EPA/ROD/R01-95/113
1995
EPA Superfund
Record of Decision:
FORT DEVENS
EPA ID: MA7210025154
OU01
FORT DEVENS, MA
09/26/1995
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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5, 1 Feb 93 replaces THAMA Form *»5 which is obsolete.
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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.
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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
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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.
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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.
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RECORD OF DECISION
SHEPLEY'S HILL LANDFILL OPERABLE UNIT
AREAS OF CONTAMINATION 4, 5, AND 18
FORT DEVENS, MASSACHUSETTS
SEPTEMBER 1995
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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
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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
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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
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DECLARATION FOR THE RECORD OF DECISION
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
W0099518.080
iv
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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
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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
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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
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DECLARATION FOR THE RECORD OF DECISION
S hep ley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
W0099518.080
viii
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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.
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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.
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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
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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
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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
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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.
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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
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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
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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.
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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.
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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.
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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
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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:
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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;
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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.
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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;
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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
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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.
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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
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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.
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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
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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
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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.
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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.
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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
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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.
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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.
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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.
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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
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Shepley's Hill Landfill Operable Unit
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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
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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.
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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
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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.
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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
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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
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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
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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,
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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:
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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)
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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.
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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
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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
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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.
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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
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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.
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T3
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RECORD OF DECISION
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
APPENDIX A - FIGURES
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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
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(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
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(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
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(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
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(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
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(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
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RECORD OF DECISION
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
APPENDIX C - RESPONSIVENESS SUMMARY
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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.
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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
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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
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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
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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
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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
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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
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RESPONSIVENESS SUMMARY
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
ATTACHMENT A - PUBLIC HEARING TRANSCRIPT
W0099518.080
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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
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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
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submitting written comments. Thank you.
(Whereupon, the hearing was
adjourned at 7:30 p.m.)
DORIS 0. WONG ASSOCIATES
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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
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0
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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
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Section I
Site-Specific Documents
Page 3 of 22
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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Section II
Guidance Documents
GRP1A\SHP.IND September 1995
Page 21 of 22
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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
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•o
-o
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RECORD OF DECISION
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
APPENDIX E - DECLARATION OF STATE CONCURRENCE
W0099518.080
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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*
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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
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RECORD OF DECISION
Shepley's Hill Landfill Operable Unit
Fort Devens, Massachusetts
APPENDIX F - GLOSSARY OF ACRONYMS AND ABBREVIATIONS
W0099518.080
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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
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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
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