMA Form *»5 which is obsolete.

-------
To:          C. Keating and B. Brandon, EPA
From:        C. Stein and D. McTigue, Gannett Fleming Inc.
Subject:      Discussion of groundwater extraction at SHL
We understand that recent discussions at EPA have raised questions concerning the
installation of a pump-and-treat (PAT) system at the toe of SHL as the interim remedy of
choice (as mandated by the!995 ROD).   Below, we have attempted to outline possible
arguments for, and against, the implementation of this system, with particular emphasis
on the technical (hydrologic and geochemical) issues, and some acknowledgment of
various political, regulatory, and economic issues that have emerged, to date.
Benefits ("pros"):

1.  There is a public perception that problems caused by SHL are Army's responsibility,
   so some remedy should be implemented as soon as possible to prevent further "off-
   site migration."

2.  There is little doubt that the proposed contingency remedy would be effective, at least
   on a local scale. The PAT scheme would remove dissolved As, Fe, and low-ORP
   groundwater emerging from the toe of the landfill.

3.  Emplacement of this system will satisfy the ROD (1995).

4.  Emplacement of this system will prevent further northward migration of high-As
   water off-site.  Note that cutting off the mass flux at the PAT system does not imply
   that there will be a reduction in arsenic concentrations downgradient (see related
   points below).

5.  The PAT system may increase ORP in downgradient domains. It would remove low-
   ORP groundwater at the toe of the landfill, which is "replaced" from what is now
   "cross-gradient," and likely higher ORP. If these  effects are sustained as the water
   moves downgradient, arsenic mobility may be decreased in certain subdomains (i.e.,
   where ORP is >~100 mV).  Note that the influence of upgradient changes in ORP on
   downgradient conditions are not known at this time, given current characterization.
   See corresponding "risk" developed below.

6.  Doing something now (even though this is only an interim remedy) moves Army
   closer to the BRAC closure date of 2005, whereas  calling a halt to installation of an
   interim remedy at SHL in favor of further exploratory work will cause significant
   delays.

-------
Neutral (neither risk nor benefit):

1.  The origin of the high As plume within the landfill has not been established. Evidence
   confirming that downgradient high-arsenic groundwater is closely linked to the
   landfill is still needed. The presence of low-ORP, high-As groundwater at Molumco
   Road and West Main Street may be the result of northward-flowing groundwater
   from within and beneath the landfill, but may also be naturally-occurring in those
   areas, due to preexisting conditions.  Conditions favoring a natural origin for the
   elevated As in groundwater are known to be present (e.g., regional occurrence of high
   As in both bedrock minerals and in overburden hydrous ferric oxide (HFO) coatings,
   presence of peat deposits, low ORP, etc.).  Thus, installation of a PAT system at the
   toe of the landfill may have no effect on  groundwater to the north.

2.  There seems to be general agreement that the ROD is no longer strictly applicable
   because new information (specifically, the discovery of high-As water at Molumco
   Rd. and W. Main St.) has come to light since it was signed. Therefore, the ROD
   requirements for any remedies should be revisited.
Risks ("cons"):

1.  The costs of implementing a PAT system obviously should be weighed against the
   benefits of performing additional characterization, including development of a
   conceptual model consistent with data, that will help to identify the process(es)
   responsible for the observed arsenic distribution and concentrations, etc.  The benefit
   of the PAT system has not been established (i.e., will it have positive, negative, or
   even no effects on the downgradient areas?).

2.  Installation of the PAT system will perturb ambient conditions. Any subsequent
   investigative work to determine the processes controlling As mobilization (either in
   the subsurface or in Plow Shop Pond) may be compromised.  It will not be possible to
   characterize ambient groundwater conditions near the toe of the landfill once
   perturbations have been introduced by the PAT system.  Moreover, since any
   perturbations (e.g., of the flow field, pH, ORP, etc.) can be expected to propagate
   downstream, any sampling at points along flow lines to the north (such as Molumco
   Rd. and West Main Street) will have to be completed by the time the PAT effects
   arrive at those points.  Otherwise, results will be compromised and possibly of limited
   usefulness.  Note that the advective travel time from the toe of SHL to Molumco
   Road and West Main Street is estimated to be of the order of a few years, which is
   also the time scale over which the additional investigation is likely to take place.  In
   addition, note that the proposed PAT scheme, with extraction of groundwater at -SO-
   SO gpm and discharge to a treatment plant offsite, will alter the regional hydrology in
   an undetermined way. Discharge of groundwater from the direction of SHL to Plow
   Shop Pond will likely decrease, and recharge of groundwater from the northwest
   portion of Plow Shop Pond will likely increase. Also, the total flux of groundwater

-------
   northward from the toe of the landfill will likely decrease, resulting in a lower
   hydraulic gradient, lower groundwater velocity, and undetermined geochemical
   consequences (e.g., lower ORP?).

3. All stakeholders should bear in mind that this is not a VOC plume, with an
   identifiable upgradient "source." Therefore, "source control" may not be an
   applicable concept. While there clearly is a "source" of arsenic beneath SHL, there is
   also likely additional "source" throughout the plume domain.  The desire to cut off
   the flux of arsenic from the site is based, to some extent, on the more familiar
   experience with VOCs, where this action usually results in attenuation downgradient
   by "flushing," dilution by mixing, degradation, etc. Here, the distribution of arsenic
   in groundwater is controlled by complex hydrologic and geochemical processes that
   are not fully characterized or well understood at this time. It is entirely possible that
   the downgradient distribution of arsenic is relatively insensitive to upgradient
   conditions.  A delay of a few years before installing a remedy at the toe of the
   landfill may not make any difference in the areal extent of high-As groundwater (e.g.,
   it is possible that the system is well-buffered with respect to pH, ORP, etc.,  and As is
   ubiquitous).

4. Conducting the necessary investigation(s) before installing a remedy will optimize the
   selection and implementation of the appropriate technology for a long-term  solution .

5. The PAT system may exacerbate the arsenic problem along the flow  lines to the
   north. It has been noted previously that the extremely low ORP conditions (~ -300 to
   -400 mV and lower) and low arsenic concentrations (generally < -50 j-ig/L) observed
   in HLA's drivepoint sampling at Molumco Rd. are consistent with the formation of
   solid-phase sulfides. The PAT system may cause the downstream propagation of
   more oxygenated water, as water from the edges of the landfill "fill in" around the
   groundwater "hole" created by the extraction well.  If this higher-ORP water is in the
   range of about -150 to -200 mV by the time it reaches Molumco Rd., these sulfides
   will oxidize, thereby releasing additional arsenic, so the arsenic problem at least at
   that point may become considerably worse.  Depending on the extent to which PAT-
   initiated oxidation occurs, it is also possible that the ORP may rise, at some
   downgradient location, to the point where ferric iron precipitates and dissolved
   arsenic is again lowered (by sorption).

6. In the event that the PAT is discontinued after a some finite period of operation, and
   the zone now containing hydrous ferric oxides (HFO) and sorbed As returns to
   ambient conditions that are more reducing,  arsenic  will be liberated.  The installation
   and subsequent shutdown of a PAT system may induce arsenic remobilization and
   downgradient re-establishment of high-arsenic groundwater.  Both startup and
   shutdown of a PAT system may effect a number of transient shifts in dissolved
   arsenic concentrations (both increases and decreases) in different portions of the
   domain.  The current hydrogeochemical system includes domains that function as
   internal "sources" and "sinks" of arsenic, and any perturbation of the flow and
   controls on ORP may result in both spatial and temporal shifts of these domains.

-------
7.  No environmental receptors (e.g., ecological impacts due to accumulation of As in
   wetland sediment to the north) have been identified to date.  It is not known whether
   or not any active remediation will be indicated in the long term.

-------
       s6^
                  in
cxt*
                            /
                            r
                  contra
       f Mcts
                                          in

                                   "vfona

             (rnlttKr\i»wrh»i erf  rSP

               of
                       be.

-ooi((
 anevax    '
 clean U)  ltv€/s

-------
         RECORD OF DECISION
SHEPLEY'S HILL LANDFILL OPERABLE UNIT
  AREAS OF CONTAMINATION 4, 5, AND 18
    FORT DEVENS, MASSACHUSETTS
           SEPTEMBER 1995

-------
                          RECORD OF DECISION
                   SHEPLEY'S HILL LANDFILL OPERABLE UNIT
                        FORT DEVENS, MASSACHUSETTS

                           TABLE OF CONTENTS
Section	Title	Page No.

DECLARATION FOR THE RECORD OF DECISION  	  v

DECISION SUMMARY 	  1
      I.      SITE NAME, LOCATION, AND DESCRIPTION	  1
      II.      SITE HISTORY AND ENFORCEMENT ACTIVITIES	  4
             A.  Land Use and Response History	  4
             B.  Enforcement History	  4
      III.     COMMUNITY PARTICIPATION	  5
      IV.     SCOPE AND ROLE OF THE RESPONSE ACTION  	  7
      V.      SUMMARY OF SITE CHARACTERISTICS  	  8
             A.  Soils	  8
             B.  Groundwater	  8
             C.  Plow Shop Pond Surface Water	  10
             D.  Plow Shop Pond Sediments	  10
      VI.     SUMMARY OF SITE RISKS  	  11
      VII.    DEVELOPMENT AND SCREENING OF ALTERNATIVES	  15
             A.  Statutory Requirements/Response Objectives  	  15
             B.  Technology and Alternative Development and Screening	  16
      VIII.    DESCRIPTION OF ALTERNATIVES 	  17
             A.  Alternative SHL-1: No-Action	  18
             B.  Alternative SHL-2: Limited Action 	  18
             C.  Alternative SHL-5: Collection/Ion Exchange
                 Treatment/Surface Water Discharge	  19
             D.  Alternative SHL-9: Collection/Discharge to POTW	  20
             E.  Alternative SHL-10: Installation of RCRA Cap	  21
      IX.     SUMMARY OF THE COMPARATIVE ANALYSIS OF
             ALTERNATIVES	  22
             A.  Overall Protection of Human Health and the Environment ...  24
             B.  Compliance with Applicable or Relevant and Appropriate
                 Requirements	  25
             C.  Long-term Effectiveness and Permanence  	  27
             D.  Reduction of Toxicity, Mobility, and Volume through
                 Treatment	  27
             E.  Short-term Effectiveness  	  28
W0099518.080

-------
Section
                           RECORD OF DECISION
                   SHEPLEY'S HILL LANDFILL OPERABLE UNIT
                        FORT DEVENS, MASSACHUSETTS

                           TABLE OF CONTENTS
                                 (continued)
Title
Page No.
             F.  Implementability	   29
             G.  Cost	   29
             H.  State Acceptance	   30
             I. Community Acceptance	   31
      X.     THE SELECTED REMEDY	   31
             A.  Groundwater Cleanup Levels  	   31
             B.  Description of Remedial Components	   33
      XI.     STATUTORY DETERMINATIONS	   39
             A.  The Selected Remedy is Protective of Human Health and the
                 Environment	   40
             B.  The Selected Remedy Attains ARARs	   41
             C.  The Selected Remedial Action is Cost-Effective	   43
             D.  The Selected Remedy Utilizes Permanent Solutions and
                 Alternative  Treatment or Resource Recovery Technologies to
                 the Maximum Extent Practicable	   44
             E.  The Selected Remedy Does Not Satisfy the Preference for
                 Treatment Which Permanently and Significantly Reduces the
                 Toxicity,  Mobility, and Volume of Hazardous Substances as a
                 Principal Element	   46
      XII.    DOCUMENTATION OF NO SIGNIFICANT CHANGES	   47
      XIII.   STATE ROLE	   48
W0099518.080

-------
                        RECORD OF DECISION
                 SHEPLEY'S HILL LANDFILL OPERABLE UNIT
                     FORT DEVENS, MASSACHUSETTS

                        TABLE OF CONTENTS
                             (continued)
Section
Title
APPENDICES
APPENDIX A - FIGURES
APPENDIX B - TABLES
APPENDIX C - RESPONSIVENESS SUMMARY
APPENDIX D - ADMINISTRATIVE RECORD INDEX
APPENDIX E - DECLARATION OF STATE CONCURRENCE
APPENDIX F - GLOSSARY OF ACRONYMS AND ABBREVIATIONS
W0099518.080
                                 111

-------
DECLARATION FOR THE RECORD OF DECISION
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
W0099518.080
                                     iv

-------
                               DECLARATION FOR THE RECORD OF DECISION
                                             Shepley's Hill Landfill Operable Unit
                                                      Fort Devens, Massachusetts
               DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION

Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
STATEMENT OF PURPOSE AND BASIS

This decision document presents the U.S. Army's selected remedial action for the
Shepley's Hill Landfill Operable Unit, Fort Devens, Massachusetts. It was developed in
accordance with the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA) as amended, 42 USC §§ 9601 et seg. and the National
Oil and Hazardous Substances Pollution Contingency Plan (NCP) as amended, 40 CFR
Part 300, to the extent practicable.  The Fort Devens Base Realignment and Closure
(BRAC) Environmental Coordinator; the Installation Commander; the U.S. Army
Deputy Chief of Staff for Personnel and Installation  Management; and the Director of
the Waste Management Division, U.S. Environmental Protection Agency New England
have been delegated the authority to approve this Record of Decision.

This decision is based on the Administrative Record that has  been developed in
accordance with Section 113(k) of CERCLA.  The Administrative Record is available for
public review at the Fort  Devens BRAC Environmental Office, Building PI2, Fort
Devens, Massachusetts, and at the Ayer Town Hall, Main Street, Ayer, Massachusetts.
The Administrative Record Index (Appendix D of this Record of Decision) identifies
each of the items considered during selection of the remedial action.
ASSESSMENT OF THE SITE

Actual or potential releases of hazardous substances from the Shepley's Hill Landfill
Operable Unit, if not addressed by implementing the response action selected in this
Record of Decision, may present an imminent and substantial endangerment to the
public health, welfare, or the environment.
W0099518.080

-------
DECLARATION FOR THE RECORD OF DECISION
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
DESCRIPTION OF THE SELECTED REMEDY

This remedial action is a source control action that addresses long-term residential
exposure to contaminated groundwater, the principal known threat at the Shepley's Hill
Landfill Operable Unit. It consists of completing closure of Shepley's Hill Landfill in
accordance with applicable Massachusetts requirements at 310 CMR  19.000, and
monitoring and evaluating the effectiveness of the landfill cover system completed in
1993 at controlling groundwater contamination and site risk.  The remedy controls the
release of contaminants from wastes buried in Shepley's Hill Landfill and reduces the
potential risk of future residential exposure to contaminated  groundwater.  The major
components of the selected remedy include:

       •      landfill closure in accordance with applicable requirements of 310 CMR
             19.000;
       •      survey of Shepley's Hill Landfill;
       •      evaluation/improvement of stormwater diversion and drainage;
       •      landfill cover maintenance;
       •      landfill gas collection system maintenance;
       •      long-term groundwater monitoring;
       •      long-term landfill gas monitoring;
       •      institutional controls;
       •      educational programs;
       •      60 percent design of a groundwater extraction system;
       •      annual reporting to the Massachusetts Department of Environmental
             Protection and the U.S. Environmental Protection Agency; and
       •      five-year site reviews.

The selected remedy includes a contingency remedy if the selected remedy proves
ineffective at controlling site risk.  The contingency remedy is groundwater extraction
and discharge to the Town of Ayer publicly owned treatment works.
STATE CONCURRENCE

The Commonwealth of Massachusetts has concurred with the selected remedy.
Appendix E of this Record of Decision contains a copy of the declaration of
concurrence.
W0099518.080
                                        vi

-------
                                DECLARATION FOR THE RECORD OF DECISION
                                              Shepley's Hill Landfill Operable Unit
                                                        Fort Devens, Massachusetts
DECLARATION

The selected remedy is consistent with CERCLA, and to the extent practicable, the NCP,
is protective of human health and the environment, complies with federal and
Commonwealth requirements that are legally applicable or relevant and appropriate to
the remedial action, and is cost effective. The remedy utilizes permanent solutions and
alternative treatment technologies, to the maximum extent practicable for the Shepley's
Hill Landfill Operable Unit.  However, because treatment of the principal source of
contamination was found not to be practicable, this remedy  does not  satisfy the statutory
preference for treatment as a principal element.

The contingency remedy, if implemented, would also be consistent with CERCLA, and to
the extent practicable,  the NCP, be protective of human health and the environment,
comply with federal  and Commonwealth requirements that are legally applicable or
relevant and appropriate to the remedial action, and be cost effective.  The remedy
utilizes permanent solutions and alternative treatment technologies, to the maximum
extent practicable for the Shepley's Hill Landfill Operable Unit. The contingency
remedy, if implemented, would satisfy the statutory preference for treatment as a
principal element.

Because this remedy will result in hazardous substances remaining on site above health-
based levels, a review will be conducted within five years after commencement of
remedial action to ensure that the remedy continues to provide adequate protection of
human health and the  environment.
W0099518.080
                                       vii

-------
DECLARATION FOR THE RECORD OF DECISION
S hep ley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
W0099518.080
                                     viii

-------
DECLARATION FOR THE RECORD OF DECISION
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
The foregoing represents the selection of a remedial action by the U.S. Department of
the Army and the U. S. Environmental Protection Agency, with the concurrence of the
Commonwealth of Massachusetts Department of Environmental Protection.

Concur and recommend for immediate implementation:
U.S. DEPARTMENT OF/THE ARMY
   ics C. Chambers
  >rt Devens BRAC Environmental Coordinator
DaTe
W0099518.080
                                      IX

-------
DECLARATION FOR THE RECORD OF DECISION
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
The foregoing represents the selection of a remedial action by the U.S. Department of
the Army and the U. S. Environmental Protection Agency, with the concurrence of the
Commonwealth of Massachusetts Department of Environmental Protection.

Concur and recommend for immediate implementation:
U.S.
THE
ARM^  X1
                                                           /
Colonel Edward *R. Nuttall
Installation Commander, Fort D
                                      Date   /
        ens
W0099518.080

-------
DECLARATION FOR THE RECORD OF DECISION
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
The foregoing represents the selection of a remedial action by the U.S. Department of
the Army and the U. S. Environmental Protection Agency, with the concurrence of the
Commonwealth of Massachusetts Department of Environmental Protection.

Concur and recommend for immediate implementation:
U.S. DEPARTMENT OF THE ARMY
                                                      2%
ARTHUR T. DEAN                                  Date
Major General, USA
Deputy Chief of Staff for
 Personnel and Installation
 Management
W0099518.080
                                     XI

-------
DECLARATION FOR THE RECORD OF DECISION
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
The foregoing represents the selection of a remedial action by the U.S. Department of
the Army and the U. S. Environmental Protection Agency, with the concurrence of the
Commonwealth of Massachusetts Department of Environmental Protection.

Concur and recommend for immediate implementation:
 U.S. ENVIRONMENTAL PROTECTION AGENCY
-L/nda M. Murphy     /  /7                               /  Date
 Director, Waste Management Division
 U.S. Environmental Protection  Agency, New England
 W0099518.080
                                      xii

-------
                                                            DECISION SUMMARY
                                               Shepley's Hill Landfill Operable Unit
                                                        Fort Devens, Massachusetts
                              DECISION SUMMARY
I.     SITE NAME, LOCATION, AND DESCRIPTION

Fort Devens is a Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA) National Priorities List (NPL) site located in the Towns of Ayer and
Shirley (Middlesex County) and Harvard and Lancaster (Worcester County),
approximately 35 miles northwest of Boston, Massachusetts. The installation occupies
approximately 9,600 acres and is divided into the North Post, Main Post, and South Post
(Figure  1 in Appendix A).  Seventy-three Study Areas (SAs) and Areas of Contamination
(AOCs) have been identified  at Fort Devens.

This Record of Decision  addresses groundwater contamination at the Shepley's Hill
Landfill at Fort Devens.  The Shepley's Hill Landfill includes three AOCs: AOC 4, the
sanitary landfill incinerator; AOC 5, sanitary landfill No. 1  or Shepley's Hill Landfill; and
AOC 18, the asbestos cell.  AOCs 5 and 18 are located within the  capped area at
Shepley's Hill Landfill.  The three AOCs are collectively referred to as Shepley's Hill
Landfill.

Shepley's Hill Landfill encompasses approximately 84 acres in the northeast corner of
the Main Post at Fort Devens.  It is situated between the bedrock outcrop of Shepley's
Hill on the west and Plow Shop Pond on the east (Figure 2 in Appendix A). Nonacoicus
Brook, which drains Plow Shop  Pond, flows through a wooded wetland at the north end
of the landfill. The southern  end of the landfill borders the Defense Reutilization and
Marketing Office (DRMO) yard and a warehouse area.  An area east of the landfill and
south of Plow Shop Pond is the site of a former railroad roundhouse.

Review  of the surficial geology map of the Ayer Quadrangle shows that in the early
1940s, the active portion of the  landfill consisted of approximately 5 acres near the end
of Cook Street, near where monitoring well SHL-1 is located. The fill was elongated
north-south along a pre-existing small valley marked by at least  two swamps (probably
kettle holes) and lying between  the bedrock outcrop of Shepley's Hill to the west and a
flat-topped kame terrace  with an elevation of  approximately 250 feet to the east, next to
Plow Shop Pond.  During the landfilling operation, the valley was filled-in, and much of
the kame terrace, which may have been used as cover material, disappeared.
Background information indicates the landfill  once operated as  an  open burning site.
W0099518.080

-------
DECSION SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
Landfill operations at Shepley's Hill Landfill began at least as early as 1917, and stopped
as of July 1, 1992.  During its last few years of use, the landfill received about 6,500 tons
per year of household refuse and construction debris, and operated using the modified
trench method. There is evidence that trenches in the  northwest portion cut into
previously used areas containing glass and spent shell casings.  The glass dated from the
mid-nineteenth century to as late as the 1920s. The approximate elevation of the bottom
of the waste is estimated to  be 214 feet above sea level at the north end and in the
central portion of the landfill, and 230 feet above sea level in the southeast portion of
the landfill.  The maximum  depth of the refuse is about 30 feet.  The average thickness
of waste is not documented; however, if the average thickness were  10 feet, the landfill
volume would be over 1,300,000 cubic yards.  Reports of flammable fluid disposal in the
southeastern portion of the landfill have not been substantiated by observations in test
pits or other research. The  Army  has no evidence that hazardous wastes were disposed
of in the landfill after November 19, 1980.  No waste hot spots or hazardous waste
disposal areas were identified during remedial investigation (RI) or supplemental RI
activities.

In an effort to mitigate the potential for off-site contaminant migration, Fort Devens
initiated the Fort Devens Sanitary Landfill  Closure Plan in 1984 in accordance with
Massachusetts regulations entitled "The Disposal  of Solid Wastes by Sanitary Landfill"
(310 CMR 19.00, April 21, 1971).  The Massachusetts Department of Environmental
Protection (MADEP) approved the plan in 1985.  Closure plan approval was consistent
with 310 CMR 19.00 and contained the following requirements:

       •     grading the landfill surface to a minimum 2 percent slope in non-
             operational areas of the landfill and 3 percent in operational areas;

       •     removing waste from selected areas within  100 feet of the  100-year
             floodplain;

       •     installing a gas venting system;

       •     installing a low permeability cap and covering the cap with sand, gravel,
             and loam, and seeding to provide cover vegetation and prevent erosion;
             and
W0099518.080

-------
                                                           DECISION SUMMARY
                                               Shepley's Hill Landfill Operable Unit
                                                        Fort Devens, Massachusetts
      •      implementing a groundwater monitoring program based on sampling five
             existing monitoring wells every four months.

The capping was completed in four phases (see Figure 2 in Appendix A).  In Phase  I,
50 acres were capped in October 1986; in Phase II, 15 acres were capped in
November 1987; and in Phase III, 9.2 acres were capped in March 1989.  The Phase IV
closure of the last 10 acres was accomplished in two steps: Phase IV-A was closed in
1991, and Phase IV-B was closed as of July 1,  1992, although the geomembrane cap was
not installed over Phase IV-B until  May 1993.

Because of the large area and shallow surface  slope of the existing landfill, early phases
of the landfill closure were completed with a 2 or 3 percent surface slope.  Slopes were
increased to 5 percent in Phase IV-B.  Phases  I through IV-A were capped with a 30-mil
polyvinyl chloride (PVC) geomembrane overlain with a 12-inch drainage layer and 6-inch
topsoil layer. At the request of MADEP, the Phase IV-B cap design was modified to
include a 40-mil PVC geomembrane,  a 6-inch  drainage layer, and a 12-inch topsoil layer.
A landfill gas collection system consisting of 3-inch diameter gas-collection pipes bedded
in a minimum 6-inch thick gas-venting layer was installed beneath the PVC
geomembrane in all closure phases.  Gas vents were installed  through the PVC
geomembrane at 400-foot centers. A minimum 6-inch cushion/protection layer was
maintained between the geomembrane and underlying waste.  As requested by the U.S.
Environmental Protection Agency (USEPA) and MADEP, four additional groundwater
monitoring  wells were installed in 1986 to supplement the five in the original
groundwater  program.  The Army submitted a draft closure plan to MADEP on July 21,
1995 pursuant to 310 CMR 19.000 to  document that Shepley's Hill Landfill was closed in
accordance with plans  and applicable  MADEP requirements.  Closure in accordance
with applicable  requirements of Commonwealth regulations is a component of the
selected and contingent remedy.

AOC 4, the sanitary landfill incinerator was located in former Building 38 near the end
of Cook Street within the area included in Phase I of the sanitary landfill closure. The
incinerator was  constructed in 1941, burned household refuse, and operated until the late
1940s.  Ash from the incinerator was buried in the landfill. The incinerator was
demolished and buried in the landfill  in September 1967. The building foundation was
removed and buried on-site in 1976.
W0099518.080

-------
DECSION SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
AOC 18, the asbestos cell, is located in the section of the landfill closed during
Phase IV. Between March 1982 and November 1985, an estimated 6.6 tons of asbestos
construction debris were placed in the  section of the landfill closed during Phase IV-A.
In 1990, a new asbestos cell was opened in the section closed during Phase IV-B, and
was used until July 1992 for disposal of small volumes of asbestos-containing material.

A more complete description of the Shepley's Hill Landfill Operable Unit can be found
in the RI Addendum report, December 1993, Section 3, and the Feasibility Study (FS)
report, February 1995, Subsection  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 a 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 as a  unit
mobilization and demobilization site.  All or portions of this function occurred during
World Wars I and  II, the Korean and Vietnam conflicts, and operations Desert Shield
and Desert Storm.  During World War II, more than 614,000 inductees were processed
and Fort Devens reached a peak population of 65,000.

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

Fort Devens was selected for cessation of operations and closure under the Defense
BRAC Act of 1990 (Public Law 101-510).

A more complete description of the Shepley's Hill Landfill Operable Unit can be found
in the RI Addendum report, December 1993, Section 3, and the FS report, February
1995, Subsection 1.2.
W0099518.080

-------
                                                          DECISION SUMMARY
                                              Shepley's Hill Landfill Operable Unit
                                                       Fort Devens, Massachusetts
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 assessed the environmental status of SAs, discussed necessary investigations,
and recommended potential responses to environmental contamination.  Priorities for
environmental restoration at Fort Devens were also assigned.  The MEP identified
Shepley's Hill Landfill as a source of groundwater contamination and recommended
additional groundwater sampling and a full RI to determine the extent of contamination.

On December 21, 1989, Fort Devens was placed on the NPL under CERCLA as
amended by the Superfund Amendments and Reauthorization Act (SARA) as a result of
volatile organic compound (VOC) contamination in groundwater at Shepley's Hill
Landfill, metal contamination in groundwater at  the Cold Spring Brook Landfill (AOC
40), and the proximity of both locations to public drinking water supplies.  A  Federal
Facilities Agreement (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.

In 1991, the  U.S. Department of Defense, through USAEC, initiated an RI for the
Group 1A sites (AOCs 4,  5, 18, and 40) at Fort Devens. The RI report was issued in
April 1993, and an RI Addendum report was issued in December 1993.  The  purpose of
the RI and RI Addendum was to determine the nature and extent of contamination at
the AOCs, assess human health and ecological risks, and provide a basis for conducting
an FS.

An FS that evaluates  remedial action alternatives for cleanup of groundwater at
Shepley's Hill Landfill was issued in February 1995. The FS identifies and screens 10
remedial alternatives  and provides a detailed analysis of five of these remedial
alternatives to allow decision-makers to select a remedy for cleanup of groundwater at
the Shepley's Hill Landfill Operable Unit.

The proposed plan detailing the  Army's preferred remedial alternative was issued in May
1995 for public comment.  Technical comments presented during the public comment
period are included in the Administrative Record. Appendix C, the Responsiveness
W0099518.080

-------
DECSION SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
Summary, contains a summary of these comments and the Army's responses, and
describes how these comments affected the remedy selection.
III.   COMMUNITY PARTICIPATION

The Army has held regular and frequent informational meetings, issued fact sheets and
press releases, and held public meetings to keep the community and other interested
parties informed of activities at Shepley's Hill Landfill.

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

The Army, as part of its commitment to involve the affected communities, forms a RAB
when an  installation closure involves transfer of property to the community.  The Fort
Devens RAB was formed in February 1994 to add members of the Citizen's Advisory
Committee (CAC) to the TRC. The CAC had been established previously to address
Massachusetts Environmental Policy  Act/Environmental Assessment issues concerning
the reuse of property at Fort Devens. The RAB 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
requirements and priorities; and conducting regular meetings that are open to the public.
The Army presented  the proposed plan for the Shepley's Hill Landfill Operable Unit at
the May  4, 1995 RAB meeting.
W0099518.080

-------
                                                           DECISION SUMMARY
                                               Shepley's Hill Landfill Operable Unit
                                                        Fort Devens, Massachusetts
On May 31, 1995, the Army issued a fact sheet to citizens and organizations, to provide
the public with a brief explanation of the Army's preferred remedy for cleanup of
groundwater at the Shepley's Hill Landfill Operable Unit.  The fact sheet also described
the opportunities for public participation and provided details on the upcoming public
comment period and public meetings.

During the week of May 22, 1995, the Army published a public notice announcing the
proposed plan, public informational meeting, and public hearing in the Times Free Press
and the Lowell Sun. A public notice announcing the public hearing was published the
week of June 12, 1995 in the Times Free Press and the week of June  19, 1995 in the
Lowell Sun. The Army also made the proposed  plan available to the  public at the
information repositories at the libraries in Ayer,  Shirley, Lancaster, and Harvard, and at
Fort Devens.

From June 1 to June 30, 1995, 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 6, 1995, the Army held an informal
informational meeting at Fort Devens to present the Army's proposed plan to the public
and discuss the cleanup alternatives evaluated in the FS. This meeting also provided the
opportunity for open discussion concerning the proposed cleanup.  On June 27, 1995, the
Army held an informal public hearing at Fort Devens to discuss the proposed plan and
to accept verbal or written comments from the public. A transcript of this meeting,
public 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 Shepley's Hill Landfill
Operable Unit is contained in the Administrative Record for review.  The Administrative
Record is  a collection  of all the documents considered by the Army in choosing the
remedy for the Shepley's Hill Landfill Operable Unit.  On June 2, 1995, the Army made
the Administrative  Record available for public review at the Fort Devens BRAC
Environmental Office, and at the Ayer Town Hall, Ayer, Massachusetts.  An index to the
Administrative Record is available at the USEPA Records Center, 90 Canal Street,
Boston, Massachusetts and is provided as Appendix D.
W0099518.080

-------
DECSION SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
IV.    SCOPE AND ROLE OF THE RESPONSE ACTION

The Army developed the selected remedy by combining components of different source
control and management of migration alternatives. The selected remedy for the
Shepley's Hill Landfill Operable Unit controls  the release of contaminants to
groundwater and controls potential groundwater use.  The selected remedy also provides
environmental monitoring of groundwater for a period of thirty years. The
implementation of the selected alternative will not adversely affect any future response
actions at the Shepley's Hill Landfill Operable Unit should they be required.

This remedial action will address the principal  threat to human health at the Shepley's
Hill Landfill Operable Unit posed by long-term residential exposure to contaminated
groundwater. Potential threats to human and ecological receptors resulting from
exposure to contaminated sediments and surface water in Plow Shop Pond will be
addressed as part of the Plow Shop Pond Operable Unit.  Potential remedial actions for
Plow Shop Pond sediment contamination will be evaluated in a separate engineering
report anticipated to be issued September 1, 1996. Environmental monitoring to assess
any continuing affect of the landfill  on the pond will take place as part of the Plow Shop
Pond Operable Unit.
V.    SUMMARY OF SITE CHARACTERISTICS

Section  1 of the FS report contains an overview of RI and supplemental RI investigations
at Shepley's Hill Landfill.  A complete discussion of site characteristics can be found in
Sections 3,  5, and 6 of the RI report, April 1993, and Sections 3, 4, and 5 of the RI
Addendum report, December 1993. Significant findings of the RI and  supplemental RI
are summarized in the following subsections.
A.    Soils

The RI at Shepley's Hill Landfill included collecting three surface soil samples from
suspected seep areas and analyzing them for Target Compound List (TCL) organic
compounds,  Target Analyte List (TAL) metals, and total organic  carbon (TOC). Low
concentrations of acetone and methylene chloride were reported  in the samples;
however, they were attributed to laboratory contamination.  No other organics were
W0099518.080

-------
                                                           DECISION SUMMARY
                                               Shepley's Hill Landfill Operable Unit
                                                        Fort Devens, Massachusetts
detected.  Concentrations of TAL metals were within the estimated background range,
except for calcium, which was elevated slightly.  This was not considered significant.
Because soil contamination was not identified during the RI, soils were not sampled
during the supplemental RI.
B.    Groundwater

Assessment of groundwater quality included two rounds of sampling at 22 monitoring
wells during the RI, and one confirming round of sampling at 27 monitoring wells plus a
second round at five monitoring wells during the supplemental RI.  Target analyte
groups for the RI and supplemental RI field programs included  VOCs, semivolatile
organic compounds (SVOCs), pesticides, polychlorinated biphenyls (PCBs), explosives,
and inorganics.

The RI report concluded that groundwater downgradient of the  landfill was
contaminated with VOCs and inorganics as well as low concentrations of explosives,
pesticides, and PCBs in scattered monitoring wells.  The presence of pesticides was not
certain, however, because of apparent laboratory contamination  of several method
blanks. The PCB Aroclor-1260 was reported at a low concentration in only one of
22 samples in one sampling round.  The SVOC di-ethylphthalate was reported at  12 and
32 parts per billion (ppb) in samples from two separate monitoring wells, and was
considered a sampling artifact.

The RI Addendum report also concluded that  downgradient monitoring wells were
contaminated with several VOCs and inorganics.  A total of nine VOCs was reported at
low concentrations in seven of the monitoring wells.  Organic compounds were reported
most frequently and at the highest concentrations in the downgradient monitoring wells
SHL-11, SHL-19, SHL-20, and SHM-93-10C along the eastern edge of the landfill. In
two instances,  concentrations exceeded federal Maximum Contaminant Levels (MCLs) or
Massachusetts Maximum Contaminant Levels (MMCLs) for drinking water: total
dichlorobenzenes were reported at 11 ppb (the MMCL for 1,4-dichlorobenzene =  5 ppb)
in monitoring well SHL-20,  and  the VOC  1,2-dichloroethane was reported at 9.9 ppb
(MCL =  5 ppb) in monitoring well SHM-93-10C.

Inorganics were also reported at their highest concentrations in  downgradient monitoring
wells, especially SHL-10, SHL-11, SHL-19, SHL-20, and SHM-93-22C.  Unfiltered
W0099518.080

-------
DECSION SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
groundwater samples from downgradient monitoring wells typically exceeded background
concentrations for arsenic, calcium, iron, magnesium, manganese, and potassium.  In
addition, there were scattered exceedances of background concentrations for barium,
lead, vanadium, and zinc.  The concentrations of arsenic ranged from 69 to 390 ppb
(MCL = 50 ppb) in unfiltered samples from these monitoring wells. A significant
portion of the total concentration of the inorganics was often associated with suspended
material in the samples.  An exception to this was the presence of dissolved arsenic in
monitoring wells SHL-11, SHL-19, and SHL-20, all of which had high concentrations of
arsenic in both filtered and unfiltered samples.  Low oxidation potential in the samples
with high dissolved arsenic concentrations was consistent with expected conditions
downgradient of the landfill.

No pesticides or PCBs were reported in the supplemental RI groundwater samples. This
led the RI Addendum report to reinterpret groundwater data presented in the RI report.
Although pesticides were reported at low concentrations in several RI  samples, no
monitoring well had pesticides detected in both RI sampling  rounds. In addition, the RI
report states that several pesticides including heptachlor, endrin, alpha- and
beta-benzenehexachloride, 2,2-bis(para-chlorophenyl)-l,l,l-trichloroethane (DDT), and
endosulfan sulfate were detected in method blank samples, and that low concentrations
of those compounds should be considered laboratory contamination. The RI report also
noted difficulties with the pesticide and PCB analyses.  These considerations and  the
supplemental RI data support the conclusion that the landfill is not a source of pesticides
or PCBs in groundwater.

Supplemental RI data included the reported presence of the  explosive nitroglycerine in
one monitoring well, the water table  monitoring well SHM-93-24A, at  80.8 ppb.  This
monitoring well is considered cross-gradient of the  landfill and the source of the
nitroglycerine is not known.  The landfill is not considered a source of nitroglycerine.
Although the explosives 1,3,5-trinitrobenzene, 1,3-dinitrobenzene and tetryl were
reported inconsistently and at low concentrations in RI samples, they were not detected
in the  supplemental RI samples.  SVOCs were not identified as groundwater
contaminants in the RI report or targeted as analytes during  the supplemental RI field
program.  They are not considered groundwater contaminants at Shepley's Hill Landfill.
C.     Plow Shop Pond Surface Water
W0099518.080
                                         10

-------
                                                            DECISION SUMMARY
                                               Shepley's Hill Landfill Operable Unit
                                                        Fort Devens, Massachusetts
During the RI, samples were collected from 13 locations along the Plow Shop Pond
shoreline to characterize surface water quality.  Target analytes included TCL organics
and TAL metals.  The VOCs chloroform and methylene chloride were reported in
several samples, and the pesticide endrin was reported at a low concentration in one
sample. Methylene chloride was  considered a laboratory contaminant and the detection
of endrin was not considered significant in the RI report. The presence of chloroform,
considered an improbable surface water contaminant in the RI report, could  not be
explained.  The inorganics copper, silver, and zinc exceeded Ambient Water Quality
Criteria (AWQC) for the protection of aquatic  life throughout the pond, and iron and
zinc exceeded AWQC in the wetlands area north of the pond.
D.    Plow Shop Pond Sediments

Plow Shop Pond is believed to have been a historical discharge area for groundwater
passing beneath Shepley's Hill Landfill and to have received contamination from the
landfill.  Areas of iron staining have been observed in Plow Shop Pond adjacent to the
landfill.  The  characterization of Plow Shop Pond sediments was accomplished during
both the RI and supplemental RI.  The RI report concluded that pond sediments were
contaminated with high concentrations of TAL metals and low concentrations of several
polynuclear aromatic hydrocarbons. The VOCs acetone, methylene chloride, and
2-butanone were reported in several samples, as were low concentrations of 2,2-bis(para-
chlorophenyl)-l,l-dichloroethene  (DDE) and heptachlor.  The presence of acetone,
methylene chloride, and heptachlor is attributed to laboratory contamination.

Additional sediment samples were collected  during the supplemental RI.  The RI
Addendum report concluded that sediments  were contaminated with arsenic, barium,
copper, chromium, iron, lead, manganese, mercury, nickel, and zinc. Based  on available
data, manufacturing process chemicals, waste disposal practices, and chemical
distribution patterns in Plow Shop and Grove ponds, the RI Addendum report identified
a former tannery located on Grove Pond as the major source of arsenic, chromium, lead,
and mercury.  Shepley's Hill  Landfill was  identified as a primary source of barium, iron,
manganese, and nickel and a secondary source of arsenic, chromium, and  lead.  Data
available at the time of the RI Addendum report were insufficient to define the source
of copper.  Subsequently available data from the Grove Pond and Railroad  Roundhouse
investigations suggest that activities at the tannery may have been a source of barium
and copper and activities at the roundhouse  may have been a source of copper and lead.
W0099518.080
                                        11

-------
DECSION SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
The supplemental RI sampling confirmed the presence of 2,2-bis(para-chlorophenyl)-
1,1-dichloroethane (ODD), DDE, and DDT at low concentrations in Plow Shop Pond
sediments.  Several chemicals exceeded sediment quality guidelines.  The RI Addendum
report did not identify the landfill as a source of the pesticides.
VI.   SUMMARY OF SITE RISKS

The risk assessment contained in the RI Addendum report evaluates the probability and
magnitude of potential human health and environmental effects associated with exposure
to contaminated media at the site and updates the risk assessment of the RI report.  The
human health risk assessment followed a four step process: (1) contaminant
identification, which identified those hazardous substances that, given the specifics of the
site, were  of significant concern; (2) exposure assessment, which identified  actual or
potential exposure pathways, characterized the potentially exposed populations, and
determined the extent of possible exposure; (3) toxicity assessment, which considered the
types and  magnitude of adverse health effects associated with exposure to hazardous
substances, and (4) risk characterization, which integrated the three earlier steps to
summarize the potential and actual risks posed by hazardous substances at the site,
including carcinogenic and non-carcinogenic risks. A detailed discussion of the human
health risk assessment approach and results is presented in Section 6 of the RI
Addendum report and summarized in Subsection 1.4 of the FS report.

Forty contaminants of potential concern, listed in Tables 1 through 7 in Appendix B of
this Record of Decision were selected for evaluation in the human health risk assessment
of the RI  Addendum report. These 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 assessment detailed in
Section  6  of the RI Addendum Report and associated appendices.

Potential human health effects associated with exposure to the contaminants of concern
were estimated quantitatively or qualitatively through the development of several
hypothetical exposure pathways. 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 site.  The following is a brief summary of the exposure pathways
W0099518.080
                                         12

-------
                                                             DECISION SUMMARY
                                                Shepley's Hill Landfill Operable Unit
                                                         Fort Devens, Massachusetts
evaluated; a more thorough description can be found in Subsection 6.1.2.2 of the risk
assessment:

      •      incidental ingestion of Plow Shop Pond surface water, and long-term
             consumption of Plow Shop  Pond fish by recreational fishermen and their
             families;

      •      contact (dermal contact and incidental ingestion) with Plow Shop Pond
             sediment by site visitors;

      •      contact (dermal contact and incidental ingestion) with surface water by
             swimmers in Plow Shop Pond; and

      •      future residential  use of groundwater (there is no current identified use).

Because the RI report  did not identify human health or ecological risks for soils
exceeding the target risk values, soils were not re-evaluated in the RI Addendum report.

Excess lifetime cancer  risks were determined for each exposure pathway by multiplying
the exposure level with the chemical-specific cancer slope factor. Cancer slope factors
have been developed by USEPA from epidemiological or animal studies to reflect a
conservative "upper bound" of the risk posed by potentially carcinogenic compounds.
That is, the true risk is unlikely to be greater than the risk predicted.  The resulting risk
estimates are expressed in scientific notation as a probability (e.g. IxlO"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 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.

The hazard index was also calculated for each pathway as  a 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.  RfDs  have been developed by USEPA to
protect sensitive individuals over the course of a lifetime and they reflect a daily
exposure level that is likely to be without an appreciable risk of an adverse health effect.
RfDs are derived from epidemiological or animal studies and incorporate uncertainty
W0099518.080
                                         13

-------
DECSION SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
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).

The human health risk assessment of the RI Addendum report identifies the following
potential human health risks:

       •      Future residential use of unfiltered groundwater interpreted to be under
             the  influence of the landfill and contaminated with several inorganics
             (arsenic, manganese, chromium, lead, nickel, and sodium) and
             1,2-dichloroethane and dichlorobenzenes was estimated to present potential
             cancer risks of 4x10"* to 8xlO"3.  Most of the risk was due to the presence of
             arsenic.   If a downward modifying factor of 10  is applied to this estimate to
             account  for the uncertainty associated with arsenic risks, the modified risk
             estimate is 4x10~5 to SxlO"4, still within or exceeding the Superfund target
             risk range.  Manganese presented average and  maximum noncancer HI
             values of 12 to 55.

             It should be noted that when present at the federal MCL for drinking
             water, arsenic presents an estimated cancer risk of IxlO"3, which exceeds
             the  target risk range, and an HI of 5.

       •      Long-term consumption of fish from Plow Shop Pond presented cancer
             risks that ranged from 3x10~6 to 4X10"4, within or exceeding the Superfund
             target risk range.  Arsenic accounted for approximately 96  to 99 percent of
             the  risk, while DDE  contributed approximately 4 to 0.4 percent.   Mercury
             presented noncancer risks that exceeded the target value of 1  (His  ranged
             from  2 to 7).  If a downward modifying factor of 10 is  applied to  the cancer
             risk estimate to account for the uncertainty associated  with arsenic  risks,
             the  modified risk estimate is 3xl07 to 4x10~5, which is within or below the
             Superfund target risk range. Thus it appears that the major human health
             risk associated with  Plow Shop Pond fish  is due to mercury contamination.
W0099518.080
                                         14

-------
                                                             DECISION SUMMARY
                                                Shepley's Hill Landfill Operable Unit
                                                         Fort Devens, Massachusetts
       •      Long-term contact with Plow Shop Pond sediment presented cancer risks of
             2x10~5 to 2x10"* and 9x10~5 to 6x10^ under current and future exposure
             scenarios, respectively.  Only under the maximum exposure assumptions did
             the estimates exceed the target risk range. Arsenic was responsible for
             essentially 100 percent of the risk.  If a downward modifying factor of  10 is
             applied  to the cancer risk estimate to account for the uncertainty
             associated with arsenic risks, the modified risk estimates are 2x10~6 to 2xH)5
             (current exposure scenario) and 9xlO~6 to 6xlO~5 (future exposure scenario),
             which are within or below the  Superfund target risk range.

The ecological risk assessment evaluates risks to aquatic and semi-aquatic receptors  from
exposure to Plow Shop Pond surface water and sediments.  Because the RI report did
not identify ecological risks for soils exceeding the target risk values, soils were  not re-
evaluated in the RI Addendum report. Exposure of ecological receptors to groundwater
was not evaluated  because this was not considered a likely or significant exposure
pathway.

The ecological risk assessment predicted, based on comparison to reference criteria, that
Plow Shop Pond surface water and sediments present potential adverse risks to  aquatic
receptors.  Average and maximum HI values for aquatic receptor exposure to surface
water were 7.7 and 12.8, respectively.  Primary contributors to potential risk were copper,
silver, and zinc.  For aquatic receptor  exposure to sediments, average and  maximum HI
values were 182 and 1,300, respectively. Primary contributors to  estimated risk  were
arsenic, chromium, manganese, and mercury. Other data, including fish and
macroinvertebrate  community studies, suggest that adverse effects may  be  less severe
than predicted by the risk assessment.

For semi-aquatic wildlife,  in both the average and maximum exposure scenarios, His
were greater than  1 for five of the  eight receptor species evaluated, including the mallard
duck, painted turtle, green frog,  mink, and muskrat. For the great blue heron, the HI for
the maximum exposure scenario but not the  average exposure scenario exceeded 1.  His
for the osprey and raccoon were well below  1.  Sediments were predicted most  likely to
present potential risks to species with  small home ranges and direct contact with
sediment, such as the green frog or painted turtle.  Primary contributors to predicted risk
were arsenic, chromium, manganese, and mercury.
W0099518.080
                                         15

-------
DECSION SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
A detailed discussion of the ecological risk assessment approach and results is presented
in Section 7 of the RI Addendum report and summarized in Subsection 1.5 of the FS
report.

Actual or potential releases of hazardous substances to groundwater from Shepley's Hill
Landfill,  if not addressed  by implementing the response action selected in this Record of
Decision, may present an imminent and substantial  endangerment to public health,
welfare, and the environment.
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 requirements and
preferences, including: a requirement that the  remedial action, when complete, must
comply with all federal and more stringent state environmental standards, requirements,
criteria, or  limitations, unless a waiver is invoked; a requirement  that a remedial action
be cost-effective and use permanent solutions  and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable; and a  preference for
remedies in which  treatment permanently and significantly reduces the toxicity, mobility,
or volume of hazardous substances as a principal element.  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 response objectives were
developed to aid in the development and screening of alternatives.  These remedial
response objectives were developed to mitigate existing and future potential threats to
public health and the environment.  The response objectives are:

      •      Protect potential residential receptors from exposure to contaminated
             groundwater migrating from the  landfill having chemicals in excess of
             MCLs.
W0099518.080
                                        16

-------
                                                            DECISION SUMMARY
                                                Shepley's Hill Landfill Operable Unit
                                                         Fort Devens, Massachusetts
      •      Prevent contaminated groundwater from contributing to the contamination
             of Plow Shop Pond sediments in excess of human health and ecological
             risk-based concentrations.

Response objectives were not identified for surface soil, landfill gas, or leachate.  The
risk assessments did not identify potential risks from exposure to surface soil, and
ambient air monitoring during the RI did not identify airborne contaminants.  Liquid
leachate was  not identified  during either RI or supplemental RI activities. Additional
actions to manage risk from exposure to Plow Shop Pond surface water and sediment
will be evaluated  separately for the Plow Shop Pond Operable Unit.
B.    Technology and Alternative Development and Screening

CERCLA and the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP) set forth the process by which remedial actions are evaluated and selected. In
accordance with these requirements, a range of alternatives was  developed for the
Shepley's Hill Landfill Operable Unit.  The NCP reaffirms CERCLA's preference for
permanent solutions that use treatment technologies to reduce the toxicity, mobility, and
volume of hazardous substances to the maximum extent practical.  With respect to
source control, the in-situ treatment, or alternately the excavation and treatment,  of such
a large, heterogeneous landfill as Shepley's Hill  Landfill is  considered impractical and
not cost effective.  Therefore, the FS for the Shepley's Hill Landfill Operable Unit
developed a range of alternatives in which containment of wastes was the principal
element.  This approach is consistent with guidance contained in the USEPA document
Conducting Remedial Investigations/Feasibility Studies for CERCLA Municipal Landfill
Sites, which states that the most practical  remedial alternative for landfills is generally
containment by capping.  All of the alternatives  (including  the no action alternative)
considered in the  FS included containment of landfill waste by the existing cover  system.
One alternative was based on installing a Resource Conservation and Recovery Act
(RCRA)  composite cover system on top of the existing geomembrane cover system.

With respect to groundwater,  the FS developed several remedial alternatives that attain
site-specific cleanup levels using different technologies and a no action alternative.
Three candidate alternatives included slurry wall containment of groundwater, two
included  in-situ treatment of groundwater, five included groundwater extraction and on-
site treatment, and one included groundwater extraction and  discharge to  the local
W0099518.080
                                         17

-------
DECSION SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
publicly owned treatment works (POTW). Except for the no action alternative, all the
alternatives also included institutional controls, long-term maintenance, and
environmental monitoring programs.

Section 3 of the FS identified, assessed, and screened technologies and process options
based on implementability, effectiveness,  and cost.  In Section 4 of the FS, these
technologies and process options were combined into the ten candidate alternatives listed
below.

       Alternative SHL-1: No Action
       Alternative SHL-2: Limited Action
       Alternative SHL-3: Containment/Collection/Short-term Ex Situ
             Treatment/Surface Water Discharge
       Alternative SHL-4: Containment/In Situ Treatment
       Alternative SHL-5: Collection/Ion Exchange Treatment/Surface Water Discharge
             Alternative SHL-6: Collection/Chemical Precipitation Treatment/Surface
             Water Discharge
       Alternative SHL-7: Collection/Constructed Wetland Treatment/Surface Water
             Discharge
       Alternative SHL-8: Groundwater Barrier/In Situ Oxidation
       Alternative SHL-9: Collection/Discharge to POTW
       Alternative SHL-10: Installation of RCRA Cap

Each alternative was then evaluated and  screened in  Section 4 of the FS based on
implementability, effectiveness, and cost,  as described in Section 300.430(e)(4) of the
NCP, to narrow the number of potential  remedial alternatives for detailed analysis.
From this screening process, five remedial alternatives were retained  for detailed
analysis.
VIII.   DESCRIPTION OF ALTERNATIVES

Of the 10 alternatives identified in the FS, five were discarded during the FS screening
step, and the remaining five were evaluated  in detail.  A detailed assessment of each
alternative can be found in Section 5 of the  FS report.  This section provides a narrative
summary of each of the following five alternatives evaluated in detail in the FS:
W0099518.080
                                         18

-------
                                                            DECISION SUMMARY
                                                Shepley's Hill Landfill Operable Unit
                                                         Fort Devens, Massachusetts
      Alternative SHL-1: No Action
      Alternative SHL-2: Limited Action
      Alternative SHL-5: Collection/Ion Exchange Treatment/Surface Water Discharge
      Alternative SHL-9: Collection/Discharge to POTW
      Alternative SHL-10: Installation of RCRA Cap
A.    Alternative SHL-1: No-Action

The No Action alternative does not contain any remedial action components beyond the
existing landfill cover system to reduce or control potential risks. No institutional
controls would be implemented to prevent future human exposure, and existing activities
to maintain existing systems and monitor for potential future releases would be stopped.
Alternative SHL-1 is developed to provide a baseline for comparison with the other
remedial alternatives.

      Estimated Time for Restoration: not applicable
      Estimated Capital Cost:                             $0
      Estimated Operation and Maintenance Cost:
             (net present worth)                           $0
      Estimated Total Cost: (net present worth,
             assuming 5% discount rate)                   $0
B.    Alternative SHL-2: Limited Action

Alternative SHL-2 contains components to maintain and potentially improve the
effectiveness of the existing landfill cover system and to satisfy the Landfill Post-Closure
Requirements of 310 CMR 19.142 to reduce potential  future exposure to contaminated
groundwater.  Key components of this alternative include:

      •      landfill closure in accordance with applicable requirements of 310 CMR
             19.000;
      •      survey of Shepley's Hill Landfill;
      •      evaluation/improvement of stormwater diversion and drainage;
      •      landfill cover maintenance;
      •      landfill gas collection system maintenance;
W0099518.080
                                        19

-------
DECSION SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
      •      long-term groundwater monitoring;
      •      long-term landfill gas monitoring;
      •      institutional controls;
      •      educational programs;
      •      60 percent design of a groundwater extraction system;
      •      annual reporting to MADEP and USEPA; and
      •      five-year site reviews.

      Estimated Time for Restoration: Approximately  12 months for      engineering
      evaluations, design, and construction.
      Estimated Capital Cost:                             $  928,000
      Estimated Operation and Maintenance Cost:
             (net present worth)                           $1,291,000
      Estimated Total Cost:  (net present worth,
              assuming 5% discount rate)                  $2,219,000
C.    Alternative SHL-5: Collection/Ion Exchange Treatment/Surface Water Discharge

Alternative SHL-5 consists of components that, together with the components of
Alternative SHL-2, would provide additional controls to prevent off-site migration of
contaminated groundwater.  Key components of Alternative SHL-5 include:

      •      landfill closure in accordance with applicable requirements of 310 CMR
             19.000;
      •      design, construction, operation, and maintenance of groundwater
             extraction, treatment, and discharge facilities;
      •      survey of Shepley's Hill Landfill;
      •      evaluation/improvement of stormwater diversion and drainage;
      •      landfill cover maintenance;
      •      landfill gas collection system maintenance;
      •      long-term groundwater monitoring;
      •      long-term landfill gas monitoring;
      •      institutional controls;
      •      educational programs;
      •      annual reporting to MADEP and USEPA; and
      •      five-year site reviews.
W0099518.080
                                        20

-------
                                                             DECISION SUMMARY
                                                Shepley's Hill Landfill Operable Unit
                                                         Fort Devens, Massachusetts
The major difference between Alternative SHL-5 and Alternative SHL-2 is the
construction and operation of groundwater extraction, treatment, and discharge facilities.
Data collected during predesign studies would be used to optimize the size and location
of groundwater extraction wells at Shepley's Hill Landfill.  Contaminated groundwater
would be treated in an on-site groundwater treatment facility that (subject to treatability
studies) includes carbon adsorption, sand filtration, and ion exchange treatment units and
discharges through an effluent pipeline to Nonacoicus Brook.

      Estimated Time for Restoration: Approximately  18 months for predesign studies,
      design, and construction. Groundwater extraction and treatment assumed to
      continue for a minimum of 30-years.
      Estimated Capital Cost:                             $2,577,000
      Estimated Operation and Maintenance Cost:
             (net present worth)                           $6,549,000
      Estimated Total Costs: (net present worth,
             assuming 5% discount rate)                  $9,126,000
D.    Alternative SHL-9: Collection/Discharge to POTW

Alternative SHL-9 adds the components of groundwater extraction and discharge to the
Town of Ayer POTW to Alternative SHL-2 to provide additional control to prevent
off-site migration of contaminated groundwater.  Key components of Alternative SHL-9
include:

      •      landfill closure in accordance with applicable requirements of 310 CMR
             19.000;
      •      design, construction, operation, and maintenance of groundwater extraction
             and discharge facilities;
      •      survey of Shepley's Hill Landfill;
      •      evaluation/improvement of stormwater diversion and drainage;
      •      landfill cover maintenance;
      •      landfill gas collection system maintenance;
      •      long-term groundwater monitoring;
      •      long-term landfill gas monitoring;
      •      institutional  controls;
      •      educational programs;
W0099518.080
                                        21

-------
DECSION SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
      •      annual reporting to MADEP and USEPA; and
      •      five-year site reviews.

The major difference between Alternative SHL-9 and Alternative SHL-2 is the
construction and operation of groundwater extraction and discharge facilities.  Data
collected during predesign studies would be used to optimize the size and location of
groundwater extraction wells at Shepley's Hill Landfill. Following construction of the
groundwater extraction facilities,  contaminated groundwater would be pumped to a
discharge manhole anticipated to be located on Scully Road near the north end of the
landfill. There, the groundwater  would combine with domestic wastewater and flow  to
the Town of Ayer POTW for treatment and subsequent discharge.  The Ayer POTW,
with  a capacity of 1.79 million gallons per day (MGD), would be able to handle the
additional anticipated volume of  20 to 30 gallons per minute (0.029 to 0.043 MGD).

Review of available groundwater monitoring  data suggests that pretreatment of the
groundwater will not  be needed to meet existing pretreatment standards established  by
the Town of Ayer. The Army would monitor the groundwater discharge to the POTW,
however, and if necessary install pretreatment facilities to meet pretreatment standards.
The Army would pay a sewer user fee to the town based on the volume of water
discharged to the POTW.

      Estimated Time for Restoration:  Approximately 15 months for predesign studies,
design, and construction. Groundwater extraction and discharge  to POTW assumed  to
continue for a minimum of 30-years.
      Estimated Capital Cost:                            $1,184,000
      Estimated Operation and  Maintenance Cost:
             (net present worth)                          $2,690,000
      Estimated Total Cost:  (net present worth,
             assuming 5% discount rate)                  $3,874,000
E.    Alternative SHL-10: Installation of RCRA Cap

Alternative SHL-10 consists of building a new landfill cover system on top of the existing
cover system at Shepley's Hill Landfill. The new cover system would be designed to
meet RCRA performance criteria and design guidance for hazardous waste landfills.
The principal component of the new cover system would be a 24-inch layer of low
W0099518.080
                                        22

-------
                                                            DECISION SUMMARY
                                                Shepley's Hill Landfill Operable Unit
                                                         Fort Devens, Massachusetts
permeability soil in intimate contact with a geomembrane.  Maintenance activities,
monitoring and reporting requirements, and institutional controls would be similar to
those of Alternative SHL-2.

      Estimated Time for Restoration: Approximately three years required for design
      and construction.
      Estimated Capital Cost:                             $19,645,000
      Estimated Operation and Maintenance Cost:
             (net present worth)                           $ 1,291,000
      Estimated Total Cost: (net present worth,
             assuming 5% discount rate)                   $20,936,000
IX.   SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES

Section 121(b)(l) of CERCLA presents several factors that at a minimum the Army is
required 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. The nine criteria are used to select a remedy that
meets the  goals of protecting human health and the environment, maintaining protection
over time, and minimizing untreated waste.
A  detailed analysis was performed on the alternatives using the nine evaluation criteria
to  select a site remedy.  Specific discussion regarding  this analysis is provided in Section
5 of the FS report. Definitions of the nine criteria are provided below:

      Threshold Criteria

      The two threshold criteria described below must be met in order for an
      alternative to be eligible for selection in accordance with the NCP.

      •      Overall Protection of Human Health and the Environment - Assesses how
             well an alternative, as a whole, achieves and maintains protection of human
             health and the environment.

      •      Compliance with Applicable or Relevant and Appropriate Requirements
             (ARARs) - Assesses how the alternative complies with location-, chemical-,
             and action-specific ARARs, and whether a waiver is required or justified.
W(X)99518.080
                                        23

-------
DECSION SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
      Primary Balancing Criteria

      The following five criteria are used to compare and evaluate the elements of
      alternatives that meet the threshold criteria.

      •      Long-Term Effectiveness and Permanence - Evaluates the effectiveness of
             the alternative in protecting human health and the environment after
             response objectives have been met. This criterion includes consideration of
             the magnitude of residual risks and the adequacy and reliability of controls.

      •      Reduction of Toxicity. Mobility, and Volume Through Treatment -
             Evaluates the effectiveness of treatment processes used to reduce toxicity,
             mobility, and volume of hazardous substances. This criterion considers the
             degree to which  treatment is irreversible, and the type and  quantity of
             residuals remaining after treatment.

      •      Short-Term Effectiveness - Examines the effectiveness of the alternative in
             protecting human health and the environment during the construction and
             implementation of a remedy until response objectives have been met.
             Considers the protection of the community, workers, and the environment
             during implementation of remedial actions.

      •      Implementability - Assesses the technical and administrative feasibility of
             an alternative and availability of required goods  and services.  Technical
             feasibility considers the  ability to construct  and operate a technology and
             its reliability, the ease of undertaking additional  remedial actions, and the
             ability to monitor the effectiveness of a remedy.  Administrative feasibility
             considers the ability to obtain approvals from other parties or agencies and
             extent of required coordination with other parties or agencies.

      •      Cost - Evaluates the capital, and operation and maintenance costs of each
             alternative.

      Modifying Criteria
W0099518.080
                                         24

-------
                                                             DECISION SUMMARY
                                                Shepley's Hill Landfill Operable Unit
                                                         Fort Devens, Massachusetts
      The modifying criteria are used on the final evaluation of remedial alternatives
      generally after the Army has received public comments on the FS and proposed
      plan.

      •      State Acceptance - This criterion considers the state's preferences among
             or concerns about the alternatives, including comments on ARARs or the
             proposed use of waivers.

      •      Community Acceptance - This criterion considers the communities
             preferences among or concerns about the alternatives.

Following the detailed analysis of each individual  alternative, the Army conducted a
comparative analysis, focusing on the relative performance of each alternative against the
nine criteria. This comparative analysis of the five alternatives is presented in Table 6-1
of the FS report and summarized below.
A.    Overall Protection of Human Health and the Environment

This criterion 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
posed through each pathway are eliminated, reduced, or controlled through treatment,
engineering controls, or institutional controls. According to CERCLA, this  criterion
must be met for a remedial alternative to be chosen as a final site remedy.

At Shepley's Hill Landfill, the existing cover system isolates landfill materials from the
environment, blocks infiltration, and based on computer modeling, diverts groundwater
that would otherwise discharge to Plow Shop Pond. Historical groundwater monitoring
between the landfill and Plow Shop Pond has shown analyte concentrations in excess of
cleanup levels; however, no current residential exposure to groundwater has been
identified, and the existing  cap prevents infiltration of contaminants into groundwater
downgradient of the landfill.  Alternatives  SHL-1, SHL-2, SHL-5, and SHL-9, all of
which rely on the existing cover to isolate waste, prevent infiltration, and reduce
groundwater discharge to the pond, are considered equally protective of human health
under current exposure scenarios.  Alternative SHL-10,  which proposes to replace the
existing geomembrane cover with a composite cover, would not afford significantly
greater protection under current conditions.
W0099518.080
                                        25

-------
DECSION SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
Differences in protectiveness may exist under future exposure conditions. Alternative
SHL-1 proposes no action to prevent future residential exposure to groundwater or to
maintain and monitor the long-term performance of the existing cover. The remaining
alternatives all propose to implement zoning and deed restrictions to prevent future
residential exposure to groundwater and to maintain and monitor long-term cover
performance.  Once installed, the composite cover system proposed for Alternative
SHL-10 would be newer  and therefore potentially provide protection longer than the
existing cover.  However, its protectiveness at any given time would not be significantly
greater than the anticipated performance of the existing cover.  In addition, the five-year
site reviews proposed for all alternatives provide the opportunity to implement additional
remedial actions if they are needed.  The installation of a composite  cover system could
be considered in the future if the existing cover system does not perform as anticipated.
Alternatives SHL-5 and SHL-9, in addition to their reliance on the existing cover system,
propose to extract contaminated groundwater for subsequent treatment and discharge.
They therefore provide some redundancy or backup to achieve cleanup levels if the
existing cover system does not perform as  anticipated.

There is no ecological exposure to groundwater. Reductions in infiltration and  leaching
coupled with the diversion of groundwater that would otherwise discharge to Plow Shop
Pond will provide protection of the environment. The potential differences in
effectiveness  of the evaluated alternatives  at protecting the environment are similar to
the differences discussed for  future protection of human health.
B.     Compliance with Applicable or Relevant and Appropriate Requirements

This criterion addresses whether a remedy complies with all state and federal
environmental and public health laws and requirements that apply or are relevant and
appropriate to the conditions and cleanup options at a specific site. If an alternative
cannot meet an ARAR, the analysis of the alternative must provide the  rationale for
invoking a statutory waiver.

Location-specific ARARs identified for the Shepley's Hill Landfill Operable Unit include
regulations that protect wetlands, floodplains, and endangered species (i.e., the
Grasshopper Sparrow, a state listed species of special concern).  Alternatives SHL-1,
SHL-2, and SHL-9 would not involve any activities anticipated to trigger wetlands or
floodplain ARARs. Alternative SHL-5 would require construction of a discharge
W0099518.080
                                         26

-------
                                                            DECISION SUMMARY
                                               Shepley's Hill Landfill Operable Unit
                                                        Fort Devens, Massachusetts
pipeline to Nonacoicus Brook and may trigger wetland and floodplain ARARs.
Activities for all alternatives would be conducted or altered to comply with wetlands and
floodplain ARARs.  All of the alternatives would be subject to ARARs protecting
endangered species.  Activities performed for any of the alternatives would be planned to
prevent or  minimize adverse effects on the Grasshopper Sparrow and its habitat. In
spite of this, implementation of Alternative SHL-10 would result in destruction of any
nesting areas of the Grasshopper Sparrow that might exist at the landfill.

Alternatives SHL-1, SHL-2, and SHL-10 rely on cover system performance to comply
with chemical-specific ARARs and cleanup levels. Currently groundwater at the
northern end of the landfill meets cleanup levels, and landfill capping is expected to
reduce leaching of landfill materials and the resulting groundwater contamination,
thereby achieving cleanup levels along the  eastern edge of the landfill.  Alternatives
SHL-5 and SHL-9 would comply with chemical-specific ARARs and cleanup levels  with
a combination of  landfill capping and groundwater extraction.  Groundwater exceeding
cleanup levels would be extracted and treated or disposed of before exiting the site.

Several action-specific ARARs have been identified for the Shepley's Hill  Landfill
Operable Unit; the most important are the ones relating to landfill cover systems and
landfill closure. The Massachusetts Solid Waste Management Regulations at 310 CMR
19.000 have been  identified as applicable.  USEPA Regulations for Owners and
Operators of Permitted Hazardous Waste Facilities at 40 CFR 264 (RCRA Subtitle C),
and USEPA Criteria for Municipal Solid Waste  Landfills at 40 CFR 258 (RCRA Subtitle
D), and Massachusetts Hazardous Waste Management Rules at 310 CMR 30.000 have
all been identified as relevant and appropriate.

The design of the existing cover system at Shepley's Hill Landfill was approved by
MADEP in 1985 pursuant to the Massachusetts  Sanitary Landfill regulations of 1971
(310 CMR 19.00). Provisions in the Massachusetts Solid  Waste Management
Regulations of 1990 (310 CMR 19.000) indicate  that the conditions of the  1985 approval
satisfy 310  CMR 19.000; therefore the existing cover is considered to comply with the
applicable cover system requirements of 310 CMR 19.000.  In addition, the existing cover
meets the  general performance standards of 310 CMR 19.000. The existing cover system
also meets  the performance standards  of RCRA Subtitle C at 40 CFR 264.310, RCRA
Subtitle D  at 40 CFR 258, and Massachusetts Hazardous Waste Regulations at 310 CMR
30.000. The existing cover varies from USEPA guidance  for RCRA final covers
primarily in that it has a geomembrane hydraulic barrier rather than a composite
W0099518.080
                                        27

-------
DECSION SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
hydraulic barrier. Table 8 in Appendix B describes how the existing cover complies with
these performance standards. Alternatives SHL-1, SHL-2, SHL-5, and SHL-9, which rely
on the existing cover, will therefore comply with ARARs for cover systems.  The cover
system of Alternative SHL-10 would be designed to meet ARARs for cover systems as
well as RCRA design guidance.  The long-term monitoring and maintenance programs of
all alternatives except Alternative SHL-1 would be designed to comply with the
applicable requirements of 310 CMR 19.000.

Action-specific ARARs for landfill post-closure requirements would be met  by all of the
alternatives except Alternative SHL-1.  Alternative SHL-5 would be required to meet the
substantive requirements of a federal National Pollutant Discharge Elimination System
(NPDES) permit to discharge treated groundwater to Nonacoicus Brook.  These
alternatives would also be required to meet ARARs for disposal  of filter cake and resin
regeneration concentrate from groundwater treatment and to meet substantive
requirements of a U.S. Army Corps of Engineers permit, a MADEP license, and a
Massachusetts water quality certification to construct a discharge pipeline to Nonacoicus
Brook.  Alternative SHL-9 would be required to meet the federal Clean Water Act
General Pretreatment Requirements to discharge to the Town of Ayer POTW.  Federal
and state air quality regulations would be met by all the alternatives.  Dust  suppression
techniques would be used, when necessary, for Alternatives SHL-5, SHL-9, and SHL-10
intrusive activities to meet air quality regulations.
C.     Long-term Effectiveness and Permanence

This refers to the ability of an alternative to maintain reliable protection of human
health and the environment over time once the cleanup levels have been met.

Alternative SHL-1 provides no controls or treatment beyond the existing cover system to
protect human health and the environment.  Alternatives SHL-2 and SHL-10 rely on  the
effectiveness of a landfill cover system to achieve the remedial action objectives.  The
other alternatives use groundwater extraction and treatment in addition to the cover
system to achieve remedial action objectives. All of the alternatives except SHL-1
include landfill post-closure and long-term groundwater monitoring to evaluate their
long-term effectiveness. All the alternatives except  SHL-1 include institutional controls.
Institutional controls require cooperation by private parties and government agencies  to
be reliable and effective.
W0099518.080
                                         28

-------
                                                            DECISION SUMMARY
                                               Shepley's Hill Landfill Operable Unit
                                                        Fort Devens, Massachusetts
Alternatives SHL-5 and SHL-9 would use data obtained from the pre-design
hydrogeological investigation to design a groundwater extraction system. This would
allow design of an extraction system that is effective in capturing contaminated
groundwater. However, groundwater extraction would not prevent landfill waste and/or
its leachate from potentially contaminating the underlying aquifer; these alternatives rely
on the cover system as discussed earlier.
D.    Reduction of Toxicity, Mobility, and Volume through Treatment

This criterion is a principal measure 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 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.

Alternatives SHL-1, SHL-2, and SHL-10 do not meet the statutory preference for
treatment under CERCLA since these alternatives do not treat contaminants contained
in groundwater or wastes at the site.  Landfill capping which is a part of each of all the
alternatives will reduce infiltration and the resulting leaching of contaminants, thus
reducing contaminant mobility.

Alternatives SHL-5 and SHL-9 meet the CERCLA statutory preference for treatment.
These alternatives would reduce the mobility of contaminants by extracting the
groundwater for treatment or disposal.  The removal of contaminants from groundwater
in Alternative SHL-5 would generate concentrated waste streams  that would require
disposal. Alternative SHL-9 would discharge extracted groundwater to the Town of Ayer
POTW.   The POTW generates sludge from treating influent water which  would require
disposal.
E.    Short-term Effectiveness

This refers to the likelihood of adverse effects on human health or the environment that
may be posed during the construction and implementation of an alternative until cleanup
goals are achieved.
W(Kl99518.080
                                        29

-------
DECSION SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
Alternatives SHL-1 and SHL-2 would have the least likelihood for adverse effects during
implementation because no intrusive activities would be required.  Alternative SHL-1
would have the least effect during implementation because it would not involve
construction or operation. Alternatives SHL-5 and SHL-9 involve installation of
extraction wells and underground piping. A Health and Safety Plan would be followed
during performance of these activities and during environmental monitoring to minimize
the risk of site hazards to workers.  Alternative SHL-5 would require transportation of
treatment residuals and adherence to RCRA and U.S. Department of Transportation
regulations to minimize potential risks to workers.

Site activities would be performed to minimize effects on the Grasshopper Sparrow and
its habitat. Maintenance schedules for Alternatives SHL-2, SHL-5, and SHL-9 would be
prepared to limit activities during the nesting season.  Construction schedules for
Alternatives SHL-5 and SHL-9 would be prepared to limit activities during nesting
season to  avoid direct effects on the bird. Alternative SHL-10 would destroy any  nesting
areas of the Grasshopper Sparrow that might exist at the landfill.
F.     Implementability

Implementability refers to the technical and administrative feasibility of an alternative,
including the ease of construction and operation; administrative feasibility; and
availability of services, equipment, and materials to construct and operate the technology.
Also evaluated is the ease of undertaking additional remedial actions.

Post-closure requirements included in all of the alternatives present no implementation
problems.  Equipment and services required for  monitoring and maintenance are readily
available.  Zoning and deed restriction (i.e., institutional controls) included in all
alternatives, except SHL-1, could be easily implemented by the Army.  Enforcement by
the Town  of Ayer would be required.

Groundwater extraction systems used in Alternatives SHL-5  and SHL-9 would be easily
designed and constructed.  Many engineering companies are qualified to  design and
install extraction systems. The treatment system proposed for Alternative SHL-5 uses
sand filtration,  carbon adsorption,  and  ion exchange, all of which are proven technologies
with vendors available. Alternative SHL-9 would require a long-term discharge
agreement between the Army and the Town of Ayer POTW as part of its
W0099518.080
                                         30

-------
                                                             DECISION SUMMARY
                                                Shepley's Hill Landfill Operable Unit
                                                         Fort Devens, Massachusetts
implementation.  Initial discussions with representatives from the Town of Ayer POTW
indicate a willingness to consider accepting the discharge.  Many engineering and
construction companies are qualified to design and install the cover system of Alternative
SHL-10.

Alternative SHL-1 would be the easiest alternative to implement at the site, and would
have the least effect on future remedial actions.
G.  Cost

Cost includes the capital (up-front) cost of implementing an alternative and the cost of
operating and maintaining the alternative  over the long term, and net present worth of
both capital and operation and maintenance costs.

A comparison of the estimated total present worth costs (based on a 5 percent discount
rate) for each alternative evaluated in detail is presented in the following table:
Alternative
SHL-1
SHL-2
SHL-5
SHL-9
SHL-10
Total Capital
$ 0
$ 928,000
$ 2,577,000
$ 1,184,000
$ 19,645,000
Total O&M (net
present worth)
$ 0
$ 1,291,000
$ 6,549,000
$ 2,690,000
$ 1,291,000
Total Costs (net
present worth)
$ 0
$ 2,219,000
$ 9,126,000
$ 3,874,000
$ 20,936,000
Capital, operation and maintenance, and present worth costs for each alternative were
calculated with an estimated accuracy of -30 percent to +50 percent.  The alternatives
with the lowest capital costs are those that include the least amount of construction, such
as Alternatives SHL-1, SHL-2, and SHL-9. Alternatives SHL-5 and SHL-10, which
involve greater amounts of construction, require larger capital  investment.
W0099518.080
                                         31

-------
DECSION SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
Operation and maintenance costs are estimated on an annual basis, and are lowest for
Alternative SHL-1, which does not provide any long-term maintenance  or monitoring.
Operation and maintenance costs for Alternatives SHL-2, SHL-5, SHL-9, and SHL-10
include environmental monitoring for 30 years.  Alternative SHL-5 includes operation of
the groundwater extraction, treatment and discharge systems, while Alternative SHL-9
includes operation of groundwater extraction and discharge systems and groundwater
monitoring for the estimated duration of treatment.
H.  State Acceptance

This criterion addresses whether, based on its review of the RI, RI Addendum, FS, and
proposed plan, the state concurs with, opposes, or has no comment on the alternative the
Army is proposing as the remedy for the AOCs.  The Commonwealth of Massachusetts
has reviewed the RI, RI Addendum, FS, proposed plan, and this Record of Decision and
concurs with the selected remedy.
I.  Community Acceptance

This criterion addresses whether the public concurs with the Army's proposed plan. No
comments were received from the community during the public comment period. The
Army believes this shows community acceptance of the proposed plan and selected
remedy.
X.    THE SELECTED REMEDY

The selected remedy to address groundwater contamination at the Shepley's Hill Landfill
Operable Unit is AJternative SHL-2: Limited Action, with Alternative SHL-9 as the
contingency remedy if Alternative SHL-2 proves not to be protective.  Each of these
alternatives includes components  for the containment of landfill wastes and management
of contaminant migration.  The remedial components of the selected remedy are
described in detail below.
W0099518.080
                                        32

-------
                                                            DECISION SUMMARY
                                               Shepley's Hill Landfill Operable Unit
                                                         Fort Devens, Massachusetts
A.     Groundwater Cleanup Levels

Groundwater cleanup levels for the Shepley's Hill Landfill Operable Unit were
developed following the USEPA guidance documents entitled, Risk Assessment Guidance
for Superfund: Volume 1 - Human Health Evaluation Manual (Part B, Development of Risk
Based Preliminary Remediation Goals), Interim, December 1991, and OSWER Directive
9355.0-30, Role of the Baseline Risk Assessment in Superfund Remedy Selection Decisions.
The first step in developing cleanup levels for protection of human health was to identify
those environmental media that in the baseline risk assessment presented either a
cumulative current or future cancer risk greater than IxlO"4 or a cumulative
noncarcinogenic HI greater than 1, based on reasonable maximum exposure assumptions.
The next step was to identify chemicals of concern within the media presenting cancer
risks greater than IxlO'6 or a hazard quotient greater than 1.  This approach identified
dichlorobenzenes, 1,2-dichloroethane, arsenic,  and manganese  as chemicals  of concern in
groundwater.  In addition, the baseline risk assessment identified the following chemicals
of concern as exceeding MCLs or MMCLs: dichlorobenzenes,  1,2-dichloroethane,
arsenic, chromium, and nickel.  Concentrations of lead in groundwater exceeded the
federal drinking water action level. Concentrations of aluminum and  iron exceeded non-
risk based federal and Massachusetts Secondary MCLs, while sodium  exceeded the
federal and Massachusetts guidelines for individuals on a sodium restricted  diet.

With the exception of manganese, groundwater cleanup levels  for chemicals of concern
were established based on MCLs and MMCLs.  No MCL or MMCL has been
established for manganese.  The cleanup level for manganese was based on background
concentrations because background concentrations exceed the  risk-based concentration
derived from the  available RfD value (5xlO~3 milligrams/kilograms/day).  Because
background concentrations for aluminum and iron exceed their respective guideline
value,  cleanup levels  for them were set at the background value.  The cleanup level for
sodium was set equal to the federal health advisory. The following table  summarizes
cleanup levels for Shepley's Hill Landfill Operable Unit groundwater.
W0099518.080
                                        33

-------
DECSION SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
Chemical of Concern
Arsenic
Chromium
1,2-Dichlorobenzene
1 ,4-Dichlorobenze ne
1 ,2-Dichloroethane
Lead
Manganese
Nickel
Sodium
Aluminum
Iron
Cleanup Level, /*g/L
50
100
600
5
5
15
291
100
20,000
6,870
9,100
Selection Basis
MCL
MCL
MCL
MMCL
MCL
Action Level
Background
MCL
Health Advisory
Background
Background
Attainment of cleanup levels in groundwater will result in an approximate eight-fold
reduction in potential human health risk, reflecting the approximate eight-fold reduction
in arsenic concentrations needed to attain the arsenic cleanup level. Recent studies
indicate that many skin tumors arising from oral exposure to arsenic are non-lethal and
that the dose-response curve for the skin cancers may be sublinear (in which case the
cancer slope factor used to generate risk estimates may be overestimated).  It  has been
USEPA policy to manage these risks downward by as much as a factor of ten.  As a
result, the carcinogenic risk for  arsenic at Shepley's Hill Landfill Operable Unit has been
managed as if it were one order or magnitude lower than the calculated risk.  The
residual human health risk from residential exposure to groundwater after attainment of
cleanup levels is estimated to be approximately  IxlO"3 (unmodified to account  for the
uncertainty associated with arsenic) and 1x10^ if modified to account for the uncertainty
associated with exposure to arsenic.
B.     Description of Remedial Components
W0099518.080
                                         34

-------
                                                             DECISION SUMMARY
                                                Shepley's Hill Landfill Operable Unit
                                                         Fort Devens, Massachusetts
Alternative SHL-2 contains components to maintain and potentially improve the
effectiveness of the existing landfill cover system and to satisfy the Landfill Post-Closure
Requirements of 310 CMR 19.142 to reduce potential future exposure to contaminated
groundwater.  Key components of this alternative include:

       •      landfill closure in accordance with applicable requirements of 310 CMR
             19.000;
       •      survey of Shepley's Hill Landfill;
       •      evaluation/improvement of stormwater diversion and drainage;
       •      landfill cover maintenance;
       •      landfill gas collection system maintenance;
       •      long-term groundwater monitoring;
       •      long-term landfill gas monitoring;
       •      institutional controls;
       •      educational programs;
       •      60 percent design of a groundwater extraction system;
       •      annual reporting to MADEP and USEPA; and
       •      five-year site reviews.

Each of these components is described in the following paragraphs.

Landfill Closure in Accordance with Applicable Requirements of 310 CMR 19.000.
Commonwealth  of Massachusetts regulations at 310 CMR 19.000 contain requirements
for the submittal to, and approval by, MADEP of plans and supporting materials to
document that landfill closure occurs according to approved plans and applicable
MADEP requirements.  The Army submitted a draft closure plan for Shepley's Hill
Landfill to MADEP on July 21, 1995 pursuant to 310 CMR 19.000; however, the landfill
will not be officially closed until MADEP  approves the documents.  Review of the plan
and official closure of the landfill by MADEP  was anticipated  prior to signature of this
Record of Decision. The Army will coordinate the finalization and submittal of plans
and support materials to MADEP to achieve official landfill closure.

Survey of Shepley's Hill Landfill.  Prior  to design and implementation of remedial
actions at Shepley's Hill  Landfill, an  accurate topographic survey of the  landfill surface is
required.  No  survey has been done since completion of the last  phase of landfill
capping. The  estimated  cost of this alternative includes an aerial survey of Shepley's Hill
Landfill.  It also includes the costs to survey the elevation  and  horizontal location of
W0099518.080
                                         35

-------
DECSION SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens,  Massachusetts
monitoring wells or piezometers installed as part of remedial alternative implementation,
and to prepare record drawings.

Evaluation/Improvement of Stormwater Diversion and Drainage. Stormwater diversion
and drainage systems at and adjacent to Shepley's Hill Landfill will be evaluated as part
of this alternative. Modifications for improvement will be implemented if the evaluation
shows they would be practical and cost-effective. The evaluation will  focus on the
following items of concern:

       •      landfill cap runoff patterns and drainage ditch flow capacities;

       •      potential run-under along the western edge of the landfill, particularly
             where the existing geomembrane cap may not have a good seal with the
             underlying bedrock; and

       •      the  effectiveness of Stormwater drainage systems upgradient  of the landfill
             (i.e., at the transfer station, tire recycling station,  DRMO yards, and along
             Market Street) at diverting run-off from potential infiltration areas
             upgradient of the landfill.

Detailed plans for evaluating Stormwater diversion and drainage would be developed
during the  alternative's design phase and submitted for regulatory agency review and
concurrence.

Landfill Cover Maintenance.  A small area of ponded water in the northwestern section
of the landfill would be drained and regraded to minimize  stress on the cover system and
prevent future ponding and potential for leakage through the PVC geomembrane.  The
area is approximately  100 feet in diameter and is estimated to be about 1  foot deep.
The water  would  be pumped out and the ponded area backfilled with common borrow to
bring the area up to the desired grade.  A new section of PVC geomembrane would be
installed on top of the fill and seamed to the existing geomembrane cap to provide a low
permeability surface in this area.

At the northern end of the landfill, erosion of cover soil in sections of the drainage
swales has  occurred in the past, exposing PVC geomembrane.  This erosion has been
repaired, but may require additional repair in the future.
W0099518.080
                                        36

-------
                                                            DECISION SUMMARY
                                                Shepley's Hill Landfill Operable Unit
                                                         Fort Devens, Massachusetts
Annual inspections are proposed to monitor the condition of the landfill cover at
Shepley's Hill Landfill, including monitoring wells, cover surface, and drainage swales to
decide if maintenance is needed.  Grass will be mowed annually and the cover repaired
as required. Landfill maintenance and mowing would be scheduled to minimize
potential adverse effects to the Grasshopper Sparrow, a state-listed species of special
concern that may nest on the cover.

Detailed plans for landfill cover maintenance would be developed  during the
alternative's design phase and submitted for regulatory agency review and concurrence.

Landfill Gas Collection System Maintenance.  Annual inspections are proposed to
monitor the Shepley's Hill Landfill gas collection system and provide any necessary
repairs.

Long-term  Groundwater Monitoring.  Groundwater monitoring is proposed to monitor
groundwater quality at Shepley's Hill Landfill and to  assess future  environmental effects.
Based  on the hydrogeologic interpretation and  analytical data presented in the RI
Addendum report, the FS report presents proposed monitoring locations and analytical
parameters for a conceptual long-term groundwater monitoring program.  The
conceptual  plan  includes installation of three new monitoring wells at the  north end of
the landfill  to create nested triplets of shallow/water table, mid-depth, and deep
overburden monitoring wells at SHL-9/SHL-22 and SHL-5.  The monitoring wells that
are included in the conceptual program would  be sampled semi-annually for a minimum
of 30 years, consistent with 310 CMR  19.142.  Table 5-3 of the  FS report presents
proposed monitoring locations and analytical parameters for a conceptual  long-term
groundwater monitoring program.

Detailed plans for long-term groundwater monitoring would be developed during the
alternative's design phase and submitted for regulatory agency review and concurrence.

Long-term  Landfill Gas Monitoring.  As part of post-closure monitoring activities,
landfill gas  will be monitored quarterly at landfill gas vents and analyzed in the field by
direct-reading instruments for lower explosive limit and total organic gases.  Semiannual
samples will be collected from the two vents with the highest field measurements and
analyzed for TCL VOCs.  These samples will be collected and analyzed in accordance
with USEPA Method TO  14. Detailed plans for landfill gas monitoring would be
W0099518.080
                                        37

-------
DECSION SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
developed during the alternative's design phase and submitted for regulatory agency
review and concurrence.

Institutional Controls.  Institutional controls are proposed in the form of zoning and
deed restrictions for any property released by the Army at Shepley's Hill Landfill during
Fort Devens base-closure activities.  The Fort Devens Preliminary Reuse Plan, Main and
North Posts has proposed that Army land bordering Plow Shop Pond be zoned for open
space and rail-related uses. By pre-empting residential use, these controls would help
limit human exposure.  In addition, the Army would place deed restrictions on landfill
area property to prohibit installation of drinking water wells.  This,  in combination with
landfill capping and long-term groundwater monitoring, would protect potential human
receptors from risks resulting from exposure  to contaminated groundwater. There  are no
current human receptors for groundwater exposure.  Institutional controls would be
drafted, implemented, and enforced in cooperation with state and local  governments.

Educational Programs. Periodic public meetings and presentations  would be conducted
to increase public awareness. This would help keep the public informed of the  site
status, including both its general condition and remaining contaminant levels. This could
be accomplished by conducting public meetings every five years coincident with the
five-year site reviews for Shepley's Hill Landfill.  The presentation would summarize site
activities and the results of monitoring programs.

60 Percent Design of a Groundwater Extraction System.  The Army will conduct
predesign hydrogeologic studies and prepare a 60 percent complete engineering design
for groundwater extraction  and discharge to the Town of Ayer POTW.  Predesign studies
may include installation of  several additional piezometers in and around the landfill,
collection of additional groundwater elevation data, and updating/refining the
groundwater model.  Detailed plans for monitoring the piezometers will be developed as
part of the long-term groundwater monitoring plan.  The 60 percent complete
engineering design will begin in  1996 and be completed before the  first  five-year site
review, scheduled for  1998.

Annual Reporting to MADEP and USEPA.  Reports which would include a description
of site activities and a summary of results of environmental monitoring would be
submitted annually to MADEP and USEPA.  This reporting would satisfy the
requirements of 310 CMR  19.132 and 19.142.
W0099518.080
                                        38

-------
                                                             DECISION SUMMARY
                                                Shepley's Hill Landfill Operable Unit
                                                         Fort Devens, Massachusetts
Five-year Site Reviews.  Under CERCLA 12 Ic, any remedial action (or lack thereof)
that results in contaminants remaining on-site must be reviewed at least every five years.
During five-year reviews, an assessment is made of whether the implemented remedy is
protective of human health and the environment and whether the implementation of
additional remedial action is appropriate.

The five-year site reviews for Alternative SHL-2 will evaluate the alternative's
effectiveness at reducing potential human  health risk from exposure to groundwater  and
at preventing groundwater from contributing to Plow Shop Pond  sediment contamination
in excess of human health and ecological risk-based values. These evaluations will be
based on how successful the alternative is at attaining cleanup  levels at individual wells
in two distinct monitoring well groups.  Well Group 1 consists  of wells, primarily at the
north end of the landfill, where cleanup levels have been attained historically. Well
Group 2 consists of wells where historically cleanup levels have not been  attained.

The goal of Alternative  SHL-2  is to maintain groundwater quality below cleanup levels
at Group 1 wells, and to attain  cleanup levels at Group 2 wells.  Since groundwater
quality historically attains cleanup levels in Group 1 wells, Alternative SHL-2 will be
considered effective with regard to these wells if five-year site reviews show that this
condition is maintained.

Evaluating effectiveness at Group 2 wells is less straightforward.  Installation of  the
geomembrane cap over the most upgradient areas at Shepley's Hill Landfill (i.e., areas in
the Phase IV-B closure) was not completed until May 1993.  Based on groundwater
modeling, it is estimated that the average time needed for groundwater to travel from
these  upgradient areas to downgradient wells SHL-11 and SHL-20 may be 10 to 14 years
or longer.  An equal or greater number of years may be needed for downgradient
groundwater quality at these wells to attain cleanup levels.  Overall groundwater quality
is expected to improve and potential risk is expected to decrease during this period,
although at some wells, certain  chemicals may show small  short-term increases in
concentration while other chemicals show decreases in concentrations and overall risk is
reduced.

The Army proposes to use reduction of risk rather than reduction of concentration as a
measure of progress toward attainment of cleanup levels because this approach focuses
on the cleanup of arsenic, which is the primary contributor to risk in  the Group  2 wells.
This approach prevents a situation in which failure to attain a  concentration reduction
W0099518.080
                                        39

-------
DECSION SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
goal for a minor contributor to risk (e.g., 1,2-dichloroethane where a reduction of 2.5
ppb represents a 50 percent reduction in concentration exceeding the cleanup level)
overshadows the achievement of 50 percent or greater reduction in the concentration of
arsenic. In the Group 2 wells, a 50 percent reduction in the concentration of arsenic
approximates a 50 percent reduction in groundwater risk, while a 50 percent reduction in
the concentration of 1,2-dichloroethane represents less than a 1 percent reduction in
groundwater risk.  Alternative SHL-2 will be considered effective with regard to these
wells if five-year reviews show an ongoing reduction of potential human health risk at
Group 2 wells and the ultimate attainment of cleanup levels by January 2008.

The specific criteria for evaluating the effectiveness of Alternative SHL-2 are stated
below. The criteria for both groups of wells must be met for the alternative to be
considered effective.

       Group  1 Wells. For Group 1 wells where analyte concentrations have historically
       attained cleanup levels, Alternative SHL-2 will be considered effective if
       concentrations of individual chemicals within individual wells do not show
       statistically  significant cleanup level  exceedances. To determine statistical
       significance, the Army will apply methods consistent with the regulations at 40
       CFR 264.97, 40 CFR 258.53, and 310 CMR 30.663.

       Group  2 Wells. For Group 2 wells where chemical concentrations have exceeded
       cleanup levels  in the past,  Alternative SHL-2 will be considered effective if a
       50 percent reduction  in the increment of risk between cleanup levels and baseline
       concentrations for chemicals of concern within individual wells is achieved  by
       January 1998, if an additional 25 percent (75 percent cumulative) is achieved by
       January 2003, and if cleanup levels are attained by January 2008.

The Army will apply methods consistent with the regulations at 40 CFR 264.97, 40 CFR
258.53, and  310 CMR 30.663 to estimate chemical concentrations at baseline conditions.
Analytical data collected during RI (August and December 1991) and supplemental RI
(March and June 1993) activities  will be used to estimate the baseline conditions. The
detailed approach  would be developed during the design phase and submitted for
regulatory agency review and concurrence.

A major consideration in assessing the protectiveness of Alternative SHL-2 and whether
additional remedial actions may be appropriate will be the basis on which individual
W0099518.080
                                         40

-------
                                                           DECISION SUMMARY
                                               Shepley's Hill Landfill Operable Unit
                                                        Fort Devens, Massachusetts
cleanup levels were set.  The Army will implement the contingency remedy if the above
criteria are not met for any chemicals for which cleanup levels were based on MCLs (40
CFR 141) and for manganese.  No MCL has been established for manganese.  The
cleanup level for manganese was based on background concentrations because
background concentrations exceed  the risk-based concentration  derived from the
available RfD value (5x10"3 milligrams/kilograms/day).  This approach for setting
cleanup levels and for evaluating the effectiveness of landfill closure is consistent with
USEPA guidance contained in Risk Assessment Guidance for Superfund: Volume I -
Human Health Evaluation Manual  (Part B, Development of Risk-Based Preliminary
Remediation Goals), Interim, December 1991, and with 40 CFR 258.55.

The Army will not implement additional remedial actions under CERCLA if cleanup
levels are not attained for aluminum and iron. The cleanup levels for aluminum and
iron were based on background concentrations because dose/response values were not
available.

Similarly, the Army will not implement additional remedial actions if the  cleanup level is
not attained for sodium. The cleanup level for sodium was based on the  health advisory
for individuals on a reduced sodium diet.

      Estimated Time for Restoration: Approximately 12 months for  engineering
            evaluations, design, and construction.
      Estimated Capital Cost:                             $   928,000
      Estimated Operation and Maintenance Cost:
            (net present worth)                           $1,291,000
      Estimated Total Cost: (net present worth,
            assuming 5% discount rate)                   $2,219,000
XI.   STATUTORY DETERMINATIONS

The selected remedy for the Shepley's Hill Landfill Operable Unit, Alternative SHL-2, 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 remedy utilizes permanent solutions and alternative treatment technologies, to the
maximum extent practicable for this site. However, because treatment of the principal
W0099518.080
                                       41

-------
DECSION SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
source of contamination at the site was found not to be practicable, Alternative SHL-2
does not satisfy the statutory preference for treatment as a principal element.
A.    The Selected Remedy is Protective of Human Health and the Environment.

Alternative SHL-2 will permanently reduce the risks to human health and environment
by eliminating, reducing, or controlling exposures to human and environmental receptors
through engineering and institutional controls.  The principal threat at the Shepley's Hill
Landfill Operable Unit is potential residential use of contaminated groundwater.  The
landfill closure plan, approved in 1985 and implemented in 1986 through 1993, relies on
landfill capping and stormwater controls to  reduce  leaching of landfill materials and
contamination of groundwater, thereby reducing potential risk associated with
groundwater use. Institutional controls included in this alternative would prevent the use
of groundwater from the contaminated aquifer, resulting in reduced potential for human
exposure to contaminated groundwater.  The landfill cover maintenance activities will
help ensure protection of human health and the environment  by maintaining the integrity
and effectiveness of the cover.

The effectiveness of the selected alternative will be evaluated by comparing groundwater
monitoring data to cleanup levels tabulated in Subsection X.A.  Attainment of cleanup
levels along the eastern edge of the landfill will result  in potential human health risk
levels within the Superfund target risk range of 1x10"  to IxlO"6 for carcinogenic
chemicals.  Groundwater at  the north end of the  landfill currently meets cleanup levels.

Groundwater modeling done during the FS suggests that capping of the landfill has
significantly reduced the amount of water in the landfill area, resulting in a  more
northerly groundwater flow and reducing  potential  adverse effects on Plow Shop Pond.
Groundwater at the north end of the landfill currently meets cleanup levels.  No
ecological receptor exposure to contaminated groundwater was identified.

Alternative SHL-9, the contingency remedy for the Shepley's Hill Landfill Operable
Unit, is also protective of human health and the environment.  Alternative SHL-9 will
permanently reduce the risks to human health and  environment by eliminating, reducing,
or controlling exposures to human  and environmental  receptors through engineering and
institutional controls.  The principal threat at the Shepley's Hill Landfill Operable Unit
is potential residential use of contaminated groundwater.  The landfill closure plan,
W0099518.080
                                        42

-------
                                                            DECISION SUMMARY
                                                Shepley's Hill Landfill Operable Unit
                                                         Fort Devens, Massachusetts
approved in 1985 and implemented in 1986 through 1993, relies on landfill capping and
stormwater controls to reduce leaching of landfill materials and contamination of
groundwater, thereby reducing potential  risk associated with groundwater use.  In
addition, as part of Alternative SHL-9 groundwater would be pumped from the
contaminated aquifer and discharged to the Town of Ayer POTW for treatment and
discharge, preventing contaminant migration and potential exposure.  Institutional
controls included in this alternative would further prevent the use of groundwater from
the contaminated aquifer, resulting in reduced potential for human exposure to
contaminated groundwater. The landfill cover maintenance activities will help ensure
protection of human health and the environment by maintaining the  integrity and
effectiveness of the cover.

The effectiveness of the contingency alternative  will be evaluated by  comparing
groundwater monitoring data to cleanup levels tabulated in Subsection X.A. Attainment
of cleanup levels along the eastern edge  of the landfill will result in potential human
health risk levels within the Superfund target risk range of 1x10^ to IxlO"6 for
carcinogenic chemicals.  Groundwater at the north  end of the landfill currently meets
cleanup levels.

Groundwater modeling done during the FS  suggests that capping of the landfill has
significantly reduced the amount of water in the landfill area, resulting in a more
northerly groundwater flow and reducing potential adverse effects on Plow Shop  Pond.
Groundwater at the north end of the landfill currently meets  cleanup levels. No
ecological receptor exposure to contaminated groundwater was  identified.
B.    The Selected Remedy Attains ARARs.

The selected remedy will attain all applicable or relevant and appropriate federal and
State requirements. No waivers are required. ARARs for the Shepley's  Hill Landfill
Operable Unit were identified and discussed in the FS (Sections 2 and 5). Table 9 in
Appendix B summarizes the ARARs for the selected remedy, including the regulatory
citation, a brief summary of the requirement, and how it will be  attained. Environmental
laws from which ARARs for the selected remedial action are derived, and specific
ARARs include:
W0099518.080
                                        43

-------
DECSION SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
Location-specific Federal Requirements

      Floodplain Management Executive Order No. 11988, (40 CFR Part 6, App.
      A) (Applicable)

      Protection of Wetlands Executive Order No.  11990 (Applicable)

      Fish and Wildlife Coordination Act, (16 USC 661 et seq.; 40 CFR Part
      302)(Applicable)

      Endangered Species Act, (16 USC  1531 et seq.; 50 CFR Part 402)(Applicable)

Location-specific State Requirements

      Massachusetts Wetland Protection Act and Regulations, (MGL c.  131 s. 40; 310
      CMR 10.00)(Applicable)

      Massachusetts Endangered Species Act and implementing regulations, (MGL c.
      131 A, s.  1 et seq.; 321 CMR 8.00)(Applicable)

      Areas of Critical Environmental Concern, (301 CMR 12.00)(Relevant and
      Appropriate)

Chemical-specific Federal Requirements

      Safe Drinking Water Act, National Primary Drinking Water Standards, MCLs, (40
      CFR Parts 141.11-141.16 and 141.50-191.51)(Relevant and Appropriate)

Chemical-specific State Requirements

      Massachusetts Surface Water Quality Standards, (314 CMR 4.00)(Applicable)

      Massachusetts Groundwater Quality Standards,-(314 CMR 6.00)(Applicable)

      Massachusetts Drinking Water Standards and Guidelines, (310 CMR
      22.00)(Relevant and Appropriate)
W0099518.080
                                        44

-------
                                                            DECISION SUMMARY
                                               Shepley's Hill Landfill Operable Unit
                                                        Fort Devens, Massachusetts
      Massachusetts Ambient Air Quality Standards, (310 CMR 6.00)(Relevant and
      Appropriate)

      Massachusetts Air Pollution Control Regulations, (310 CMR 7.00)(Relevant and
      Appropriate)

Action-specific Federal Requirements

      Resource Conservation and Recovery Act (RCRA), (Subtitle D, 40 CFR
      258)(Relevant and Appropriate)

      Resource Conservation and Recovery Act (RCRA), (Subtitle C, 40 CFR 260,
      264)(Relevant and Appropriate)

Action-specific State Requirements

      Massachusetts Solid Waste Management Regulations, (310 CMR
      19.100)( Applicable)

      Massachusetts Hazardous  Waste Regulations, (310 CMR 30.00)(Relevant and
      Appropriate)

The contingency remedy, Alternative SHL-9, will also attain all applicable or relevant
and appropriate federal and State requirements. No waivers are required. ARARs for
the Shepley's Hill Landfill Operable Unit were identified and discussed in the FS
(Sections 2 and 5).  ARARs for the  Alternative SHL-9 are the same as for Alternative
SHL-2 with the addition of the General Pretreatment Program regulations (40 CFR 403)
promulgated pursuant to the Clean Water Act. These regulations require that
nondomestic wastewater discharges to  a POTW must comply with the  general
prohibitions of the regulation, any categorical pretreatment standards,  and local
pretreatment standards. The discharge of groundwater to the POTW would be sampled
to evaluate compliance with the regulation.
C.    The Selected Remedial Action is Cost-Effective.
W0099518.080
                                        45

-------
DECSION SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
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
attain, or, as  appropriate, waive ARARs, the  Army evaluated the overall effectiveness of
each alternative according to 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.

Review of the discussion of "Overall Protection of Human Health and the Environment"
in Subsection IX.A. and of "Cost" in Subsection IX.G. suggests that Alternatives SHL-2,
SHL-5,  SHL-9, and SHL-10  all provide a similar level of protectiveness. However,
Alternative SHL-2 does so at the lowest cost and is considered the most cost-effective of
those four alternatives. The cost of Alternative SHL-9, although approximately 1.75
times as much as Alternative SHL-2, is still considered proportional to the benefits, and
Alternative SHL-9 is also considered cost-effective.  Alternative SHL-5 is very similar to
Alternative SHL-9, but costs over twice  as much as Alternative SHL-9 and over four
times as much as Alternative SHL-2: it is not considered cost-effective. Alternative
SHL-10, which costs nearly ten times as much as Alternative SHL-2,  is not considered
cost-effective. The costs of the selected remedy, Alternative SHL-2,  in 1994 dollars are:

      Estimated Capital Cost:                             $  928,000
      Estimated Operation and Maintenance
             Cost (net present worth):                      $ 1,291,000
      Estimated Total Cost
             (net present worth):                           $ 2,219,000

Should  the selected remedy  fail to be protective, the contingency remedy, Alternative
SHL-9,  will be implemented, the overall effectiveness of which is proportional to its
costs. The costs of the contingency remedy are presented below:

      Estimated Capital Cost:                             $ 1,184,000
      Estimated Operation and Maintenance
             Cost (net present worth):                      $ 2,690,000
      Estimated Total Cost
             (net present worth):                           $ 3,874,000
W0099518.080
                                         46

-------
                                                            DECISION SUMMARY
                                               S hep ley's Hill Landfill Operable Unit
                                                         Fort Devens, Massachusetts
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 determined
which alternative made use of 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 emphasized
long-term effectiveness and permanence and the reduction of toxicity, mobility,  and
volume  through treatment; and considered 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.

As described  in Section IX, Summary of The Comparative Analysis of Alternatives,
Alternative SHL-1 does not provide long-term effectiveness and permanence, while
Alternatives SHL-2, SHL-5, SHL-9,  and SHL-10 provide  similar long-term effectiveness
and permanence.

Alternatives SHL-1, SHL-2, and SHL-10 do not meet the statutory preference for
treatment under CERCLA since these alternatives do not treat contaminants contained
in groundwater or wastes at the site. Landfill capping which is a part of each alternative
will reduce infiltration and the resulting leaching of contaminants, thus reducing
contaminant mobility. Alternatives SHL-5 and SHL-9 meet the CERCLA statutory
preference for treatment. These alternatives would reduce the mobility of contaminants
by extracting  the groundwater for treatment or disposal.

Among  the five alternatives, Alternatives  SHL-1 and SHL-2 have the least potential for
adverse  short-term effects while Alternative SHL-10  has  the greatest potential.
Alternatives SHL-5 and SHL-9 share a similar intermediate potential for adverse short-
term effects.

Although Alternative SHL-1 is seen to have the easiest technical implementability,
significant obstacles to  current implementation or implementation of future remedial
W0099518.080
                                        47

-------
DECSION SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
actions are not foreseen for any of the alternatives.  Implementation of Alternative SHL-
9 does require a long-term discharge agreement between the Army and the Town of
Ayer POTW.

Alternative SHL-1, the No Action alternative, does not require any capital commitment
or any ongoing expenditure for operation and maintenance.  Of the remaining
alternatives, Alternative SHL-2 has the lowest estimated cost. Alternative SHL-5 costs
approximately four times more than Alternative SHL-2, while Alternative SHL-9 costs
approximately two times more than Alternative SHL-2. The estimated cost of
Alternative SHL-10 is approximately ten times greater than the cost of Alternative
SHL-2.

The Army believes Alternative SHL-2 provides the best balance among the alternatives
that are protective and attain ARARs.  Alternative SHL-2 offers potential long-term
effectiveness with little potential for short-term risks. The alternative is readily
implementable at a moderate cost.  Although named Limited Action, Alternative SHL-2
is based on the presence of an existing landfill cover system designed to comply with
applicable MADEP criteria. Installation of the cover system was only completed in 1993,
and Alternative SHL-2 provides an opportunity to monitor and evaluate the effectiveness
of the cover system at controlling groundwater contamination.  The selection of
Alternative SHL-2 is cost-effective  and consistent with USEPA guidance  contained in the
USEPA document Conducting Remedial Investigations/Feasibility Studies for CERCLA
Municipal Landfill Sites, which states that the most practical remedial alternative for
landfills is generally containment by capping.

The Army believes the contingency remedy,  Alternative SHL-9, provides the  next best
balance among the alternatives that are protective and  attain ARARs. Alternative SHL-
9 offers potential long-term effectiveness, but compared to Alternative SHL-2 has a
somewhat greater potential for short-term risks. The alternative is readily
implementable at approximately twice the cost of Alternative SHL-2. Similar to
Alternative SHL-2, Alternative SHL-9 is based on the presence of an existing landfill
cover system designed to comply with applicable MADEP criteria.  Alternative SHL-9
has groundwater extraction and treatment/disposal components to further control
contaminant migration and potential exposure.
W0099518.080
                                         48

-------
                                                            DECISION SUMMARY
                                               Shepley's Hill Landfill Operable Unit
                                                         Fort Devens, Massachusetts
E.    The Selected Remedy Does Not Satisfy the Preference for Treatment Which
      Permanently and Significantly Reduces the Toxicity, Mobility, and Volume of
      Hazardous Substances as a Principal Element

The principal element of the selected remedy is source control by containment of landfill
materials. This element addresses the primary  threat at the Shepley's Hill Landfill
Operable Unit, which is potential residential use of contaminated groundwater, by
controlling the leaching of landfill materials and the release of contaminants to
groundwater. Therefore, the selected remedy does reduce contaminant mobility, but not
by treatment.  In-situ treatment, or alternately the excavation and treatment, of such  a
large, heterogeneous landfill as Shepley's Hill Landfill is considered impractical and not
cost effective.  If the selected remedy proves not to be protective, the  contingency
alternative (Alternative SHL-9), which includes groundwater extraction and treatment,
will be implemented  to attain cleanup levels.
XII.  DOCUMENTATION OF NO SIGNIFICANT CHANGES

The Army presented a proposed plan (preferred alternative) for
remediation of Shepley's Hill Landfill Operable Unit on June 6, 1995.  The components
of the preferred alternative (Alternative SHL-2: Limited Action) included:

      •      survey of Shepley's Hill Landfill;
      •      evaluation/improvement of stormwater diversion and drainage;
      •      landfill cover maintenance;
      •      landfill gas collection system maintenance;
      •      long-term groundwater monitoring;
      •      long-term landfill gas monitoring;
      •      institutional controls;
      •      educational programs;
      •      60 percent design  of a groundwater extraction system
      •      annual reporting to MADEP and USEPA; and
      •      five-year site reviews.

New information obtained prior  to the final selection of the remedy for Shepley's Hill
Landfill Operable Unit resulted in  a modification of the preferred alternative discussed
in the proposed plan. The preferred alternative, Alternative SHL-2, was selected in part
W0099518.080
                                        49

-------
DECSION SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
because approval of landfill closure documents and official closure of the landfill by
MADEP under applicable requirements of 310 CMR 19.000 were expected prior to
Record of Decision signature. However, although construction of the cap on the landfill
is complete, and the Army has submitted supporting documentation to MADEP,  the
landfill closure will not be officially complete until MADEP approves the documents.

Consequently, the selected remedy has been modified to include achievement by the
Army of the official closure of the landfill by MADEP.  The ARARs table has been
modified to reflect this additional remedial requirement. This change to the remedy,
though significant, has little or no effect on the scope, performance, or cost of the
proposed remedy, and does not require additional public comment.

The contingency remedy, Alternative SHL-9, has also been modified from the proposed
plan to include  achievement by the Army of official closure of the  landfill by MADEP
pursuant to applicable requirements of 310 CMR 19.000.
XIII.  STATE ROLE

The Commonwealth of Massachusetts has reviewed the alternatives presented in the FS
and proposed plan and concurs with the selected remedy for the Shepley's Hill Landfill
Operable Unit. The Commonwealth has also reviewed the RI, RI Addendum, and FS to
determine if the selected remedy complies with applicable or relevant and appropriate
laws and regulations of the Commonwealth. A copy of the declaration of concurrence is
attached as Appendix E.
W0099518.080
                                        50

-------
T3
-O

-------
RECORD OF DECISION
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
                           APPENDIX A - FIGURES
W0099518.080

-------
                                                  MOORE ARMY
                                                    AIRFIELD
                                                              SHEPLEY'S
                                                                 HILL
                                                               LANDFILL
                         VERBECK
                          GATE
      ...SO, COUNTY,
        ^^"(W^CE^S,—•	>
                                                  JACKSON
                                                    GATE
                                                              .. . - TOWN LINE

                                                                   RIVER/BROOK

                                                                   POND/LAKE

                                                              	 INSTALLATION BOUNDARY

                                                                   ROADS/ HIGHWAY
9502006D(a) 5
                                                                         FIGURE 1
                                                                    LOCATION OF
                                        SHEPLEY'S HILL LANDFILL OPERABLE UNIT
                                                                FORT DEVENS, MA
                                       —	ABB Environmental Services, Inc.-

-------
                     ••.••.••PHASE
                     '.'.-'•'.•'•'. 198.6 '•'.•'•'.•'•'
                . ' • . ' • '(SHEPLEY'S HILL LANDFILL).
            LEGEND
       •$•   MONITORING WELL
	RESERVATION BOUNDARY
 tr ~ = ID   CULVERT
-  —  —   - DRAINAGE COURSE
  ...         RAILROAD TRACKS
-*	*	x— FENCE
 [ • .  - .  •"]  EDGE OF MEMBRANE CAP
       1000 FEET
                              FIGURE 2
SHEPLETS HILL LANDFILL SFTE MAP
                    FORT DEVENS, MA
            ABB Environmental Services, Inc.-

-------
x>
•o
TJ
D

X

CO

-------
RECORD OF DECISION
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
                         APPENDIX B - TABLES
W0099518.080

-------
                                                  TABLE 1
                 SUMMARY STATISTICS FOR SHEPLEY'S HILL LANDFILL GROUNDWATER
                                               WELL GROUP1

                                           RECORD OF DECISION
                                SHEPLEY'S HILL LANDFILL OPERABLE UNIT
                                             FORT DEVENS, MA
ANALYTE
MAXIMUM
FREQUENCY DETECTED ARITHMETIC
OF CONCENTRATION MEAN
DETECTION fiuc/L) tuelL)
COPC
(YfN)
UNFILTERED SAMPLES '
1,1-Dichloroetbane
1,2-Dichloroethane
1,2-Dichloroethene (cis & trans)
1,2-Dichloropropane
Acetone
Benzene
Chloroethane
Chloroform
Dichlorobenzenes (total)
Toluene
Aluminum
Antimony
Arsenic
Barium
Calcium
Chromium
Cobalt
Copper
ron
Lead
Magnesium
Manganese
Nickel
'otassium
Sodium
Vanadium
Zinc
4 714
5 714
6 714
1 714
1 /14
3 /14
1 /14
3 /I4
1 /14
1 /14
13 /14
2 /14
12 /14
13 /14
14 /14
5 /14
1 /14
4 /14
14 /14
10 /14
14 /14
14 /14
1 114
13 /14
14 /14
3 /14
3 /14
4.4
9.9
7
O.J2
15
1.7
5.5
0.87
11
0.56
75500
3.3
390
350
219000
115
54.6
92.2
97400
66.8
24000
9650
177
31800
67300
79.1
220
0.86
0.97
1.4
0.27
7
0.51
1.3
0.33
5.4
0.26
4259
1.7
101
47.6
54280
9
14
8.6
17608
5.2
7603
2045
22.9
7119
20749
9.4
29.4
Y
Y
Y
Y
N
Y
Y
N
Y
N
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
FILTERED SAMPLES >
Aluminum
Antimony
Arsenic
Barium
Calcium
Iron
Lead
Magnesium
Manganese
'otassium
Sodium
Zinc
i no
1 /10
6 /10
10 no
10 /10
7 /10
2 /10
9 710
10 710
9 710
10 710
1 710
236 BB
3.12
270
117
175000
91600
1.52 BB
19900
9540
10600
64600
25.5
NA
2
71
30
37402
14427
NA
4679
1812
4127
16934
11
N
y
Y
Y
Y
Y
N
Y
Y
Y
Y
Y
 Notes
 NA = Not applicable
 ^g/L = Micrograms per liter
 BB = Less than background concentration
 I From March and June 1993 sampling rounds
 2 Unfilleted samples from momtonng wells SHL-3, SHL-4. SHL-5, SHL-9, SHL-10, SHL-11. SHL-18.
  SHL-19, SHL-20, SHL-22, SHM-93-01A. SHM-9J-10C. SHM-93-I8B. SHM-93-22C
 3 Filtered samples from monitoring wells SHL-3. SHL-4, SHL-5. SHL-9, SHL-10. SHL-11, SHL-19
  SHL-20, SHM-93-01A, SHM-93-18B
g:\t65\usaec\Ubles\fdfs\rod\l .wkl
                                                                                                                  07/14/95

-------
                                                   TABLE 2
                     SUMMARY STATISTICS FOR SHEPLEY'S HILL LANDFILL GROUNDWATER
                                               WELL GROUP 3-

                                            RECORD OF DECISION
                                  SHEPLEY'S HILL LANDFILL OPERABLE UNIT
                                              FORT DEVENS, MA



ANALYTE
UNFILTERED SAMPLES2
Aluminum
Arsenic
Barium
Calcium
Chromium
Iron
Lead
Vlagnesium
Manganese
Potassium
Sodium
FILTERED SAMPLES'
Barium
Calcium
Magnesium
Manganese
'otassium
Sodium

FREQUENCY
OF
DETECTION

2/4
2/4
4/4
4/4
2/4
4/4
2/4
4/4
4/4
4/4
4/4

I/
I/
I/
I/
I/
I/
MAXIMUM
DETECTED
CONCENTRATION
(ut/L)

4030 BB
17
28 BB
15400
7.38 BB
5350 BB
7.38
2850 BB
1590
2080 BB
17300

8.71 BB
1 1000 BB
1840 BB
114 BB
829 BB
16400

ARITHMETIC
MEAN
fnc/L)

1800
8.4
14
1100
5.1
2500
3.4
1900
680
1900
7600

NA
NA
NA
NA
NA
NA


COPC
WTO

N
Y
N
Y
N
N
Y
N
Y
N
Y

N
N
N
N
N
Y
 Notes:
 ug/L = Micrograms per liter
 NA = Not applicable
 BB = Less than background concentration
 I From March 1993 sampling round.
 2 Unflltered samples from monitoring wells SHL-8D, SHL-8S, SHL-13, SHL-21.
 3 Filtered samples from monitoring well SHL-13.
g:\J65taMec\abteUaa\rod\2wkl
                                                                                                          07/1^95

-------
                                               TABLE3
                  SUMMARY STATISTICS FOR SHEPLEY'S HILL LANDFILL GROUNDWATER
                                            WELL GROUP 4'

                                         RECORD OF DECISION
                               SHEPLEY'S HILL LANDFILL OPERABLE UNIT
                                          FORT DEVENS, MA



ANALYTE
UNFILTERED SAMPLES1
Trichlorofluoromethane
Aluminum
Arsenic
Barium
Calcium
Iron
Lead
Magnesium
Manganese
Potassium
Sodium
Zinc
FILTERED SAMPLES'
Barium
Calcium
Chromium
jon
Lead
viagnesium
Manganese
}otassium
Sodium
Zinc

FREQUENCY
OF
DETECTION

1 /
1 /
1 /
1 /
1 /
1 /
1 /
1 /
1 /
1 /
1 /
1 /

1 /
1 /
1 /
1 /
1 /
1 /
1 /
1 /
1 /
1 /
MAXIMUM
DETECTED ARITHMETIC
CONCENTRATION MEAN
fat/L) foc/L)

2.1
1330 BB
24
39.4 BB
15600
1840 BB
3.69 BB
1900 BB
1430
3260
7370 BB
35.8

26.2 BB
16900
6.95 BB
42.5 BB
1.63 BB
1860 BB
1850
1870 BB
7630 BB
28.8





NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA


COPC
fVW>

Y
N
Y
N
Y
N
N
N
Y
Y
N
Y

N
Y
N
N
N
N
Y
N
N
Y
 Notes:
 ug/L = Micrograms per liter
 NA = Not applicable
 BB = Less than background concentration
 I From March 1993 sampling record
 2 Unfiltered samples from monitoring well SHL-15
 3 Filtered samples from monitoring well SHL-15
g \t65\UMec\Ubla\fdfc\lod\3 wk I
                                                                                                      07/14/95

-------
                                                TABLE4
                          SUMMARY STATISTICS FOR ANALYTE CONCENTRATIONS
                              IN PLOW SHOP POND BLUEGILLS (WHOLE FISH)1

                                         RECORD OF DECISION
                                SHEPLEY'S fflLL LANDFILL OPERABLE UNIT
                                           FORTDEVENS,MA
ANALTYE
FREQUENCY
OF MINIMUM MAXIMUM ARITHMETIC
DETECTION CONCENTRATION CONCENTRATION MEAN
Pesticides (ug/Vg)
DDE
2/5
21
29
12.92
Inorganics (mg/kc)
Aluminum
Arsenic
Barium
Calcium
.^nrotnium
Cobalt
Copper
JOT)
Lead
Magnesium
vlanganesc
Mercury
Selenium
Sodium
Thallium
Zinc
5/5
1/5
5/5
5/5
5/5
4/5
5/5
5/5
1/5
5/5
5/5
5/5
5/5
5/5
1/5
5/5
1.6
1.3
1.3
23300
0.48
0.1
0.44
42.4
0.16
496
39.1
0.19
0.42
1480
0.1
22.2
4.5
1.3
4.4
48800
0.93
0.16
0.6
130
0.16
754
94.7
0.54
0.67
2290
0.1
29.6
2.5*
0.331
2.76
31940
0.656
0.10S
0.506
79.72
0.072
56S
63.2
0.368
0.55
1794
0.06
25.02
Notes:
ug/kg = nucrograms per kilogram
mg/kg - milligrams per kilogram
I Table inlcudes detected anaryta only.
All detected analytes were included as COPCs.

-------
                                                  TABLES
                             SUMMARY STATISTICS FOR ANALYTE CONCENTRATIONS
                               IN PLOW SHOP POND BULLHEAD AND BASS (FILLETS)'

                                            RECORD OF DECISION
                                   SHEPLEY'S HILL LANDFILL OPERABLE UNIT
                                              FORTDEVENS.MA


ANALYTE
FREQUENCY
OF
DETECTION

MINIMUM
CONCENTRATION

MAXIMUM
CONCENTRATION

ARITHMETIC
MPAN
Pesticides Gig/kg)
DDE
2/10
15
31
9.6675
Inorganics (nig/kg)
Ancnic
Calcium
Chromium
Cobalt
Copper
iron
Magnesium
Manganese
Mercury
Selenium
Sodium
Zinc
2/10
10/10
2/10
2/10
10/10
10/10
10/10
1/10
9/10
8/10
10/10
10/10
0.09
82.8
0.19
0.11
0.08
1.7
252
0.3
0.12
0.11
283
3.4
0.15
627
0.24
0.11
0.24
27
344
0.3
4
0.2
509
6.1
0.0497
170.615
0.123
0.056
0.174
8.195
279.15
0.163
1.144
0.125
420.85
4.48
Notes:
ug/kg - nucrograms per kilogram
rug/kg = milligrams per kilogram
i Table includes detected analytes only.
All detected analytes were included as COPCs.

-------
                                          TABLE 6
              SUMMARY STATISTICS FOR PLOW SHOP POND SHALLOW SEDIMENT1
                                    RECORD OF DECISION
                          SHEPLEY'S HILL LANDFILL OPERABLE UNIT
                                      FORT DEVENS, MA

FREQUENCY
OF
ANALYTE DETECTION
CONCENTRATION

MEAN MAXIMUM
(US/t) fllf/f)


COPC
mrr>
ORGANICS
Acetone 9/13 0.19 0.55
Mmethylene chloride 11/13 0.05 0.12
2-buUuione 5/13 0.04 0.13
Benzo(a)anthnicene 1/13 0.22 1.1
Chrysene 1/13 0.32 1.5
Fluoranthene 1/13 0.5 3.4
Naphthalene 1/13 0.32 1.6
Phenanthrcne 1/13 0.38 2.5
Pyrene 3/13 0.97 4.35
DDE 6/41 0.05 1.3
ODD 4//41 0.07 1.8
DDT 1/41 0.03 0.13
Heptachlor 2/41 0.006 0.092
N
N
N
Y
Y
Y
Y
Y
Y
Y
Y
Y
N
INORGANICS
Aluminum 41/41 7,938 24,000
Arsenic 41/41 467 3,200
Barium 38/41 108 344
Beryllium 8/41 0.53 2.72
Cadmium 13/41 9.8 60
Calcium 39/41 8,074 20,100
Cobalt 8/41 5.8 58.7
Chromium 38/41 1,987 10,000
Copper 30/41 39.7 132
Iron 41/41 36,314 330,000
Lead 40/41 125 632
Magnesium 36/41 1,629 6,900
Manganese 37/41 2,639 54,800
Mercury 37/41 18.2 130
Nickel 25/41 23 79.3
Potassium 17/41 435 2,350
Selenium 12/41 1.95 6.6
Sodium 35/41 1,113 2.870
Vanadium 15/41 24.6 166
Zinc 17/41 88.6 403
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
 Notes:
 Hg/g = micrograrns per gram
 1. Based on sediment samples SE-SHL-01 through SE-SHL-13 (April 1993 RI) and SHD-92-01 through
  SHD-92-28 at depths of less than 1 foot
g:\t65\ui»ec\l»bl<=\fd£>\ro
-------
                                                            TABLE 7
                              CHEMICALS OF POTENTIAL CONCERN1 IN HUMAN HEALTH RISK ASSESSMENT
                                                    SHEPLEY'S HILL LANDFILL

                                                      RECORD OF DECISION
                                             SHEPLEY'S HILL LANDFILL OPERABLE UNIT
                                                       FORT DEVENS, MA
CHEMICAL OF POTENTIAL CONCERN FISH TISSUE
GROUNDWATER
SEDIMENT WELLGROUP1 1WELLGROUP3 1WELLGROUP4
norganics
Aluminum X
Antimony
Arsenic X
Barium X
Beryllium
Calcium X
Cadmium
Chromium X
Cobalt X
Copper X
Iron X
Lead X
Magnesium X
Manganese X
Mercury X
Nickel
Potassium
Selenium X
Sodium X
Thallium X
Vanadium
Zinc X
X X
X
X X X X
X X
X
X X X X
X
X X
X X
X X
X X
XXX
X X
X X X X
X
X X
XX X
X
XXX

X X
XX X
g \t65\us«cc\t»ble5\fd&\ro5

-------
                                                                 TABLE 7
                                 CHEMICALS OF POTENTIAL CONCERN1 IN HUMAN HEALTH RISK ASSESSMENT
                                                         SHEPLEY'S HILL LANDFILL

                                                           RECORD OF DECISION
                                                 SHEPLEY'S HILL LANDFILL OPERABLE UNIT
                                                             FORT DEVENS, MA
CHEMICAL OF POTENTIAL CONCERN
FISH TISSUE
SEDIMENT
                                                                                                     GROUNDWATER
WELLGROUP1
[WELL GROUP 3
IWELLGROUP4
VOCs
   Benzene
   Chloroethane
   Chloroform
   1,1-Dichloroethane
   1,2-Dichloroethane
   1,2-Dichloroethene (cis & trans)
   1,2-Dichloropropane
   Trichlorofluoromethane
                                             X
                                             X
                                             X
                                             X
                                             X
                                             X
                                             X
SVOCs
   Dichlorobenzenes (total)
   Benzo(a)anthracene
   Chrysene
   Fluoranthene
   Naphthalene
   Phenanthrene
   Pyrene	
                         X
                         X
                         X
                         X
                         X
                         X
Pesticldes/PCBs
    ODD
    DDE
    DDT
                         X
                         X
                         X
i:\t65UmecUables\fdfi\rodV7 wfc 1
                                                                         2 of 2

-------
                                                     TABLE 8
                                  SUMMARY OF COVER SYSTEM PERFORMANCE STANDARDS

                                                RECORD OF DECISION
                                        SHEPLEY'S HILL LANDFILL OPERABLE UNIT
                                                 FORT DEVENS, MA
MASSACHUSETTS SOLID
WASTE REGULATIONS
310 CMR 19.000
Minimize percolation
of water into landfill.

Promote drainage of
precipitation.
Minimize erosion of
final cover.

Facilitate gas venting.
RCRA SUBTITLE C
40 CFR 264
Minimize migration
of liquids through
landfill.
Have a
permeability less
than or equal to
bottom liner or
subsoils.
Promote drainage
and minimize
erosion.

Function with
minimum
maintenance.

RCRA SUBTITLE D
40 CFR 258
Minimize infiltration
through landfill.
Have a permeability
less than or equal to
bottom liner or
subsoils or less than
10 E-5 centimeters
per second,
whichever is less.

Minimize erosion of
final cover.


MASSACHUSETTS
HAZARDOUS WASTE
REGULATIONS
310 CMR 30.000
Minimize migration of
liquids through landfill.
Have a permeability
less than or equal to
bottom liner.
Promote drainage and
minimize erosion of
cover.

Function with
minimum
maintenance.

How COMPLIANCE is ACHIEVED
BY EXISTING COVER
Geomembrane installations such as the existing
one at Shepley's Hill Landfill have a permeability
of 10 E -7 centimeters per second or less that
minimizes infiltration and migration of liquid into
landfilled waste. Sloped surface promotes runoff
and minimizes infiltration. Vegetation promotes
evapotranspiration.
Existing geomembrane permeability is less than
that of sands underlying landfill. There is no
bottom liner.
The existing cover is sloped to promote drainage
and vegetated to prevent erosion.
The existing cover is sloped and vegetated to
minimize erosion.
The existing cover was constructed in a manner
to minimize maintenance. Monitoring and
maintenance of cover systems to maintain
integrity is normal practice.
The existing collection piping and riser system
facilitate gas venting. Analysis of gas samples
from vents confirms that they function.
W007956T/1
Page 1 of 2

-------
(continued)
                                                      TABLE 8
                                   SUMMARY OF COVER SYSTEM PERFORMANCE STANDARDS

                                                 RECORD OF DECISION
                                         SHEPLEY'S HILL LANDFILL OPERABLE UNIT
                                                  FORT DEVENS, MA
MASSACHUSETTS SOLID
WASTE REGULATIONS
310 CMR 19.000
Minimize percolation
of water into landfill.
Accommodate settling
and subsidence to
continue to meet
performance
standards.
Ensure isolate of
wastes from
environment.
RCRA SUBTITLE C
40 CFR 264
Minimize migration
of liquids through
landfill.
Accommodate
settling and
subsidence to
maintain cover
integrity.

RCRA SUBTITLE D
40 CFR 258
Minimize infiltration
through landfill.

MASSACHUSETTS
HAZARDOUS WASTE
REGULATIONS
310 CMR 30.000
Minimize migration of
liquids through landfill.
Accommodate settling
and subsidence to
maintain cover
integrity.

How COMPLIANCE is ACHIEVED
BY EXISTING COVER
Geomembrane installations such as the existing
one at Shepley's Hill Landfill have a permeability
of 10 E -7 centimeters per second or less that
minimizes infiltration and migration of liquid into
landfilled waste. Sloped surface promotes runoff
and minimizes infiltration. Vegetation promotes
evapotranspiration.
Landfill materials were compacted and graded
during construction of the existing cap to
accommodate settling. Maintenance actions are
possible to maintain cover integrity If or when
settling occurs.
The existing cover isolates wastes from potential
terrestrial receptors by covering them with soil
and lowers groundwater to elevations interpreted
to be below waste.
W007956T/2
Page 2 of 2

-------
                                                                     TABLE 9
                                   SYNOPSIS OF FEDERAL AND STATE ARARs FOR ALTERNATIVE SHL-2:

                                                               RECORD OF DECISION
                                                      SHEPLEY'S  HILL LANDFILL OPERABLE UNIT
                                                                 FORT DEVENS, MA
                                                                                   LIMITED ACTION
 AUTHORITY
    LOCATION
 CHARACTERISTIC
      REQUIREMENT
    STATUS
          REQUIREMENT SYNOPSIS
  ACTION TO BE TAKEN TO
   ATTAIN REQUIREMENT
Federal
Regulatory
Authority
Floodplains
Floodplain Management
Executive Order No.
11988, [40CFR Part6,
App. A]
Applicable
Requires federal agencies to evaluate the
potential adverse effects associated with
direct and indirect development of a
floodplain. Alternatives that involve
modification/construction within a floodplain
may not be selected unless a determination
is made that no practicable alternative
exists. If no practicable alternative exists,
potential harm must be minimized and
action taken to restore and preserve the
natural and beneficial values of the
floodplain.	
To the extent that any
activity associated with this
alternative takes place in
the floodplain, the activity
will be altered to comply
with the law.
              Wetlands
                   Protection of Wetlands
                   Executive Order No.
                   11990
                          Applicable
                  Under this Order, federal agencies are
                  required to minimize the destruction, loss,
                  or degradation of wetlands, and preserve
                  and enhance natural and beneficial values
                  of wetlands.
                  If remediation is required within wetland
                  areas, and no practical alternative exists,
                  potential harm must be  minimized and
                  action taken to restore natural and beneficial
                  values.
                                            To the extent that any
                                            activity associated with this
                                            alternative takes place in
                                            wetlands, the activity will be
                                            altered to comply with the
                                            law.
          W0099518T/1
                                                      Page 1 of 9

-------
(continued)
                                                                     TABLE 9
                                   SYNOPSIS OF FEDERAL AND STATE ARARs FOR ALTERNATIVE SHL-2: LIMITED ACTION

                                                               RECORD OF DECISION
                                                      SHEPLEY'S HILL LANDFILL OPERABLE UNIT
                                                                 FORT DEVENS, MA
  AUTHORITY
   LOCATION
CHARACTERISTIC
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO
 ATTAIN REQUIREMENT
               Surface Waters
               Endangered
               Species
                  Fish and Wildlife
                  Coordination Act [16
                  USC 661 et seq.; 40 CFR
                  Part 302]
                    Applicable
             Actions which affect species/habitat require
             consultation with U.S. Department of the
             Interior, U.S. Fish and Wildlife Service, and
             National Marine Fisheries Service, and/or
             state agencies, as appropriate, to ensure
             that proposed actions do not jeopardize the
             continued existence of the species or
             adversely modify or destroy critical habitat.
             The effects of water-related projects on fish
             and wildlife resources must be considered.
             Action must be taken to prevent, mitigate,
             or compensate for project-related damages
             or losses to fish and wildlife resources.
             Consultation with the responsible agency is
             also strongly recommended for on-site
             actions.  Under 40  CFR Part 300.38, these
             requirements apply to all response activities
             under the NCP.
                                 No off-site remedial actions
                                 performed for this
                                 alternative. On-site actions
                                 would be minimal and
                                 would include agency
                                 consultation prior to
                                 implementation.
               Endangered
               Species
                  Endangered Species Act
                  [16 USC 1531 et seq.; 50
                  CFR Part 402]
                    Applicable
             This act requires action to avoid
             jeopardizing the continued existence of
             listed  endangered or threatened species or
             modification of their habitat.
                                 To minimize impact, landfill
                                 cover maintenance would
                                 be performed after nesting
                                 areas of the Grasshopper
                                 Sparrow have been
                                 identified.
           W0099518T/2
                                                    Page 2 of 9

-------
(continued)
                                                                  TABLE 9
                                 SYNOPSIS OF FEDERAL AND STATE ARARs FOR ALTERNATIVE SHL-2:  LIMITED ACTION

                                                            RECORD OF DECISION
                                                    SHEPLEY'S HILL LANDFILL OPERABLE UNIT
                                                              FORT DEVENS, MA

AUTHORITY
State
Regulatory
Authority




















LOCATION
CHARACTERISTIC
Floodplains
Wetlands















Endangered
Species





REQUIREMENT
Massachusetts Wetland
Protection Act and
Regulations [MGL c. 131
s. 40; 310 CMR 10.00]













Massachusetts
Endangered Species Act
and implementing
regulations [MGL c.
131A, s. 1 et seq.; 321
CMR 8.00]

STATUS
Applicable
















Applicable






REQUIREMENT SYNOPSIS
Wetlands and land subject to flooding are
protected under this Act and these
regulations. Activities that will remove,
dredge, fill, or alter protected areas (defined
as areas within the 100-year floodplain) are
subject to regulation and must file a Notice
of Intent with the municipal conservation
commission and obtain a Final Order of
Conditions before proceeding with the
activity. A Determination of Applicability or
Notice of Intent must be filed for activities
such as excavation within a 100 foot buffer
zone. The regulations specifically prohibit
loss of over 5,000 square feet of bordering
vegetated wetland. Loss may be permitted
with replication of any lost area within two
growing seasons.
Actions must be conducted in a manner
which minimizes the impact to
Massachusetts listed endangered species
and species listed by the Massachusetts
Natural Heritage Program.

ACTION TO BE TAKEN TO
ATTAIN REQUIREMENT
If remedial activities alter
more than 5,000 square
feet of protected area, the
affected area will be
restored within two growing
seasons.











To minimize impacts,
landfill cover maintenance
would be performed after
nesting areas of the
Grasshopper Sparrow have
been identified.
          W0099518T/3
Page 3 of 9

-------
(continued)
                                                                    TABLE 9
                                   SYNOPSIS OF FEDERAL AND STATE ARARs FOR ALTERNATIVE SHL-2: LIMITED ACTION

                                                               RECORD OF DECISION
                                                      SHEPLEY'S HILL LANDFILL OPERABLE UNIT
                                                                FORT DEVENS, MA
  AUTHORITY
   LOCATION
CHARACTERISTIC
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO
 ATTAIN REQUIREMENT
              Area of Critical
              Environmental
              Concern
                  Areas of Critical
                  Environmental Concern
                  [301 CMR 12.00]
                    Relevant and
                    Appropriate
             An Area of Critical Environmental Concern is
             of regional, state, or national importance or
             contains  significant  ecological systems with
             critical inter-relationships among a number-of-
             components.  An eligible area must contain
             features from four or more of the following
             groups:  (1) fishery habitats;  (2) coastal
             feature;  (3) estuarlne  wetland;  (4) Inland
             wetland;  (5) inland surface water; (6) water
             supply area  (i.e.,  aquifer  recharge  area);
             (7) natural hazard  area (i.e., floodplain);
             (8) agricultural  area; (9) historical/archeo-
             logical resources; (10) habitat resource (i.e.,
             for endangered wildlife;  or (11) special  use
             areas.
                                 Activities must be controlled
                                 to minimize impacts  to
                                 nesting  areas  of the
                                 Grasshopper Sparrow.
           W0099518T/4
                                                    Page 4 of 9

-------
(continued)
                                                                     TABLE 9
                                   SYNOPSIS OF FEDERAL AND STATE ARARs FOR ALTERNATIVE SHL-2:  LIMITED ACTION

                                                               RECORD OF DECISION
                                                      SHEPLEY'S HILL LANDFILL OPERABLE UNIT
                                                                FORT DEVENS, MA
 AUTHORITY
   CHEMICAL
    MEDIUM
     REQUIREMENT
  STATUS
        REQUIREMENT SYNOPSIS
   ACTION TO BE TAKEN TO ATTAIN
           REQUIREMENT
 Federal
 Regulatory
 Authority
Groundwater
Safe Drinking Water
Act, National Primary
Drinking Water
Standards, MCLs [40
CFR Parts 141.11 -
141.16 and 141.50-
191.51]
Relevant
and
Appropriate
The National Primary Drinking Water
Regulation establishes MCLs and non-
zero Maximum Contaminant Level Goals
for several common organic and
inorganic contaminants. These MCLs
specify the maximum permissible
concentrations of contaminants in public
drinking water supplies. MCLs are
federally enforceable standards based in
part on the availability and cost of
treatment techniques.
MCLs will be used to evaluate the
performance of this alternative.  If
MCLs are exceeded, the remedy will
be re-evaluated.
 State
 Regulatory
 Authority
Surface water
Massachusetts Surface
Water Quality
Standards [314 CMR
4.00]
Applicable
Massachusetts Surface Water Quality
Standards designate the most sensitive
uses for which surface waters of the
Commonwealth are to be enhanced,
maintained and protected and designate
minimum water quality criteria for
sustaining the designated uses. Surface
waters at Fort Devens are classified as
Class B. Surface waters assigned to this
class are designated as habitat  for fish,
other aquatic life and wildlife, and for
primary and  secondary contact
recreation.
Discharges associated with remedial
actions will be controlled/monitored
to ensure that surface waters meet
standards.
           W0099518T/5
                                                     Page 5 of 9

-------
(continued)
                                                                    TABLE 9
                                  SYNOPSIS OF FEDERAL AND STATE ARARs FOR ALTERNATIVE SHL-2: LIMITED ACTION

                                                              RECORD OF DECISION
                                                     SHEPLEY'S HILL LANDFILL OPERABLE UNIT
                                                               FORT DEVENS, MA
 AUTHORITY
CHEMICAL
 MEDIUM
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN
        REQUIREMENT
             Groundwater
              Massachusetts
              Groundwater Quality
              Standards [314 CMR
              6.00]
                   Applicable
           Massachusetts Groundwater Quality
           Standards designate and assign uses for
           which groundwaters of the
           Commonwealth shall be maintained and
           protected and set forth water quality
           criteria necessary to maintain the
           designated uses. Groundwater at Fort
           Devens is classified as Class I.
           Groundwaters assigned to this class are
           fresh groundwaters designated as a
           source of potable water supply.     	
                                MCLs will be used to evaluate the
                                performance of this alternative.  If
                                MCLs are exceeded, the remedy will
                                be re-evaluated.
              Groundwater
              Massachusetts Drinking
              Water Standards and
              Guidelines [310 CMR
              22.00]
                   Relevant
                   and
                   Appropriate
           The Massachusetts Drinking Water
           Standards and Guidelines list MMCLs
           which apply to water delivered to any
           user of a public water supply system as
           defined in 310 CMR 22.00. Private
           residential wells are not subject to the
           requirements  of 310 CMR 22.00; however,
           the standards are often used to evaluate
           private residential contamination
           especially in CERCLA activities.
                                MMCLs will be used to evaluate the
                                performance of this alternative. If
                                MMCLs are exceeded, the remedy
                                will be re-evaluated.
           W0099518T/6
                                                 Page 6 of 9

-------
(continued)
                                                                 TABLES
                                 SYNOPSIS OF FEDERAL AND STATE ARARs FOR ALTERNATIVE SHL-2:  LIMITED ACTION

                                                            RECORD OF DECISION
                                                   SHEPLEY'S HILL LANDFILL OPERABLE UNIT
                                                             FORT DEVENS, MA
AUTHORITY

CHEMICAL
MEDIUM
Air
Air
REQUIREMENT
Massachusetts Ambient
Air Quality Standards
[310 CMR 6.00]
Massachusetts Air
Pollution Control
Regulations [310 CMR
7.00]
STATUS
Relevant
and
Appropriate
Relevant
and
Appropriate
REQUIREMENT SYNOPSIS
Regulations specify primary and
secondary ambient air quality standards
to protect public health and welfare for
certain pollutants
Regulations pertain to the prevention of
emissions in excess of Massachusetts or
national ambient air quality standards or
in excess of emission limitations in those
regulations.
ACTION TO BE TAKEN TO ATTAIN
REQUIREMENT
Ambient Air Quality Standards will be
used to evaluate the performance of
this alternative. If standards are
exceeded, the remedy will be re-
evaluated.
Ambient Air Quality Standards will be
used to evaluate the performance of
this alternative. If standards are
exceeded, the remedy will be re-
evaluated.
          W0099518T/7
Page 7 of 9

-------
(continued)
                                                                  TABLE 9
                                 SYNOPSIS OF FEDERAL AND STATE ARARs FOR ALTERNATIVE SHL-2:  LIMITED ACTION

                                                            RECORD OF DECISION
                                                    SHEPLEY'S  HILL LANDFILL OPERABLE UNIT
                                                              FORT DEVENS, MA
AUTHORITY
Federal
Regulatory
Authority
State
Regulatory
Authority
ACTION
Solid waste
landfill construc-
tion, operation,
closure, and
post-closure
Hazardous
waste landfill
construction,
operation,
closure, and
post-closure
Solid waste
landfill
construction,
operation,
closure, and
post-closure.
REQUIREMENT
Resource Conservation
and Recovery Act
(RCRA) [Subtitle D,
40 CFR 258]
Resource Conservation
and Recovery Act
(RCRA) [Subtitle C,
40 CFR 260,264]
Massachusetts Solid
Waste Management
Regulations [310 CMR
19.000]
STATUS
Relevant
and
Appropriate
Relevant
and
Appropriate
Applicable
REQUIREMENT SYNOPSIS
RCRA Subtitle D regulates the generation,
transport, storage, treatment, and
disposal of solid wastes. Regulations at
40 CFR 258 govern preparedness and
prevention, closure, and post-closure at
municipal solid waste landfills.
RCRA Subtitle C regulates the generation,
transport, storage, treatment, and
disposal of hazardous wastes.
Regulations at 40 CFR 264 govern
preparedness and prevention, closure,
and post-closure at landfills.
These regulations outline the
requirements for construction, operation,
closure, and post-closure at solid waste
management facilities in the
Commonwealth of Massachusetts.
ACTION TO BE TAKEN TO ATTAIN
REQUIREMENT
Performance of this alternative will be
evaluated to determine compliance
with the substantive requirements of
federal solid waste regulations. If the
substantive requirements are not met
at the appropriate time, the remedy
will be re-evaluated.
Performance of this alternative will be
evaluated to determine compliance
with the substantive requirements of
federal hazardous waste regulations.
If the substantive requirements are
not met at the appropriate time, the
remedy will be re-evaluated.
This alternative includes components
to meet closure and post-closure
requirements at Shepley's Hill
Landfill.
          W0099518T/8
Page 8 of 9

-------
(continued)
                                                                  TABLE 9
                                 SYNOPSIS OF FEDERAL AND STATE ARARs FOR ALTERNATIVE SHL-2:  LIMITED ACTION

                                                            RECORD OF DECISION
                                                    SHEPLEY'S HILL LANDFILL OPERABLE UNIT
                                                             FORT DEVENS, MA
AUTHORITY

ACTION
Hazardous
waste landfill
construction,
operation,
closure, and
post-closure
REQUIREMENT
Massachusetts
Hazardous Waste
Regulations [310 CMR
30.00]
STATUS
Relevant
and
Appropriate
REQUIREMENT SYNOPSIS
Regulates handling, storage, treatment,
disposal, and record keeping at
hazardous waste facilities.
ACTION TO BE TAKEN TO ATTAIN
REQUIREMENT
Performance of this alternative will be
evaluated to determine compliance
with the substantive requirements of
Massachusetts hazardous waste
regulations. If the substantive
requirements are not met at the
appropriate time, the remedy will be
re-evaluated.
          W0099518T/9
Page 9 of 9

-------
•o
-a

-------
RECORD OF DECISION
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
                APPENDIX C - RESPONSIVENESS SUMMARY
W0099518.080

-------
RESPONSIVENESS SUMMARY                                             Page 1
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts

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

The Army held a 30-day public comment period from June 1 to June 30,  1995 to provide
an opportunity for interested parties to comment on the Feasibility Study (FS), proposed
plan, and other documents developed to address the cleanup of contaminated
groundwater at the Shepley's Hill Landfill Operable Unit at Fort Devens, Massachusetts.
The FS developed and evaluated various options (referred to as remedial alternatives) to
address human health and ecological risk from exposure to contaminated groundwater
and potential migration of substances present in groundwater at the Shepley's Hill
Landfill Operable Unit.  The Army identified its preferred alternative for cleanup of
groundwater in the proposed plan  issued on  May 31, 1995.

All documents on which  the preferred alternative  were  based were placed in the
Administrative Record for review.  The Administrative  Record contains all supporting
documentation considered by the Army in choosing the remedy for Shepley's Hill
Landfill Operable Unit.  The Administrative Record is  available to the public at the Fort
Devens Base Realignment and Closure (BRAC) Environmental Office, Building PI2,
Fort Devens, and at the  Ayer Town Hall, Main Street, Ayer. An index to the
Administrative Record is available at the U.S. Environmental Protection Agency
(USEPA) Records Center, 90 Canal Street, Boston, Massachusetts and is provided as
Appendix D to the Record of Decision.

This Responsiveness Summary is organized into the following sections:

I.     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 presented in the proposed plan, including the Army's selected
      remedy.
WOOW518.080

-------
RESPONSIVENESS SUMMARY                                             Page 2
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts

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

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

                                    *********

I.     OVERVIEW OF REMEDIAL ALTERNATIVES CONSIDERED  IN THE FS
      INCLUDING THE SELECTED REMEDY

Ten remedial alternatives were developed in the FS report and screened based on
implementability, effectiveness, and cost to narrow the number of remedial alternatives
for  detailed analysis.  Of the initial ten, five were retained for detailed  evaluation.  The
five retained alternatives are:
A.    Alternative SHL-1: No-Action

The No Action alternative does not contain any remedial action components beyond the
existing landfill cover system to reduce or control potential risks.  No institutional
controls would be implemented to prevent future human exposure, and existing activities
to maintain existing systems and monitor for potential future releases would be stopped.
Alternative SHL-1  is developed to provide a baseline for comparison with the other
remedial alternatives.
B.    Alternative SHL-2: Limited Action

Alternative SHL-2 contains components to maintain and potentially improve the
effectiveness of the existing landfill cover system and to satisfy the Landfill Post-Closure
Requirements of 310 CMR 19.142 to reduce potential future exposure to contaminated
groundwater.  Key components of this alternative include:
W0099518.080

-------
RESPONSIVENESS SUMMARY                                              Page 3
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts

      •      landfill closure in accordance with applicable requirements of 310 CMR
             19.000;
      •      survey of Shepley's Hill Landfill;
      •      evaluation/improvement of stormwater diversion and drainage;
      •      landfill cover maintenance;
      •      landfill gas collection system maintenance;
      •      long-term groundwater monitoring;
      •      long-term landfill gas monitoring;
      •      institutional  controls;
      •      educational programs;
      •      60 percent design of a groundwater extraction system;
      •      annual reporting to Massachusetts Department of Environmental
             Protection (MADEP) and USEPA; and
      •      five-year site reviews.

The Army's selected remedy is Alternative SHL-2, with Alternative SHL-9 as the
contingency remedy.
C.    Alternative SHL-5: Collection/Ion Exchange Treatment/Surface Water Discharge

Alternative SHL-5  consists of components that, together with the components of
Alternative SHL-2, would provide additional controls to prevent off-site migration of
contaminated groundwater.  Key components of Alternative SHL-5 include:

      •      landfill closure in accordance with applicable requirements of 310 CMR
             19.000;
      •      design, construction, operation, and maintenance of groundwater
             extraction, treatment, and discharge facilities;
      •      survey of Shepley's Hill Landfill;
      •      evaluation/improvement of stormwater diversion and drainage;
      •      landfill cover maintenance;
      •      landfill gas collection system maintenance;
      •      long-term groundwater monitoring;
      •      long-term landfill gas monitoring;
      •      institutional controls;
      •      educational programs;
      •      annual reporting to MADEP and USEPA; and
      •      five-year  site reviews.
W0099518.080

-------
RESPONSIVENESS SUMMARY                                              Page 4
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts

The major difference between Alternative SHL-5 and Alternative SHL-2 is the
construction and operation of groundwater extraction, treatment, and discharge facilities.
Data collected during predesign studies would be used to optimize the size and location
of groundwater extraction wells at Shepley's Hill Landfill. Contaminated groundwater
would be treated in an on-site groundwater treatment facility that (subject to treatability
studies) includes carbon adsorption, sand filtration, and ion exchange treatment units and
discharges through an effluent pipeline to Nonacoicus Brook.
D.    Alternative SHL-9: Collection/Discharge to POTW

Alternative SHL-9 adds the components of groundwater extraction and discharge to the
Town of Ayer publicly owned treatment works (POTW) to Alternative SHL-2 to provide
additional control to prevent off-site migration of contaminated groundwater. Key
components of Alternative SHL-9 include:

      •      landfill closure in accordance with applicable requirements of 310 CMR
             19.000;
      •      design, construction, operation, and maintenance of groundwater extraction
             and discharge facilities;
      •      survey of Shepley's Hill Landfill;
      •      evaluation/improvement of stormwater diversion and drainage;
      •      landfill cover maintenance;
      •      landfill gas collection system maintenance;
      •      long-term groundwater monitoring;
      •      long-term landfill gas monitoring;
      •      institutional controls;
      •      educational programs;
      •      annual reporting to MADEP and USEPA; and
      •      five-year site reviews.

The major difference  between Alternative SHL-9 and Alternative SHL-2 is the
construction and operation of groundwater extraction and discharge facilities. Data
collected during predesign studies would be used to  optimize the size and location of
groundwater extraction wells at Shepley's Hill Landfill.  Following construction of the
groundwater extraction facilities, contaminated groundwater would be pumped to a
discharge  manhole anticipated to be located on Scully Road near the north end of the
landfill.  There, the groundwater would combine with domestic wastewater and flow to
the Town  of Ayer POTW for treatment and subsequent discharge. The Ayer POTW,
WIK199518.080

-------
RESPONSIVENESS SUMMARY                                             Page 5
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts

with a capacity of 1.79 million gallons per day (MOD), would be able to handle the
additional anticipated volume of 20 to 30 gallons per minute (0.029 to 0.043 MGD).

Review of available groundwater monitoring data suggests that pretreatment of the
groundwater will not be needed to meet existing pretreatment standards established by
the Town of Ayer.  The Army would monitor the groundwater discharge to the POTW,
however, and if necessary install pretreatment facilities to meet pretreatment standards.
The Army would pay a sewer user fee to the  town based on the volume of water
discharged to the POTW.
E.    Alternative SHL-10: Installation of RCRA Cap

Alternative SHL-10 consists of building a new landfill cover system on top of the existing
cover system at Shepley's Hill Landfill. The new cover system would be designed to
meet Resource Conservation and Recovery Act (RCRA) performance criteria and design
guidance for hazardous waste landfills. The principal component of the new cover
system would be a 24-inch layer of low permeability soil in intimate contact with a
geomembrane.  Maintenance activities, monitoring and reporting requirements,  and
institutional controls would be similar to those of Alternative SHL-2.
II.    BACKGROUND ON COMMUNITY INVOLVEMENT

Community concern and involvement have been low throughout the history of Shepley's
Hill Landfill.  Although the Army has kept the community and other interested parties
informed of site activities through regular and frequent informational meetings, fact
sheets, press releases, and public meetings,  no members of the public attended the public
informational meeting on the proposed plan or the public hearing.

In February 1992 the Army released, following public review, a community relations plan
that outlined a program to address community concerns and keep citizens informed
about and involved in remedial activities at Fort Devens.  As part of this plan, the Army
established a Technical Review Committee (TRC) in early 1992. The TRC, as  required
by SARA Section 211 and Army  Regulation 200-1, included representatives from
USEPA,  U.S. Army Environmental Center  (USAEC), Fort Devens, MADEP, local
officials and the community. Until January 1994, when it was replaced by the
Restoration Advisory Board (RAB), the committee generally met quarterly to review and
provide technical comments on schedules, work plans, work products, and proposed
W0099518.080

-------
RESPONSIVENESS SUMMARY                                             Page 6
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts

activities for the Study Areas at Fort Devens. The Remedial Investigation (RI), RI
Addendum, and FS reports, proposed plan, and other related support documents were all
submitted  to the TRC or RAB for their review and comment.

The Army, as part of its commitment to involve the affected communities, forms a RAB
when an installation closure involves transfer of property to the community.  The Fort
Devens RAB was formed in February 1994 to add members of the Citizen's Advisory
Committee (CAC) to the TRC.  The CAC had been established previously to address
Massachusetts Environmental Policy Act/Environmental Assessment issues concerning
the reuse of property at Fort Devens. The RAB 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
requirements and priorities; and conducting regular meetings that are open to the public.
The Army presented the proposed plan for the Shepley's Hill Landfill Operable Unit at
the May 4, 1995 RAB meeting.

On May 31, 1995, the Army issued a fact sheet to citizens and organizations, to provide
the public with  a brief explanation of the Army's preferred remedy for cleanup of
groundwater at  the Shepley's Hill Landfill Operable Unit.  The fact sheet also described
the opportunities for public participation and provided details on the upcoming public
comment period and public meetings.

During the week of May 22, the Army published a public notice announcing  the
proposed plan, public informational meeting, and public hearing in the Times Free Press
and the Lowell  Sun. A public notice announcing the public hearing was published the
week of June 12, 1995 in the Times Free Press and the week of June 19,  1995 in the
Lowell Sun.  The Army also made the proposed plan available to the public  at the
information repositories at the libraries in Ayer, Shirley, Lancaster, Harvard  and at Fort
Devens.

From June 1 to June 30, 1995, 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 6, 1995, the Army  held an informal
informational meeting at Fort Devens to present the Army's proposed plan to the public
and discuss the  cleanup alternatives evaluated in the FS. This meeting also provided the
opportunity for  open discussion concerning the proposed cleanup. On June 27, 1995, the
W0099518.080

-------
RESPONSIVENESS SUMMARY                                            Page 7
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts

Army  held an informal public hearing at Fort Devens to discuss the proposed plan and
to accept verbal or written comments from the public.

All  supporting documentation for the decision regarding the Shepley's Hill Landfill
Operable Unit is contained in the Administrative Record for review.  The Administrative
Record is a collection of all the documents considered by the Army in choosing the
remedy for the Shepley's Hill Landfill Operable Unit.  On June 2, 1995, the Army made
the  Administrative Record available for public review at the Fort Devens  BRAC
Environmental Office, and at the Ayer Town Hall, Ayer, Massachusetts.  An index to the
Administrative Record is available at the USEPA Records Center,  90 Canal Street,
Boston, Massachusetts and is provided  as Appendix D.
III.   SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
      PERIOD AND ARMY RESPONSES

No comments were received during the public comment period.
W0099518.080

-------
RESPONSIVENESS SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
             ATTACHMENT A - PUBLIC HEARING TRANSCRIPT
W0099518.080

-------
   (M
   <•>
   f
   rg

   <0
   — « o
O 5
O °
C/5 jn
   -
O 5
*'
on
   IT
   U.
   O
   in
                   ABB  ENVIRONMENTAL SERVICES,  INC.
              PROPOSED PLAN

SHEPLEY'S  HILL LANDFILL  OPERABLE UNIT

     'FORT  DEVENS,  MASSACHUSETTS
                              PUBLIC  HEARING
                HELD AT:

      FORT  DEVENS,  MASSACHUSETTS

        TUESDAY,  JUNE 27,  1995

                7:00 P.M.
             (Robin  Gross,  Registered Professional Reporter)
                        DORIS 0. WONG ASSOCIATES

-------
 Vj
 o
 >n
o'

-------
 1                      PROCEEDINGS




 2            MR. CHAMBERS:  Welcome,  everybody,  to  Fort




 3   Devens.   My name is James Chambers.   I'm  the  BRAC




 4   environmental coordinator for the U.S.  Army  here at




 5   Fort Devens.




 6            Tonight's hearing is in  regards  to  the




 7   remedial action proposed plan for Shepley's  Hill




 8   Landfill, and I'd like to open up the  floor  to




 9   comments.  We do have a court stenographer here




10   tonight to officially record your comments.




11            I'd like to recognize Ms.  Lynn Welsh from




12   the Massachusetts Department of Environmental




13   Protection; Mr. James Byrne of the  U.S.




14   Environmental Protection Agency;  Mr.  Gerry Keefe




15   from the U.S. Environmental Protection Agency;  Mr.




16   Charles George from the U.S. Army Environmental




17   Center;  and Mr. Paul Exner and Mr.  Stan Reed




18   representing ABB Environmental Services.




19            (Recess taken)




20            MR. CHAMBERS:  It's now  7:30.  Let  the




21   record show that we were prepared to  make a




22   presentation this evening and no  members  of  the




23   .public showed.




24            The 30th of June is the  last  day for
                   DORIS 0. WONG ASSOCIATES

-------
 1




 2




 3




 4




 5




 6




 7




 8




 9




10




11




12




13




14




15




16




17




18




19




20




21




22




23




24
submitting written comments.  Thank  you.



               (Whereupon, the hearing  was



              adjourned at  7:30 p.m.)
                   DORIS 0. WONG  ASSOCIATES

-------
 1




 2




 3




 4




 5




 6




 7




 8




 9




10




11




12




13




14




15




16




17




18




19




20




21




22




23




24
                   CERTIFICATE




         I, Robin Gross, Registered  Professional




Reporter, do hereby certify  that  the  foregoing




transcript, Volume I, is a true and  accurate




transcription of my stenographic  notes  taken  on June




27,  1995 .
                                 •f?
                        Robin Gross



                   Registered Professional  Reporter
                   DORIS  0.  WONG  ASSOCIATES

-------
0
X
o

-------
RECORD OF DECISION
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
             APPENDIX D - ADMINISTRATIVE RECORD INDEX
W0099518.080

-------
              Fort Devens

            Group  1A Sites
 Shepley's Hill Landfill Operable Unit
      Administrative Record File

                 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 Fort
Devens Group 1A Shepley's Hill Landfill Operable Unit. Section I of the Index
cites site-specific documents and Section II cites guidance documents used by U.S.
Army staff in selecting a response action at the site.  Some documents in this
Administrative Record File Index have been cited but not 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 Environmental
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 Realignment
and Closure Office (BRAC).

      The Administrative Record is required by the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act (SARA).
                               Page  1 of 22

-------
       Section I




Site-Specific Documents
     Page 3 of 22

-------
                ADMINISTRATIVE RECORD FILE INDEX

                                   for
                        Fort Devens Group 1A Site
                    Shepley's Hill Landfill Operable Unit

                      Compiled: September 29, 1995
1.0  Pre-Remedial

    1.2 Preliminary Assessment

        Cross Reference:  The following Reports, Comments, and Responses to
        Comments (entries 1 through 6) are filed and cited as entries 1 through
        6 in minor break 1.2 Preliminary Assessment of the Fort Devens Group
        1A 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.
GRP1A\SHP.IND                                                    September 1995
                               Page 5 of 22

-------
3.0  Remedial Investigation (RI)

    3.2  Sampling and Analysis Data

         Reports

         1.   Cross  Reference: "Method for Determining Background
             Concentrations - Inorganic Analytes in Soil and Groundwater - Fort
             Devens," ABB Environmental Services, Inc. (January 20, 1993)
             [Filed and cited as entry number 1 in minor break 3.2 Sampling
             and Analysis Data of the Fort Devens Group 1A Sites
             Administrative Record Index].

    3.4  Interim Deliverables

         The following Reports and Comments (entries 1 through 2) are filed
         and cited as entries 1 and 2 in minor break 3.4 of the Group 1A
         Administrative  Record Index File.

         Reports

         1.   "Final Ground Water Flow Model at Fort Devens," Engineering
             Technologies Associates, Inc. (May 24, 1993).

         Comments

         2.   Comments Dated February 1, 1993 from James P. Byrne, EPA
             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.

    3.5  Applicable or Relevant and Appropriate Requirements (ARARs)

         Cross Reference:  The following report (entries 2 and 3) are filed and
         cited as entries 1 and 2 in minor break 3.5 Applicable or Relevant and
         Appropriate  Requirements  (ARARs) of the Fort Devens Groups 3, 5, &
         6 Sites  Administrative Record  Index unless otherwise noted below.

         Reports

         1.   Cross Reference: "Draft Assessment of Chemical-Specific
             Applicable or Relevant and Appropriate Requirements (ARARs)
             for Shepley's Hill Landfill and Cold Spring Brook Landfill, Fort
             Devens, Massachusetts," U.S. Army Toxic and Hazardous Materials
             Agency  (May 21, 1992).  [Filed and cited as entry number 1  in

GRP1A\SHP.1ND                                                      September 1995
                                Page 6 of 22

-------
             minor break 3.5 Applicable or Relevant and Appropriate
             Requirements (ARARs) of the Fort Devens Group 1A Sites
             Administrative Record File Index].
        2.   "Draft Applicable or Relevant and Appropriate Requirements
             (ARARs) for CERCLA Remedial Actions," U.S.  Army Toxic and
             Hazardous Materials Agency (May 21, 1992).
        3.   "Draft Assessment of Location-Specific Applicable or Relevant and
             Appropriate Requirements (ARARs)  for Fort Devens,
             Massachusetts," U. S. Army Toxic and Hazardous Materials
             Agency (September 1992).
    3.6 Remedial Investigation (RI) Reports

        Cross Reference:  The following Reports, Comments, and Responses to
        Comments (entries 1 through  15) are filed and cited in minor break 3.6
        Remedial Investigation (RI) Reports of the Group 1A Administrative
        Record Index unless otherwise noted below.

        Reports

        1.   "Final Remedial Investigation Report, Group 1A - Volume I,"
             Ecology and Environment, Inc. (April 1993).
        2.   "Final Remedial Investigation Report, Group 1A - Volume II,"
             Ecology and Environment, Inc. (April 1993).
        3.   "Final Remedial Investigation Addendum Report - Volume I, "ABB
             Environmental Services, Inc.  (December 1993)
        4.   "Final Remedial Investigation Addendum Report - Volume II,
             "ABB Environmental Services, Inc. (December 1993)
        5.   "Final Remedial Investigation Addendum Report - Volume III,
             "ABB Environmental Services, Inc. (December 1993)
        6.   "Final Remedial Investigation Addendum Report - Volume IV,
             "ABB Environmental Services, Inc. (December 1993)

        Comments

        7.   Comments Dated February 8, 1993 from James P. Byrne, EPA
             Region I on the December 1992 "Draft Final Remedial
             Investigations Report," Ecology and Environment, Inc.
        8.   Comments Dated February 11, 1993 from D. Lynne  Chappell,
             Commonwealth of Massachusetts Department of Environmental
             Protection on the December 1992 "Draft Final Remedial
             Investigations Report," Ecology and Environment, Inc.
        9.   Comments Dated June 1, 1993 from James P. Byrne, EPA Region I
             on the April 1993 "Final  Remedial Investigation Report, Group 1A
             - Volume I-II," Ecology and Environment, Inc.

GRP1A\SHP.IND                                                    September 1995
                               Page 7 of 22

-------
        10.  Comments Dated June 18, 1993 from D. Lynne Chappell,
            Commonwealth of Massachusetts Department of Environmental
            Protection on the April 1993 "Final Remedial Investigation Report,
            Group 1A - Volume I-II," Ecology and Environment, Inc.
        11.  Comments Dated September 2,  1993 from James P. Byrne, EPA
            Region I on the July 26, 1993 "Draft Remedial Investigation
            Addendum Report," ABB Environmental Services, Inc.
        12.  Comments Dated September 9,  1993 from D. Lynne Welsh,
            Commonwealth of Massachusetts Department of Environmental
            Protection on the July 26, 1993 "Draft Remedial Investigation
            Addendum Report," ABB Environmental Services, Inc.
        13.  Comments Dated January 21, 1994 from Molly Elder,
            Commonwealth of Massachusetts Department of Environmental
            Protection on the December 21, 1993 "Final Remedial Investigation
            Addendum Report'" ABB Environmental Services, Inc.
        14.  Comments Dated February 15, 1994 from James P. Byrne, EPA
            Region I on the December 21, 1993 "Final Remedial Investigation
            Addendum Report," ABB Environmental Services, Inc.

        Responses to Comments

        15.  Responses Dated December 21, 1994 from U.S. Army
            Environmental Center on the following document:  "Draft
            Remedial Investigation Addendum Report," ABB Environmental
            Services, Inc.

    3.7  Work Plans and Progress Reports

        Cross Reference:  The following Reports, Comments, and  Responses to
        Comments (entries 1 through 3) are  filed and cited in minor break 3.7
        Work Plans and Progress Reports of the Group 1A Administrative
        Record Index unless otherwise noted below.

        Reports

        1.  "Final Work Plan and Field Sampling Plan - Remedial
            Investigation," Ecology and Environment, Inc. (February 1992).

        Comments

        2.  Letter from Carrol J. Howard, Fort Devens to D. Lynne Chappell,
            Commonwealth of  Massachusetts Department of Environmental
            Protection (March  3, 1992).  Concerning confirmation that the state
            is waiving its  right to comment on the  February 1992  "Final Work
            Plan and Field Sampling Plan - Remedial Investigation," Ecology
            and Environment, Inc.

GRP1A\SHP.1ND                                                     September 1995
                               Page 8 of 22

-------
         3.   Letter from James P. Byrne, EPA Region I to F. Timothy Prior,
             Fort Devens (March 19, 1992).  Concerning approval of the
             February 1992 "Final Work Plan and Field Sampling Plan -
             Remedial Investigation," Ecology and Environment, Inc.
4.0  Feasibility Study (FS)

    4.1  Correspondence
         Cross Reference: The following Letters and Comments (entries 1 and
         2) are filed and cited as entries 1 and 2 in minor break 4.1
         Correspondence of the Fort Devens Group 1A Sites Administrative
         Record Index.
    Letters

    1.   Letter Dated July 25, 1994 from James C. Chambers, Department of the
         Army, Headquarters Fort Devens, Brae Environmental Coordinator, on
         the Army's proposed triggers for implementing contingency remedial
         actions at the Shepley's Hill Landfill Operable Unit at Fort Devens.

    Comments

    2.   Comments Dated August 16, 1994 from D. Lynne Welsh,
         Commonwealth of Massachusetts Department of Environmental
         Protection on the Letter Dated July 25, 1994 from James C. Chambers
         on the Contingency Thresholds for Alternative SHL-2 at Shepley's Hill
         Landfill.

    4.4  Interim Deliverables

         Cross Reference: The following documents (entries 1 through 4) are
         filed  and cited as entries 1 through 4 in minor break 4.4 Interim
         Deliverables of the Group 1A Sites Administrative Record File Index.

         Reports

         1.   "Draft Alternatives Screening Report,"  ABB Environmental
             Services, Inc. (July 26, 1993).

         Comments

         2.   Comments Dated September 2, 1993 from James P. Byrne, EPA
             Region I on the July 26, 1993 "Draft Alternatives Screening
             Report." ABB Environmental Services, Inc.

GRP1A\SHP.IND                                                     September 1995
                               Page 9 of 22

-------
        3.   Comments Dated September 9, 1993 and September 20, 1993 from
             D. Lynne Welsh, Commonwealth of Massachusetts Department of
             Environmental Protection on the July 26, 1993 "Draft Alternatives
             Screening Report." ABB Environmental Services, Inc.

        Responses to Comments

        4.   Responses Dated March 18, 1994 from U.S. Army Environmental
             Center on the following document:  Draft Alternatives Screening
             Report, dated July 26, 1993.

    4.6  Feasibility Study (FS) Reports

        Cross Reference:  The following Letters, Reports,  Comments, Responses
        to Comments and Responses to  Responses to Comments (entries 1
        through 16) are filed and cited in minor break 4.6 Feasibility Study (FS)
        Reports of the Fort Devens Group 1A Sites Administrative Record
        Index.

        Reports

        1.   "Draft Feasibility Study Shepley's Hill Landfill Operable Unit,"
             ABB Environmental Services, Inc. (March 18, 1994).
        2.   "Revised Draft Feasibility Study,  Shepley's Hill Landfill Operable
             Unit, Fort Devens Feasibility Study for Group 1A Sites," ABB
             Environmental Services, Inc. (September 1994).
        3.   "Revised Draft Shepley's Hill Groundwater Operable Unit
             Feasibility Study and Contingency Triggers," (Letter Dated
             November 30, 1994 from Major Pease).
        4.   "Final Feasibility Study Shepley's Hill Landfill Operable Unit, Fort
             Devens Feasibility Study for Group 1A Sites," ABB Environmental
             Services, Inc. (February 1995).

        Comments

        5.   Comments Dated April 28,  1994 form James  P. Byrne, EPA Region
             I  on the March 18, 1994 "Draft Feasibility Study Shepley's Hill
             Landfill Operable Unit," (ABB Environmental Services, Inc.).
        6.   Comments Dated May 5, 1994 from D. Lynne Welsh,
             Commonwealth of Massachusetts Department of Environmental
             Protection on the March 18, 1994 "Draft Feasibility Study Shepley's
             Hill Landfill Operable Unit," (ABB Environmental Services, Inc.  ).
        7.   Comments Dated November 10,  1994 from James P. Byrne,
             USEPA, on the "Revised Draft Feasibility Study for Shepley's Hill
             Landfill Operable Unit,"  (ABB Environmental Services, Inc.).
GRP1A\SHP.IND                                                     September 1995
                               Page 10 of 22

-------
         8.   Comments Dated November 15, 1994 from D. Lynne Welsh,
             Commonwealth of Massachusetts Department of Environmental
             Protection on the September 1994 "Revised Draft Feasibility Study.
             Shepley's Hill Landfill Operable Unit,"  (ABB Environmental
             Services, Inc.).
         9.   Comments Dated January 11, 1995 from James P. Byrne, USEPA,
             on the "Revised Draft Feasibility Study for Shepley's Hill Landfill
             Operable Unit," ABB Environmental Services, Inc.
         10.  Comments Dated January 11, 1995 from James P. Byrne, USEPA,
             on the Proposed Feasibility Study Language For Alternative SHL-2,
             Shepley's Hill Landfill Source Control Operable Unit.
         11.  Comments Dated January 23, 1995 from D. Lynne Welsh,
             Commonwealth of Massachusetts Department of Environmental
             Protection on the November 30, 1994 "Revised Draft Shepley's  Hill
             Groundwater Operable Unit Feasibility Study and Contingency
             Triggers".
         12.  Comments Dated March 27, 1995 from  D. Lynne Welsh,
             Commonwealth of Massachusetts Department of Environmental
             Protection on the "Final Feasibility Study,  Shepley's Hill Landfill
             Operable Unit," (ABB Environmental Services, Inc.).

         Responses to Comments

         13.  Responses Dated September 1994 from U.S. Army Environmental
             Center on the following document: Draft Feasibility  Study Shepley's
             Hill Landfill Operable Unit, Feasibility  Study For Group 1A Sites,
             Fort Devens, Massachusetts.
         14.  Responses Dated February 1995 from U.S. Army Environmental
             Center on the following document: revised Draft Feasibility Study
             Shepley's Hill Landfill Operable Unit, Feasibility Study for Group
             1A Sites, Fort Devens, Massachusetts.

         Responses to Responses to Comments

         15.  Rebuttal Dated November 15, 1994 from D. Lynne Welsh,
             Commonwealth of Massachusetts Department of Environmental
             Protection on the Responses to Comments on the Draft Feasibility
             Study, Shepley's Hill Landfill Operable  Unit.
         16.  Responses Dated June 1995 from U.S. Army  Environmental Center
             on the following documents: Final Feasibility Study,  Draft
             Proposed Plan and Draft Fact Sheet Shepley's Hill Landfill
             Operable Unit.
GRP1A\SHP.IND                                                     September 1995
                               Page 11 of 22

-------
    4.7  Work Plans and Progress Reports

        Cross Reference: The following Reports, Comments, and Responses to
        Comments (entries 1 through 10) are filed and cited in minor break 4.7
        Work Plans and Progress Reports of the Fort Devens Group 1A Sites
        Administrative Record Index unless otherwise noted below.

        Reports

        1.   "Final Feasibility Study Work Plan," ABB Environmental Services,
            Inc. (August 1992).
        2.   "Final Data Gap Activity Work Plan," ABB Environmental Services,
            Inc. (March 31,  1993).

        Comments

        3.   Comments Dated September 14, 1992 from James P. Byrne, EPA
            Region I on the August 1992 "Final Feasibility Study Work Plan,"
            ABB Environmental Services, Inc.
        4.   Comments Dated September 21, 1992 from D. Lynne Chappell,
            Commonwealth of Massachusetts Department of Environmental
            Protection on the August 1992 "Final Feasibility Study Work Plan,"
            ABB Environmental Services, Inc.
        5.   Comments Dated January 11, 1993 from James P. Byrne, EPA
            Region I on the December 1992 "Draft Final Data Gap Activities
            Work Plan," ABB Environmental Services, Inc.
        6.   Comments Dated January 20, 1993 from D. Lynne Chappell,
            Commonwealth of Massachusetts Department of Environmental
            Protection on the December 1992 "Draft Final Data Gap Activities
            Work Plan," ABB Environmental Services, Inc.
        7.   Comments Dated February 17, 1993 from James P. Byrne, EPA
            Region I and D. Lynne  Chappell, Commonwealth of Massachusetts
            Department of Environmental  Protection on the December 1992
            "Draft Final Data Gap Activities Work Plan," ABB Environmental
            Services, Inc.
        8.   Comments Dated April 21, 1993 and April 26, 1993 from James P.
            Byrne, EPA Region I on the March  31, 1993 "Final Data Gap
            Activity Work Plan,"  ABB Environmental Services, Inc.
        9.   Comments Dated May 13, 1993 from D. Lynne Chappell on the
            March 31, 1993 "Final Data Gap Activity Work Plan," ABB
            Environmental Services, Inc.
GRP1A\SHP.1ND                                                    September 1995
                              Page 12 of 22

-------
         Responses to Comments

         10.  Responses Dated May 1993 from U.S. Army Environmental Center
             on the following document:  Final Data Gap Activity Work Plan,
             dated March 31, 1993.

    4.9  Proposed Plan for Selected Remedial Action

         1.   Cross Reference: "Draft Proposed Plan, Shepley's Hill Landfill
             AOCs 4,5, & 18, Fort Devens, Massachusetts," ABB Environmental
             Services, Inc. (February 1995). [Filed and cited as entry number 1
             in minor break 4.9 Proposed Plan for Selected Remedial Action in
             the Fort Devens Group 1A Sites Administrative Record File Index.]
         2.   Cross Reference: "Proposed Plan,  Shepley's Hill Landfill AOCs 4,
             5, & 18, Fort Devens, Massachusetts," ABB Environmental Services,
             Inc. (May 1995).  [Filed and cited as entry  number 2 in minor
             break 4.9 Proposed Plan for Selected Remedial Action in the Fort
             Devens Group 1A Sites Administrative Record File Index.]

         Comments

         3.   Cross Reference: Comments Dated March 30, 1995 from D. Lynne
             Welsh, Commonwealth of Massachusetts Department of
             Environmental Protection on the February 1995 "Draft Proposed
             Plan, Shepley's Hill Landfill," (ABB Environmental Services, Inc.).
             [Filed and cited as entry number 3 in minor break 4.9 Proposed
             Plan for Selected Remedial Action in the Fort Devens  Group 1A
             Sites Administrative Record File Index.]
         4.   Cross Reference: Comments Dated July 17, 1995 from D. Lynne
             Welsh, Commonwealth of Massachusetts Department of
             Environmental Protection on the May 1995 Proposed Plan for
             Shepley's Hill Landfill Operable Unit, Fort Devens, Massachusetts
             (ABB Environmental Services, Inc.).

         Responses to Comments

         5.   Cross Reference: Responses Dated June 1995 from U.S. Army
             Environmental Center on the following documents: Final
             Feasibility Study, Draft Proposed Plan and Draft Fact Sheet
             Shepley's Hill Landfill Operable Unit. [Filed and cited as entry
             number 19 in minor break 4.6 Proposed Plan for Selected
             Remedial Action in the Fort Devens Group 1A Sites
             Administrative Record File Index.]
GRP1A\SHP.IND                                                      September 1995
                               Page 13 of 22

-------
5.0 Record of Decision

         Cross Reference: The following Reports, Comments, and Responses to
         Comments (entries 1 through 6) are filed and cited in minor break 5.4
         Record of Decision of the Fort Devens Group 1A Sites Administrative
         Record Index unless otherwise noted below.

    5.4  Record of Decision

         Reports

         1.   "Draft Record of Decision Shepley's Hill Landfill Operable Unit,
             Fort Devens, Massachusetts", ABB Environmental Services, Inc.
             (July 1995).
         2.   "Revised Draft Record of Decision Shepley's Hill Landfill Operable
             Unit, Fort Devens, Massachusetts", ABB Environmental Services,
             Inc. (August 1995).
         3.   "Final Record of Decision Shepley's Hill Landfill Operable Unit,
             Fort Devens, Massachusetts", ABB Environmental Services, Inc.
             (September 1995).

         Comments

         4.   Comments Dated August 17, 1995 from James P. Byrne, USEPA
             Region I on the July 1995 Draft Record of Decision for Shepley's
             Hill Landfill Operable Unit, Fort Devens, Massachusetts (ABB
             Environmental Services, Inc.).
         5.   Comments Dated August 18, 1995 from D. Lynne Welsh,
             Commonwealth of Massachusetts Department of Environmental
             Protection on the July 1995 Draft Record of Decision, Shepley's
             Hill Landfill Operable Unit, Fort Devens, Massachusetts (ABB
             Environmental Services, Inc.).
         6.   Comments Dated September 13, 1995 from James  P. Byrne,
             USEPA Region I on the August 1995  Revised Draft Record  of
             Decision Shepley's Hill Landfill Operable Unit, Fort Devens,
             Massachusetts (ABB Environmental Services, Inc.).
GRP1A\SHP.IND                                                      September 1995
                               Page 14 of 22

-------
6.0  Remedial Design (RD)

    6.6  Work Plans and Progress Reports

         Cross Reference: The following Reports and Comments (entries 1
         through 3) are filed and cited in minor break 6.6 Remedial Design (RD)
         Work Plans and Progress Reports of the Fort Devens Group 1A Sites
         Administrative Record Index unless otherwise noted below.

         Reports

         1.   "Final Delivery Order Work Plan for Predesign Investigations,
             Areas of Contamination (AOCs) 4, 5, & 18 Shepley's Hill Landfill,
             Fort Devens, Massachusetts," Stone & Webster Environmental
             Technology & Services (June 1995).

         Comments

         2.   Comments Dated July 11, 1995 from James P. Byrne, USEPA
             Region I on the June 1995 Final Delivery Order Work Plan for
             Predesign Investigations Shepley's Hill Landfill, Fort Devens,
             Massachusetts" (Stone & Webster Environmental Technology &
             Services).
         3.   Comments Dated July 26, 1995 from D. Lynne Welsh,
             Commonwealth of Massachusetts Department of Environmental
             Protection on the June 1995 Final Delivery Order Work Plan,
             Areas of Contamination (AOCs) 4, 5, & 8, Shepley's Hill Landfill
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 Facility Agreements
             of the Fort Devens Group 1A  Sites Administrative Record Index].
GRP1A\SHP.IND                                                      September 1995
                               Page 15 of 22

-------
13.0  Community Relations

    13.2 Community Relations Plans

        Reports

        1.   Cross Reference: "Final Community Relations Plan," Ecology and
             Environment, Inc. (February 1992) [Filed and cited as entry number
             1 in minor break 13.2 Community Relations Plans  of the Fort
             Devens Group 1A Sites Administrative Record Index].
        2.   Cross Reference: "Fort Devens Community Relations Plan for
             Environmental Restoration, 1995 Update," ABB Environmental
             Services, Inc. (May  1995).  [Filed and cited as entry number 2 in
             minor break 13.2 Community Relations Plans of the Fort Devens
             Group 1A Sites Administrative Record Index].

        Comments

        3.   Cross Reference: Letter from James P. Byrne, EPA Region I to F.
             Timothy Prior, Fort Devens (March 19, 1992). Concerning
             approval of the February 1992 "Final Community Relations Plan,"
             Ecology and Environment, Inc. [Filed and cited as  entry number 2
             in minor break 13.2 Community Relations Plans of the Fort Devens
             Group 1A Sites Administrative Record Index].
        4.   Cross Reference: Comments Dated July 17, 1995 from James P.
             Byrne, USEPA, Region I, on  the May 1995  Fort Devens
             Community Relations Plan for Environmental Restoration, 1995
             Update (ABB Environmental Services, Inc.).  [Filed and cited as
             entry number 4 in minor break 13.2 Community Relations Plans of
             the Fort Devens Group 1A Sites Administrative Record Index].

    13.5 Fact Sheets

         1.   Cross Reference: "Shepley's Hill Landfill Draft Fact Sheet, Fort
             Devens, Massachusetts," ABB Environmental Services, Inc.
             (February 1995). [Filed and cited as entry number  1 in minor break
             13.5  Fact Sheets of the Group 1A Sites Administrative Record File
             Index.]
        2.   Cross Reference: "Fact Sheet 2, Shepley's Hill Landfill Proposed
             Plan, Fort Devens,  Massachusetts Environmental Restoration
             Program," ABB Environmental Services, Inc. (May 1995).  [Filed
             and cited as entry number 2 in minor break 13.5 Fact Sheets of the
             Group 1A Sites Administrative Record File Index.]
GRP1A\SHP.IND                                                      September 1995
                               Page 16 of 22

-------
        Comments

        3.   Cross Reference:  Comments Dated March 30, 1995 from D. Lynne
             Welsh, Commonwealth of Massachusetts Department of
             Environmental Protection on the February 1995 "Shepley's Hill
             Landfill Draft Fact Sheet, Fort Devens, Massachusetts," (ABB
             Environmental Services, Inc.). [Filed and cited as entry number 3
             in minor break 13.5 Fact Sheets of the Group 1A Sites
             Administrative Record File Index.]

        Responses to Comments

        4.   Cross Reference:  Responses Dated June 1995 from U.S. Army
             Environmental Center on the Final Feasibility Study, Draft
             Proposed Plan and the Draft Fact Sheet, Shepley's Hill Landfill
             Operable Unit, Fort Devens, Massachusetts.  [Filed and cited as
             entry number 19 in minor break 4.6 Feasibility Study Reports of the
             Group 1A Sites Administrative Record File Index.]

    13.11     Technical Review Committee Documents

        Cross Reference:  The following Reports, Comments, and Responses to
        Comments (entries 1 through 8) are filed and cited in minor break 13.11
        Technical Review Committee Documents of the Group 1A
        Administrative Record Index unless otherwise noted below.

        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).
GRP1A\SHP.IND                                                     September 1995
                              Page 17 of 22

-------
17.0  Site Management Records

    17.6 Site Management Plans

    Cross-Reference: The following Reports, Comments, and Responses to
    Comments (entries  1 through 9) are filed and cited in minor break 17.6 Site
    Management Records of the Groups 3, 5, & 6 Administrative Record Index
    unless otherwise noted below.

        Reports

        1.   "Final Quality  Assurance Project Plan," Ecology and Environment,
             Inc. (November 1991).
        2.   "General Management Procedures, Excavated Waste Site Soils,
             Fort Devens, Massachusetts," ABB Environmental Services, Inc.
             (January 1994).
        3.   "Final Project  Operations Plan, Fort Devens, Massachusetts", ABB
             Environmental Services, Inc. (May 1995).
        4.   "Project Operations Plan, Fort Devens, Massachusetts," ABB
             Environmental Services, Inc. (June 1995).

        Comments

        5.   Cross Reference: Comments from James P. Byrne, EPA Region I
             on the November 1991  "Final Quality Assurance Project Plan,"
             Ecology and Environment, Inc. [These Comments are filed and
             cited as a part of entry number 8 in the Responses to Comments
             section of this minor break].
        6.   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.
        7.   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 Deliverables of the
             AOCs 44/52 Administrative Record Index.]
        8.   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.
GRP1A\SHP.IND                                                     September 1995
                               Page 18 of 22

-------
         Responses to Comments

         9.   Cross-Reference: 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 25, 1994. [These Responses to Comments are filed and
             cited as a part of entry number 7 in the Responses to Comments
             section of minor break 4.4 Interim Deliverables of the AOCs 44/52
             Administrative Record Index.]

         Responses to Comments

         10.  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.
         11.  Cross-Reference: U.S. Army Environmental Center Responses to
             Comments for 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 entry number 8 in the Responses to
             Comments section of minor break 4.4  Interim Deliverables of the
             AOCs 44/52 Administrative Record Index.]

    17.9     Site Safety Plans

         Cross Reference: The following Reports and Comments (entries 1
         through 3) are filed and cited as entries 1 through 3 in minor break 17.9
         Site Safety Plans of the Group  1A Sites Administrative  Record File
         Index unless otherwise noted below.]

         Reports

         1.   "Final Health and Safety Plan," Ecology and Environment, Inc.
             (November 1991).

         Comments

         2.   Cross Reference: Comments from James P. Byrne, EPA Region I
             on the November 1991 "Final Health and Safety Plan," Ecology and
             Environment, Inc. [These Comments are filed and cited  as a part of
             entry number 8 in minor break 17.6 Site Management Plans of the
             Group 1A Sites Administrative Record File Index].

GRP1A\SHP.IND                                                     September 1995
                               Page 19 of 22

-------
        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.
            Reports
GRP1A\SHP.IND                                                    September 1995
                              Page 20 of 22

-------
                                   Section II

                             Guidance Documents
GRP1A\SHP.IND                                                         September 1995
                                 Page 21 of 22

-------
                       GUIDANCE DOCUMENTS

The following guidance documents were relied upon during the Fort Devens
cleanup. These documents may be reviewed, by appointment only, at the
Environmental Management Office at Fort Devens, Massachusetts.

1.   Occupational Safety and Health Administration (OSHA).  Hazardous Waste
    Operation and Emergency Response (Final Rule, 29 CFR Part 1910, Federal
    Register. Volume 54, Number 42) March 6, 1989.
2.   USATHAMA. Geotechnical Requirements for Drilling Monitoring Well.
    Data Acquisition, and Reports. March 1987.
3.   USATHAMA. IRDMIS User's Manual. Version 4.2, April 1991.
4.   USATHAMA. USATHAMA Quality Assurance Program: PAM-41. January
    1990.
5.   USATHAMA. Draft Underground Storage Tank Removal Protocol - Fort
    Devens. Massachusetts.  December 4, 1992.
6.   U.S. Environmental Protection Agency.  Guidance for Preparation of
    Combined Work/Quality Assurance Project Plans for Environmental
    Monitoring:  OWRS OA-1. May 1984.
7.   U.S. Environmental Protection Agency.  Office of Research and
    Development Interim Guidelines and Specifications for Preparing Quality
    Assurance Project Plans: QAMS-005/80. 1983.
8.   U.S. Environmental Protection Agency.  Office of Emergency and Remedial
    Response. Interim Final Guidance for Conducting Remedial Investigations
    and Feasibility Studies  Under CERCLA  (OSWER Directive 9355.3-01,
    EPA/540/3-89/004, 1986.
9.   U.S. Environmental Protection Agency.  Test Methods for Evaluating Solid
    Waste:  EPA SW-846 Third  Edition. September 1986.
10.  U.S. Environmental Protection Agency.  Office of Emergency and Remedial
    Response. Risk Assessment Guidance for Superfund. Volume I. Human
    Health Evaluation Manual (Part A). (EPA/540/1-89/002), 1989.
11.  U.S. Environmental Protection Agency.  Hazardous Waste Management
    System: Identification and Listing of Hazardous Waste: Toxicity
    Characteristic Revisions. (Final  Rule, 40 CFR Part 261 et al, Federal
    Register Part V), June 29, 1990.
GRP1A\SHP.IND                                                    September 1995
                              Page 22 of 22

-------
•o
-o

-------
RECORD OF DECISION
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
         APPENDIX E - DECLARATION OF STATE CONCURRENCE
W0099518.080

-------
                        1 508 792 7621

09-25-1995 11=11    1 508 792 7621         MASS.  DEP/CENTRAL REGION          P. 02
              Conrnonwealth of Massachusetts
              Executive Office of Environmental Affaire
              Department  of
              Environmental Protection
              Central Regional Office
   September 18,  1995

   Mr.  John De Villars
   Regional Administrator
   U.S.  Environmental Protection Agency
   Region I
   JFR  Federal Building
   Boston,  MA 02203

   RE:   ROD Concurrence,  Shefcley's Hill Landfill, AOCs 4, 5 and 18,
        Fort Devens, MA

   Dear Mr.  De Villars:

        The Massachusetts Department of Environmental Protection
   (MADEP)  has reviewed the preferred remedial alternative
   recommended by the Aray and the EPA for the final cleanup of the
   Shepley's Hill Landfill, 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 landfill as one operable unit and include* ftjfes following  **»
   components:

             e   Completion of any outstanding closure requirements
                 identified under 310 CMR 19.000;,

             e   Survey  of Shepley's Hill Landfill;

             e   Evaluation/improvement of stormwater diversion and
                 drainage;

             e1   Landfill cover maintenance;

             e   Long-term groundwater and landfill gas monitoring;

             e   Institutional controls;

             •   Educational programs;

                                 •  MX(BM)m-7ftK1  •  TiliptiDBi BJPD m-TM*

-------
                              a^ 7b21

O9-25-1995 11:12    1 508 792 7621         MASS. DEP/CENTRAL REGION          P. 03
   ROD Concurrence
   Fort Devens, MA
   September 18, 1995
   Page 2


             •    Design of groundwater  extraction  system;

             •    Annual reporting  to MADEP  and USEPA;  and

             •    Five-year site reviews.

        The MADEP'e concurrence with the preferred  remedial
   alternative is based upon the expectation that it will result in
   a permanent solution a0 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 Port
   Devexia Remedial Project Manager, Jim  Byrne, for  their efforts to
   ensure that the Massachusetts environmental requirements 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 questions, please contact Lynne
   Welsh at (508) 792-7653, ext. 3851.
                                      Sincerely,
                                      Cornelius .yf* Leazy
                                      Regional Director
                                      MADBP, CERO
   cc: Fort Devens Mailing List  (cover letter only)
       Edward Kunce, MADEP
       Jay Naparstek, MADEP
       informational Repositories
       Jim Byrne, EPA
       Charles George, ABC
       Mark Applebee, ACOB
       Judy Kohn, Mass Land Bank

-------

-------
RECORD OF DECISION
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
      APPENDIX F - GLOSSARY OF ACRONYMS AND ABBREVIATIONS
W0099518.080

-------
                               GLOSSARY OF ACRONYMS AND ABBREVIATIONS
AOC
ARAR
AWQC

BRAC

CAC
CERCLA

CFR
CMR

ODD
DDE
DDT
DRMO

FS

HI

IAG
IRP

MADEP
MCL
MEP

MOD
MMCL

NPL
NCP
NPDES

PCB
POTW
ppb
PVC
Area of Contamination
Applicable or Relevant and Appropriate Requirement
Ambient Water Quality Criteria

Base Realignment and Closure Act

Citizen's Advisory Committee
Comprehensive Environmental Response, Compensation, and
Liability Act
Code of Federal Regulations
Code of Massachusetts Regulations

2,2-bis(para-chlorophenyl)-l,l-dichloroethane
2,2-bis(para-chlorophenyl)-l,l-dichloroethene
2,2-bis(para-chlorophenyl)-1,1,1 -trichlor oethane
Defense Reutilization and Marketing Office

Feasibility Study

Hazard  Index

Interagency Agreement
Installation Restoration Program

Massachusetts Department of Environmental Protection
Maximum Contaminant Level
Master Environmental Plan

million gallons per day
Massachusetts Maximum Contaminant Level

National Priorities List
National Contingency Plan
National Pollutant Discharge Elimination System

poly chlorinated biphenyl
publicly owned treatment works
parts per billion
polyvinyl chloride
W0099518.080

-------
GLOSSARY OF ACRONYMS AND ABBREVIATIONS
RAB
RCRA
RfD
RI

SA
SARA
SVOC

TAL
TCL
TOC
TRC
USAEC
USEPA

VOC
Restoration Advisory Board
Resource Conservation and Recovery Act
Reference Dose
remedial investigation

Study Area
Superfund Amendments and Reauthorization Act of 1986
semivolatile organic compound

Target Analyte List
Target Compound list
total organic carbon
Technical Review Committee

micrograms per liter
U.S. Army Environmental Center
U.S. Environmental Protection Agency

volatile organic compound
W0099518.080

-------