Superfund Record of Decision Fort Devens-Sudbury Training Annex Operable Units 4 and 5 Middlesex County Massachusetts


                                    EPA/ROD/R01-96/118
                                    1996
EPA Superfund
     Record of Decision:
     FORT DEVENS-SUDBURY TRAINING ANNEX
     EPA ID: MAD980520670
     OU 04, 05
     SUDBURY, MA
     09/30/1996

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                         RECORD OF DECISION
                       OIERABIiE UNITS 4 AND  5
                       SUDBURY TRAINING ANNEX
                   MIDDIiESEX COUNTY, MASSACHUSETTS

                          SEPTEMBER 1996

                         RECORD OF DECISION
                       OPERABLE UNITS 4 AND  5
               SUDBURY TRAINING ANNEX, MASSACHUSETTS

                         TABIiE OF CONTENTS
Section                         Title                          Page No.

DECLARATION FOR THE RECORD OF DECISION  	V

1.0  SITE NAME, LOCATION, AND DESCRIPTION  	 1-1

2 . 0  SITE HISTORY AND ENFORCEMENT ACTIVITIES	 2-1

     2 .1  LAND USE AND RESPONSE HISTORY   	 2-1
          2.1.1  OU 4 	 2-1
          2.1.2  OU 5 	 2-4
     2 .2  ENFORCEMENT HISTORY 	 2-6

3.0  COMMUNITY PARTICIPATION 	 3-1

4.0  SCOPE AND ROLE OF RESPONSE ACTION  	 4-1

5.0  SUMMARY OF SITE CHARACTERISTICS  	 5-1

     5.1  OU 4 	 5-1
     5.2  OU 5 	 5-2

6.0  SUMMARY OF SITE RISKS 	 6-1

     6.1  SUMMARY OF RISKS AT OU 4  	 6-2
          6.1.1  Human Health Risk Assessment  Summary 	 6-2
          6.1.2  Ecological Risk Assessment  Summary 	 6-7
     6.2  SUMMARY OF RISKS AT OU 5  	 6-8
          6.2.1  Human Health Risk Assessment  Summary 	 6-8
          6.2.2  Ecological Risk Assessment  Summary 	6-13

7.0  DESCRIPTION OF THE NO ACTION ALTERNATIVE  	 7-1

8.0  DOCUMENTATION OF NO SIGNIFICANT CHANGES  	 8-1

9.0  STATE ROLE 	 9-1

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                         RECORD OF DECISION
                       OPERABLE UNITS 4 AND 5
                SUDBURY TRAINING ANNEX, MASSACHUSETTS
APPENDICES
APPENDIX A
APPENDIX B
APPENDIX C
APPENDIX D
TRANSCRIPT OF PUBLIC MEETING
RESPONSIVENESS SUMMARY
ADMINISTRATIVE RECORD INDEX
MASSACHUSETTS DEPARTMENT OF
ENVIRONMENTAL PROTECTION LETTER OF
CONCURRENCE
                         LIST OF FIGURES
Figure
               Title
                                             Page No.
1-1  Location of Operable Units 4 and 5  	  1-2
2-1  Site Plan - Operable Unit 4  (Sites  P11/P13)  	  2-2
2-2  Site Plan - Operable Unit 5  (Sites A12/P36/P37)  	  2-5

                             LIST OF TABLES


Table                              Title                           Page No.

6-1  Contaminants of Potential Concern - OU 4  	  6-3
6-2  Summary of Excess Cancer Risks Associated With OU 4  	 6-5
6-3  Summary of Estimated Hazard Indices for Noncarcinogenic Effects
     Associated With OU 4 	  6-6
6-4  Contaminants of Potential Concern - OU 5  	  6-9
6-5  Summary of Excess Cancer Risks Associated With OU 5  	 6-11
6-6  Summary of Estimated Hazard Indices for Noncarcinogenic Effects
     Associated With OU 5 	 6-12

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DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

Operable Units 4 and 5
Sudbury Training Annex
Middlesex County, Massachusetts

STATEMENT OF PURPOSE AND BASIS

This decision document presents the decision for No Action at Operable Units (OUs) 4 and 5, Sudbury
Training Annex, Middlesex County, Massachusetts. It was developed in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act of 1980 (CERCLA) as amended, 41 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 Sudbury Training Annex Base Realignment and closure (BRAG) Environmental
Coordinator; the Installation commander; and the Director of the Office of Site Remediation and
Restoration, U.S. Environmental Protection Agency New England (USEPA) 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 BRAG
Environmental Office, Building P12, Fort Devens, Massachusetts, and at the Sudbury, Massachusetts Town
Hall.

DESCRIPTION OF THE SELECTED REMEDY: NO ACTION

The U.S. Army and USEPA, with concurrence of the Massachusetts Department of Environmental Protection
(MADEP), have determined that No Action under CERCLA is necessary to address contamination at OU 4 and OU
5. However, the Army will close the septic tank behind Building T104 at OU 5 under state regulations.

DECLARATION

The U.S. Army and the USEPA, with concurrence of the MADEP, have determined that no remedial action under
CERCLA is necessary at OU 4 and OUS. OU 4, located in the northwestern corner of the Annex and consisting
of the two areas Pll and P13, was reportedly used for research and development of military materials such
as framed plastic and organic chemicals. OU 5, located in the southeastern corner of the Annex and
consisting of the three areas A12, P36, and P37, was reportedly used for research and development of
missile guidance and radar systems, and for assembly of electronic eguipment. As this is a decision for No
Action under CERCLA, the statutory reguirements of CERCLA Section 121 for remedial actions are not
applicable, and no five-year review will be undertaken.

The foregoing represents the decision for no 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

Concur and recommend for immediate implementation:

The foregoing represents the decision for No 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:

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

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SECTION 1

1.0 SITE NAME, LOCATION, AND DESCRIPTION

Sudbury Training Annex (Annex) is a National Priorities List (NPL) site under the Comprehensive
Environmental Response, compensation and Liability Act (CERCLA). The Annex is located 20 miles west of
Boston, one mile south of Maynard, and two miles northwest of the Town of Sudbury, in Middlesex County,
Massachusetts. The installation includes portions of the towns of Maynard, Hudson, Marlborough, Stow, and
Sudbury. The installation covers approximately 4.3 square miles (2,292 acres). Hudson Road divides the
installation into two equal sections: the larger, northern section, and the smaller, southern section.

There are currently several areas of concern within the Annex under investigation. The areas of concern at
the Annex have been organized into Operable Units (OUs) for investigation and remediation purposes. This
Record of Decision (ROD) relates to No CERCLA Action at OU 4 and OU 5. OU 4, located in the northern
portion of the Annex, consists of adjacent Areas Pll and P13. OU 5, located in the southern portion of the
Annex, consists of adjacent Areas A12, P36, and P37 (Figure 1-1).

The Annex was placed on the base closure list in September 1995. Except for an area retained for Army
housing, the Annex will be transferred entirely to three federal agencies. The majority of the land has
been requested by the U.S. Fish and Wildlife Service (USFWS) and will become part of the Great Meadows
Wildlife Refuge. The Air Force and the Federal Emergency Management Agency (FEMA) have also requested
small parcels to continue their existing operations.

A more complete description of the Annex can be found in the Final Remedial Investigation (RI) Report,
December 1995, Volume I, Subsection 2.2 More complete descriptions of OUs 4 and 5 can be found in the
Final RI Report, December 1995, Volume II, Section 3 and Volume III, Section 3, respectively. The RI
Report is available for review at the Base Realignment and Closure (BRAG) Environmental Office at Fort
Devens, and the town libraries in Hudson, Maynard, Stow, and Sudbury.

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Six buildings have been removed from the site leaving only foundations (Buildings T401, T402, T403, T419,
T461, and T466). Most of these buildings were demolished in the 1960s. For the most part, these
foundations have been obscured and are now overgrown with grass.

The area along White Pond Road has been used extensively by varying units for field test activities,
starting in 1952 and continuing until as late as 1991. Probable and confirmed uses of the site include:
farming; ordnance research and development; laboratory research on foamed plastics, organic chemicals,
flame testing, meteorological projects, and insecticide and rodenticide research; and training of
Massachusetts State Police, Massachusetts Air National Guard, Massachusetts Army National Guard, and
Massachusetts Fire Fighting Academy (MFFA) units. The area was the location of a farm prior to Army use,
and some of the buildings later used by the Army were converted from farm use.

Removal actions at OU 4 were conducted in 1991 and 1992.

1991. The Army removed several empty drums from OU 4 and relocated them to the temporary drum storage
area, the former MFFA training area, located at the site's north end.

1992. In 1992, several above ground storage tanks (ASTs) were removed by Fort Devens personnel from near
Buildings T406 and T410.

Six underground storage tanks (USTs) were removed by the Army in 1992. In addition to removing the tanks
from the ground, the soil surrounding the tanks was tested for the presence of oil and hazardous material.
Petroleum-contaminated soil detected in the tank areas was removed.

A more detailed description of OU 4 site history can be found in Volume II, Section 1.0 of the Remedial
Investigation Report, December 1995. The RI Report is available for review at the BRAG Environmental
Office at Fort Devens, and the town libraries in Hudson, Maynard, Stow and Sudbury.

2.1.2 OU 5

OU 5 (Areas A12, P36, and P37) is located in the southeastern corner of the annex, on the south side of the
Old Marlboro Road near the termination of the Diagonal Road. An OU 5 site map is shown in Figure 2-2. The
site consists of an area approximately 1,000 feet long by up to 250 feet wide along a northeast to
southwest axis along the south side of Old Marlboro road. The site contains two fabricated metal
buildings, T104 and T106, which were constructed in 1958. The site formerly contained a 40 foot high metal
detection tower that was designated Building T103.

OU 5 is located on the site of a low hill of glacial till identified was a ground moraine or as a drumlin,
which slopes gently to a surrounding outwash plain. This layer of outwash material gradually thickens
toward the east and the wetlands area to the east-northeast to greater than 21 feet thick. Bedrock was not
encountered during any drilling activities at the site; however, it appears that bedrock topography is
sub-parallel to surface topography. Bedrock elevations appear to range from approximately 40 to 60 feet
below ground surface.

Building T103, the 40 foot metal detection tower, was formerly located approximately 100 feet southeast of
Building T104. The tower was disassembled sometime after 1971, although the concrete footings, electrical
connections, and various debris from the tower are scattered around its former location.

The likely use of Building T104 was for research and development of missile guidance and radar systems, and
the likely use of Building T106 was for the assembly of electronic eguipment. Building T104 was also used
from sometime prior to 1982 to July 1985 for the staging of transformers.

In July 1985, Fort Devens personnel discovered that a transformer staged near Building T104 had leaked
oil-containing polychlorinated biphenyls (PCBs) from a bullet hole puncture. An estimated 100 to 200
gallons of PCB oil were released onto the ground.

That month, the remaining 300 gallons of fluid were removed from the leaking transformer, and 75 tons of
visibly contaminated soil were excavated from the release areas. Additional soil removals performed from
September through November 1985 and in June and July 1986 increased the total amount of soil removed to
over 175 tons.

In December 1988, the 10,000 gallon UST located near the southeastern corner of Building T104 was removed.
This UST had contained No. 2 fuel oil. No visibly contaminated soils or odors were noted.

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In December 1988, a 1,000-gallon UST used to store No. 2 Fuel Oil was removed from the northeastern corner
of Building T106.  Prior to the excavation, 75 gallons of waste oil were removed from the tank.  The UST
was reported to be in poor condition, with extensive corrosion and a 1-inch hole located in the side of the
tank directly below the fill line.  The soil surrounding the tank prior to removal was stained and emanated
strong petroleum odors.  Sixteen cubic yards of soil were removed from the tank pull area.

A more detailed description of OU 5 site history can be found in Volume III, section 1.0 of the Remedial
Investigation Report, December 1995.  The RI Report is available for review at the BRAG Environmental
Office at Fort Devens, and the town libraries in Hudson, Maynard, Stow, and Sudbury.

2.2  ENFORCEMENT HISTORY

Site investigation activities at the Annex have been conducted in accordance with the Inter-Agency
Agreement between the United States Army and the USEPA under CERCLA.  The USEPA analysis of the Annex was
based in part on ongoing Army environmental studies under the Defense Environmental Restoration Program
(DERP) .

On January 29, 1987, the Annex was classified as a Federal facility under the jurisdiction, custody, and
control of the Department of Defense (DoD), within the meaning of Executive Order 12580, 52 Federal
Regulations 2923, and within the meaning of the DERP, 10 U.S.C., Section 2701 et seg.  The Master
Environmental Plan  (MEP),  a key element in the attainment of DERP goals, was authored by OHM Remediation
Services Corp. (OHM) in 1992, and updated by Ecology and Environment, Inc.  (E&E) in 1993, and ABB
Environmental Services, Inc. (ABB-ES) in 1995.

The Annex was included in the USEPA NPL Update No. 9 in the July 14, 1989 Federal Register.  On February
21, 1990, the Annex was placed on the NPL.

NUS Corporation  (1985/1987), as a contractor to USEPA, conducted a preliminary assessment/site
investigation (PA/SI) at the Annex to fulfill CERCLA reguirements. Individual sites comprising the sturdy
areas addressed in this ROD were grouped into Areas OU 4 and OU 5 as a result of Phase I Site
Investigations (Sis) performed by OHM between 1990 and 1992, and Phase II Sis performed by E&E in 1993 and
1994. Remedial Investigations at OU 4 and OU 5 were carried out by E&E in 1993 and 1994.

3.0  COMMUNITY PARTICIPATION

The Army has held guarterly public Technical Review Committee (TRC) meetings, issued newsletters and press
releases, and held a number of public meetings to keep the community and other interested parties informed
of activities at the Sudbury Annex.

In April 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 Sudbury Annex.  As part of this plan, the Army established a TRC, which first met May 13, 1991.  The
TRC, as reguired by the Superfund Amendments and Reauthorization Act of 1986 (SARA) Section 211 and Army
Regulation 200-1, included representatives from USEPA, U.S. Army Environmental Center (USAEC), Fort Devens,
MADEP, U.S. Army Corp of Engineers  (USCOE), local officials, and the community.  The TRC generally met
guarterly to review and provide technical comments on schedules, work plans, work products, and proposed
activities for the study areas (SAs) at Sudbury Annex.  The RI,  RI Addendum, and Feasibility Study  (FS)
reports, proposed plan, and other related support documents were submitted to the TRC for their review and
comment.

During the week of August 19, 1996, the Army published a public notice announcing the proposed plan, public
informational meeting, and public hearing in the Sudbury Town Crier, the Middlesex News, the
Marlborough-Hudson Enterprise,  and the Maynard Beacon.  the Army also made the proposed plan available to
the public at the information repositories at the libraries in Stow, Hudson, Sudbury, and Maynard, and at
Fort Devens.

From August 19 to September 18, 1996, the Army held a 30-day public comment period to accept public
comments on the proposed plan.   On September 11, 1996, the Army held an informal public hearing at the stow
Town Building, Stow, Massachusetts to discuss the proposed plan and to accept verbal or written comments
from the public.   No verbal comments were received.  A transcript of this meeting is attached as Appendix
A, and public comments and the Army's response to comments are included in the attached Responsiveness
Summary  (Appendix B).

All supporting documentation for the decision regarding the No Action ROD for OU 4 and OU 5 is contained in
the Administrative Record.  The Administrative Record is a collection of all the documents considered by
the Army in choosing the No Action decision.  On March 20, 1994, the army made the Administrative Record

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available for public review at the Sudbury Annex BRAG Environmental Office, and at the Sudbury Town Hall,
Sudbury, Massachusetts.

4.0 SCOPE AND ROLE OF RESPONSE ACTION

The U.S. Army and the USEPA have determined the No Action is required at OU 4 and OU 5. USEPA has the
authority to revisit the No Action under CERCLA decision even if the Annex is removed from the NPL. This
could occur if future conditions indicate that an unacceptable risk to human health or the environment
would result from exposure to contaminants at OU 4 and OU 5.

Areas OU 4 and OU 5 have been investigated by the Army beginning with preparation of the Master
Environmental Plan in 1992, and concluding with the Remedial Investigation Report issued in December 1995.
During this period, field work and data analyses were performed to characterize surface and subsurface
conditions at OU 4 and OU 5. Potential risks to human health and the environment were calculated using
data from the investigations. Although risk assessments conducted in 1994 concluded that soil and
groundwater at OU 4 and OU 5 may pose a future human health risk, the risk may be overstated because, due
to base closure, the new anticipated future land use of the Annex will be a wildlife refuge with limited
recreation human exposures after the property is transferred to the USFEW. Further rationale for the No
action decision at OU 4 and OU 5 are presented below for the risks posed.

With respect to the exceedance of cancer and non-cancer risks due to consumption of groundwater under a
residential scenario, No Action is warranted because arsenic, the contaminant creating the majority of the
risk, was detected below its Maximum Contaminant Level (MCL). MCLs are enforceable, human health-based
drinking water standards. A comparison of filtered and unfiltered groundwater show that inorganics in
groundwater are due to turbidity and not site-related contamination. In addition, groundwater use is
unlikely because the Annex will be transferred to other federal agencies, and private homes will not be
developed.

As for potential cancer and non-cancer risks due to direct contact with soil at OU 4 and OU 5, No Action is
warranted because exposures under recreational use would be much less than residential use. Therefore, the
potential cancer and non-cancer risks are qualitatively estimated to be acceptable.

Based on this assessment, No Action at areas OU 4 and OU 5 is warranted under CERCLA. However, the Army
will close the septic tank behind Building T104 at OU 5 under state regulations.

5.0 SUMMARY OF SITE CHARACTERISTICS

Site investigations were conducted in 1992 and 1993 to characterize the nature and distribution of
contaminants at OU 4 and OU 5. Detailed descriptions of the data are presented in the Phase (Final RI
Report (E&E, 1995). The significant findings of the contamination assessments are summarized in the
following subsections.

5.1 OU 4

In surface soils, the key contaminants of concern are metals, pesticides, polynuclear aromatic hydrocarbons
(PAHs), and PCBs. Pesticide detections are probably related to general pest management practices. In the
former area of fire training by the MFFA in the parking lot, there appears to be a limited area of metals,
PAH, and pesticide contamination. The metals and PAHs are likely related to former flammable liquid and
car fire training by the MFFA. At the former location of the 500 gallon UST northeast of Building T406,
the metals may be the result of degradation of galvanized steel in the AST. PCBs may be related to a
nearby transformer located immediately north of Building T406, or a spill of waste oil. At the former
location of the ASTs east of Building T410, metals may be related to the former ASTs, and PCBs could be the
result of a small spill of waste oil.

In subsurface soil, the only contaminant found consistently was total petroleum hydrocarbons (TPHC) in
excavations of the former USTs at the site. No contaminants of concern were identified in boring samples
from the three wells near Building T405. No pesticides were found in the two soil borings near Building
T405. Cadmium was the only detection in the soil from the two test pits excavated in the area west of
Building T405.

No groundwater contaminant plumes were identified at the site. For inorganic analytes, discussion of
potential contamination has focused only on filtered sampling results, due to the difficulty of assessing
unfiltered samples which inevitably contain suspended solids, several metals were detected in multiple
sampling rounds above local background levels in one well located just east of Building T405. Pesticides
were also found in this well at relatively low levels but only in one of four sampling rounds. Toluene was
also found in two of four sampling rounds. The source of the metals is unknown. The pesticides could

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potentially be related to pesticide research but may also be related to infiltration of pesticides from the
surface due to general pest control practices. The toluene could be related to solvents used in the
research, but the infrequent and low concentrations and limited number of detections does not indicate a
large-scale spill. These detections appear to be limited to the well east of Building T405, as metals
were not elevated above background and no volatile organics or pesticides were found in samples collected
from the downgradient well. Low levels of several other pesticides were infrequently detected in several
other wells in areas upgradient of Building T405, and the source of these detections is probably general
pest control practices. TPHC was detected in several wells at the site. The infrequency and relatively
low levels of detection do not indicate extensive TPHC contamination at the site, but may indicate some
limited infiltration of petroleum or gasoline from activities at the site.

In general, zinc and the pesticide DDT and/or its degradation products appear to be migrating in surface
water off-site, but their concentrations decline sharply with increasing distance from the site, and are
below detection limits prior to the drainage entering Honey Brook.

Sediment sampling results indicate a limited presence of metals, pesticides, and TPHC in some of the
sediments in the drainage from the central portion of the site and the on-site wetland. The impact on the
tributary to Honey Brook decreases as distance from the site increases.

Research activities conducted at the site do not appear to have been sources of significant site
contamination.

A complete discussion of OU 4 site characteristics can be found in Section 4.0, Volume II of the RI Report.
The RI Report is available for review at the BRAG Environmental Office at Fort Devens, and the town
libraries in Hudson, Maynard, Stow, and Sudbury.

5.2 OU 5

In surface soil samples, the sampling data indicate limited concentrations of metals, PCBs, pesticides, and
TPHC around Building T104, low levels of PCBs in the former PCB spill/remediation area, and low level PAH
and TPHC around Building T106. The pattern of PCB detections points to a potential low-level spill in the
asphalt pad area, migration of PCBs from either the transformer staging done in and around Building T104,
or from excavated soil associated with the PCB spill remediation in 1985 and 1986.

The metals found at levels above background around Building T104 may be related to the metal debris found
around the perimeter of the building, although some could potentially be related to the former research
activity conducted in the building. Pesticides were found above background in a few samples from around
Building T104 and at the PCB spill/remediaton area. These detections probably indicate the use of
pesticides for pest management practices, but the concentrations do not indicated a spill of pesticides
affecting soils. No volatile organic compounds (VOCs) were found in surface soil. Semivolatiles detected
included trace levels of several PAH compounds in one sample taken near Building T106.

Subsurface soil sampling indicated metals around Building T104, and low levels of TPHC near Buildings T104
and T106. No PCBs or pesticides were found in subsurface soil, including those collected in the PCB
spill/remediation area. No VOCs were found. Metals were detected above background levels in the borings at
Building T104.

Groundwater sampling did not indicate metals in filtered samples that are likely to be site-related
contaminants. The only organic compound found in downgradient wells was TPHC, found above background in
one of two rounds of sampling in the monitoring well in the former parking lot and the monitoring well on
the northwest side of Building T106. The TPHC detections are likely related to infiltration of petroleum
from the parking area and the nearby road, or miscellaneous automobile/truck spills in these areas.

Concentrations of metals above background were detected in two of three Marlboro Brook surface water
samples. Some metals are probably due to sources located further upstream.

Metals concentrations found in two of the Marlboro Brook sediment samples were either below or just
slightly above background. The likely source of metals in Marlboro Brook sediment is not the site, but
sources further upstream. Pesticides were also found in sediment samples. The pattern of detection
suggests the source of the pesticides is runoff containing residual pesticides from past pest management
practices at the Annex. PAH compounds and TPHC were found only the sediment sample near Moore Road. The
likely source of PAHs and TPHC is Moore Road.

A complete discussion of OU 5 site characteristics can be found in section 4.0, Volume II of the RI Report.
The RI Report is available for review at the BRAG Environmental Office at Fort Devens, and the town
libraries in Hudson, Maynard, Stow, and Sudbury.

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6.0 SUMMARY OF SITE RISKS

Risk assessments were conducted to estimate the probability and magnitude of potential adverse human health
and environmental effects from exposure to contaminants associated with soil, sediment, and groundwater at
OU 4 and OU 5. Human health risk assessments for OU 4 and OU 5 prepared in 1994 evaluated current and
future land use scenarios which included, respectively, site trespassers and site residents. Since then,
the future use scenario of the Annex changed from residential to wildlife refuge; however, the risk
assessments were not revised and potential future risks under the new future use have been gualitatively
evaluated. Under the base closure process, the Annex property will be transferred to three agencies, with
the USFWS receiving approximately 2,000 acres of land. Therefore, the residential future use scenario
evaluated in the risk assessments provides an overly conservative estimate of risk to site contaminants.
Human exposure under a residential use scenario would be more limited, compared to exposure under a
residential use scenario.

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

• contaminant identification, which identified those hazardous substances That, given the
specifics of the site, were of significant concern;

• exposure assessment, which identified actual or potential exposure pathways, characterized the
potentially exposed populations, and determined the extent of possible exposure;

• toxicity assessment, which considered the types and magnitude of adverse health effects
associated with exposure to the identified hazardous substances; and

• risk characterization, which integrated the three earlier steps to summarize the potential and
actual risks posed by hazardous substances at the site, including cancer and non-cancer risks.

Excess lifetime cancer risks were determined for each exposure pathway by multiplying the exposure level by
the chemical-specific cancer slope factor. Cancer slope factors have been developed by USEPA from
epidemiological or animal studies to reflect a conservative "upper bound" of the risk posed by potentially
carcinogenic compounds. That is, the true risk is unlikely to be greater than the predicted risk. The
resulting risk estimates are expressed in scientific notation as a probability (e.g., 1x10-6 for
1/1,000,000) and indicated (using this example) that an individual has a one-in-a-million chance of
developing cancer as a result of site-related exposure over 70 years to the particular compound at the
stated concentration. Current USEPA practice considers cancer risks to be additive when assessing exposure
to a mixture of hazardous substances.

The Hazard Quotient (HQ) was also calculated for each pathway as USEPA's measure of the potential for
non-cancer health effects. The HQ is calculated by dividing the exposure level by the reference dose (RfD)
or other suitable benchmark for non-cancer health effects. RfDs have been developed by USEPA to protect
sensitive individuals over the course of a lifetime, and reflect a daily exposure level that is likely to
be without an appreciable risk of an adverse health effect. RfDs are derived from epidemiological or
animal studies and incorporate uncertainty factors to help ensure that adverse health effects will not
occur. The HQ is often expressed as a single value (e.g., 0.3) indicating the ration of the stated
exposure to the RfD value (in this example, the exposure is approximately one-third of an acceptable
exposure level for the given compound). HQs are added, resulting in a Hazard Index (HI) for each pathway.
If the HI is greater than 1, the predicted intake could potentially cause adverse health effects. This
determination is necessarily imprecise because the derivation of dose-response values (i.e., RfDs) involves
the use of multiple safety and uncertainty factors. In addition, the HQs for individual compounds should
be added only if their target organs or mechanisms of action are identical. Therefore, the potential for
adverse effects from a mixture having an HI in excess of 1 must be assessed on a case-by-case basis.

The results of the human health risk assessments are discussed below, followed by a discussion of the
ecological risk assessment for OU 4 and OU 5.

6.1 SUMMARY OF RISKS AT OU 4

6.1.1 Human Health Risk Assessment Summary

Contaminants of potential concern (COPCs) at OU 4 listed in Table 6-1 were selected for evaluation in the
human health risk assessment of the RI Report. These contaminants of concern were selected to represent
potential site-related hazards bases on toxicity, concentration, freguency of detection, and mobility and
persistence in the environment. A detailed discussion of the human health risk assessment approach and
results is presented in Volume II, section 6.0 of the RI Report.

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                                TABLE  6-1
                    CONTAMINANTS  OF POTENTIAL CONCERN
                                  OU 4
              SURFACE
    CHEMICAL   SOIL
    SUBSURFACE
SOIL      SEDIMENT
     SURFACE
WATER   GROUNDWATER
Metals
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
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
X
X
X
X
X
X
X
X
X

X
X

X

X
X
X

X
X
X

X



X
X
X
X

X

X
X
X
X
X
X
X
X

X
X
X
X
X
X
X
X
X
X


X
X

-------
                                        TABIiE  6-1
                            CONTAMINANTS OF POTENTIAL CONCERN
                                          OU 4
         CHEMICAL

Pesticides/PCBs
                          SURFACE
                             SOIL
  SUBSURFACE
     SOIL
                                                 SEDIMENT
SURFACE
  WATER
                                                                      GROUNDWATER
alpha-Chlordane
gamma-Chlordane
p,p'-DDD                    X
p,p'-DDE                    X
p,p'-DDT                    X
Dieldrin                    X
Endosulfan, B
Endrin
Heptachlor                  X
Heptachlor epoxide
PCB 1254                    X
PCB 1260                    X
Semivolatile Organics
Bis(2-ethylhexyl)phthalate
Di-n-octylphthalate        X
Acenaphthene               X
Benzo(b)fluoranthene
Chrysene                   X
Fluoranthene
2-Methylnaphthylene        X
Phenanthrene               X
Pyrene
X
X
                        X
                        X
                        X
         X
         X
                                               X

                                               X

-------
                                     TABLE 6-1
                         CONTAMINANTS OF POTENTIAL CONCERN
                                       OU 4

                     SURFACE          SUBSURFACE                     SURFACE
       CHEMICAL               SOIL              SOIL      SEDIMENT   WATER    GROUNDWATER

Volatile Organics

Methylene chloride      X
Methyl ethyl ketone     X
1,1-Trichloroethane     X
Toluene                        XX                                   X
Trichlorofluoromethane         X
Other Organics
Total petroleum                XX                             X
hydrocarbons

Note:  Groundwater COPC selection is based on unfiltered groundwater data.

Key:

X = Selected as a COPC for the human health risk assessment.

Source:  Ecology and Environment, Inc.,  1994

-------
Tables 6-2 and 6-3 summarize the human health risks at OU 4 identified in the RI Report. These tables also
show which exposure pathways are most responsible for the estimated risks.

Under the current USEPA Superfund policy (USEPA, 1992b), acceptable exposures to carcinogens are those that
represent an excess upper bound lifetime cancer risk of between 10-4 to 10-6. For noncarcinogenic effects,
acceptable exposure levels are those with an HI of 1.0 or less.

The estimated potential cancer risk for Reasonable Maximum Exposure (RMEs) to contaminants at OU 4 (see
Table 6-2) are 4.4x10-7 for the adolescent site trespasser's exposure to soil, and 1.8x10-7 for the
adolescent trespasser's exposure to sediment. These are below the acceptable USEPA 10-4 to 10-6 risk
range. The RME case assumes that all of a receptor's exposure is to the maximum contaminant concentrations
observed at the site, and is therefore a conservative estimate.

His for potential reasonable maximum exposures to noncarcinogenic COPCs in soil and sediment are well below
USEPA's benchmark value of 1.0.

Under a possible future residential scenario, the estimated potential cancer risks from RMEs to site soil
contamination are 6.6x10-5 for adult residents and 4.3x10-5 for children, both within the 10-4 to 10-6
range deemed acceptable by USEPA. The estimated cancer risks for the average exposure case are lower by
approximately an order of magnitude. Noncancer His associated with residential RMEs to soil contaminants
total 0.97 for adults and 3.6 for children; the child's HI is above the acceptable HI of 1.0.

Potential cancer risks to adolescent site residents from exposure to sediments are estimated to be 3.6x10-6
for the RME case and 8.2x10-7 for the average exposure case. Noncancer His associated with sediment
exposures were well below 1.0, indicating that sediment contaminants are unlikely to cause adverse health
effects.

Estimated potential cancer risks from consumption of unfiltered groundwater under the RME case are 8.8x10-4
for adults and 4.1x10-4 for children, above the 10-4 to 10-6 range. Average case risk estimates were
approximately one-fifth as great. When metals data from filtered groundwater samples are used to remove
the effects of suspended sediment, estimated RME cancer risks drop by two-thirds to 3.Ix 10-4 and 1.4x10-4
for adults and children, respectively. The arsenic concentration that is responsible for the latter risk
estimates is well below the USEPA's Maximum Contaminant Level (MCL) for arsenic in drinking water of 50
U/L.

-------
                                                        TABIiE 6-2
                                   SUMMARY OF EXCESS CANCER RISKS ASSOCIATED WITH OU 4
     PATHWAY
                       CASE
                                 ADULT
                                          RECEPTOR

                                         ADOLESCENT
                                              RISK CONTRIBUTIONS BY   RISK CONTRIBUTIONS
                                                EXPOSURE ROUTEA          BY CHEMICALA
                                                        CHILDa
Exposure Pathways Potentially Complete Under Current Site Conditions
Trespasser Soil
Contact
RME
Average
4.4x10-7
4.5x10-8
Dermal contact - 87%
Soil Ingestion - 13%
                                                                            PCBs - 98?
Trespasser           RME
Sediment Contact     Average
                      1.8x10-7
                      4.1x10-8
                       Sediment  Ingestion --  100%
                               Arsenic -  95%
                               Beryllium  -  4:
Exposure Pathways Potentially Complete Under Possible Future Site Conditions
Future resident soil RME        6.6x10-5
contact              Average    4.8x10-6
                                4.3x10-5   Dermal contact - 90%
                                3.2x10-6   Soil ingestion - 10%
                                                                            PCBs - 98%
Future resident      RME
sediment contact     Average
                      3.6x10-6
                      8.2x10-7
                       Sediment  Ingestion -  100°
                               Arsenic -  95%
                               Beryllium  -  9°
Future residential   RME         8.8x10-4
groundwater          Average    1.9x10-4
usage, unfiltered
                                4.1x10-4   Water Ingestion - 100°
                                8.7x10-5
                                                      Arsenic - 95i
                                               Beryllium - 9%
Future residential   RME         3.1x10-4
groundwater          Average    1.5x10-4
usage, filtered
                                1.4x10-4   Water Ingestion - > 99%
                                6.7x10-5   Dermal contact - < 1%
                                                      Arsenic - 57%
                                                      Berylliumb - 41%
                                                      Chlordane - 1%
                                                      Heptachlor epoxide -
                                                      1%
a  Reasonable Maximum Exposure  (RME) case for the receptor showing the greatest risk.
b  Beryllium was not detected in unfiltered groundwater; its concentration was assumed to be egual to one-half the guantitation  limit.

-------
                                                          TABIiE 6-3
                     SUMMARY OF ESTIMATED HAZARD INDICES FOR NONCARCINOGENIC EFFECTS ASSOCIATED WITH OU 4
         PATHWAY
                            CASE
                                                 RECEPTOR
                                                  ADOLESCENT
                                        ADULT     ADOLESCENT     CHILDa

Exposure Pathways Potentially Complete Under Current Site Conditions
                                           RISK CONTRIBUTION BY
                                               EXPOSURE  ROUTEA
Trespasser Soil Contact


Trespasser Sediment Contact
 RME
 Average   -

RME
Average   -
0.017
0.0017

0.0021
0.0005
          Dermal  contact  -  78%
          Soil  Ingestion  -  22%

          Sediment  Ingestion -  > 99%
          Dermal  contact  -  < 1%
Exposure Pathways Potentially Complete Under Possible Future Site Conditions
Future resident soil contact
Future resident sediment
contact
                                  RME      0. 97
                                  Average  0.070  —
  RME
  Average
0.042
0.0098
 3.6      Dermal  contact  -  58%
0.31      Soil  ingestion  -  42%

          Sediment  Ingestion -  > 99t
          Dermal  Contact  -  < 1%
Future residential groundwater    RME      8.5
usage, unfiltered                 Average  2.0
Future residential groundwater
usage, filtered
  RME      2.9
  Average   0.75
                                19
                               4.4
              6.7
              1.7
                      Water  Ingestion  -  100%
         Water Ingestion -  100%
a  Reasonable Maximum Exposure  (RME) case for the receptor showing the greatest risk.
b  Hazard indices for the child were calculated using subchronic RFDs.
                                                   HAZARD  INDICES  BY
                                                         CHEMICALA
                                                                                                       PCB-1254 - 2.7
Arsenic  -  8.0
Manganese  - 7.5
Antimony 2.0

Manganese  - 3.5
Arsenic - 1.8

-------
Total His for noncarcinogenic effects from consumption of groundwater based on data from unfiltered
groundwater samples are 8.5 for adults and 19 for children under the RME case; His are approximately
one-fifth as great for the average exposure case. When the risks are recalculated using metals data from
filtered groundwater samples, the total His for the RME case drop to 3.1 for adults and 6.7 for children.
Total His estimated for the average exposure case were less than 1.0 for both adults and children.

Although estimated potential cancer risks from consumption of groundwater were greater than 10-4, and total
His from consumption of groundwater were greater than one, action is not warranted. Arsenic, the
contaminant creating the majority of the risk, was detected below its MCL. A comparison of unfiltered and
filtered groundwater data show that inorganics in groundwater are due to turbidity and not site-related
contamination. In addition, groundwater use is unlikely because the Annex will be transferred to other
federal agencies, and private homes will not be developed.

Although total His from contact with site soil under a future residential scenario is greater than one,
action is not warranted. As stated above, No Action is warranted for soil because exposures under
recreational use would be much less than residential use.

6.1.2 Ecological Risk Assessment Summary

The following metals were selected as ecological COPCs in surface water, sediments, and surface soils
potentially affected by the activities at OU 4 :

• Zinc in surface water;

• Arsenic in sediments; and

• Lead and zinc in surface soils.

In this section, ecological risks identified in Volume II, Section 7.0 of the RI Report are summarized.
Ecological risk characterization involves two major steps: risk estimation and risk description. The
risks are estimated using HQs calculated with estimated exposure and toxicity reference values for each
endpoint species.

The wildlife HQs for the average exposure case were all less than 1. These results indicated that the mean
concentration of these COPCs are unlikely to pose a risk to the meadow vole, raccoon, white-footed mouse,
American robin, or red fox at OU 4. An arsenic HQ slightly greater than 1 was calculated for the RME case
for the meadow, vole. Potential risks to aguatic organisms for the average exposure case and the RME case
for raccoon, red fox, white-footed mouse, and American robin were less than 1 for all of the COPCs. The
results indicate that arsenic, lead, and zinc are unlikely to pose a significant risk to any of these
species.

Potential risks to aguatic organisms were calculated for the average exposure case and for the RME case.
The average and maximum surface water concentrations of zinc exceed the Toxicity Reference Value (TRV),
suggesting that zinc may pose a potential risk to sensitive species of aguatic life. The HQ for arsenic in
sediment was less than 1 for the average exposure case and only slightly greater than 1 in the RME case,
indicating that this COPC poses no more than a marginal risk to aguatic life at OU 4.

Potential risks to terrestrial vegetation were calculated for the average exposure case and for the RME
case. An HQ greater than 1 was calculated for the average concentration of zinc. In addition, the maximum
detected concentrations of zinc exceeded the most conservative reference value available for this
contaminant (HQ greater than 1).

Metals and organic chemicals in soils, surface water, and sediment at the OU 4 site are not considered to
pose significant risks to populations of plants or wildlife. Levels of zinc in soils exceed reference
values for plants but primarily for the maximum detected concentration of this chemical. These exceedances
are not likely to be ecologically significant due to the limited extent of contamination and the disturbed
nature of the habitat. Zinc found in the unfiltered surface water exceeds reference values for sensitive
species of aguatic life. However, the zinc Ambient Water Quality Criteria (AWQC) for aguatic life is
likely to be overly conservative for the site.

The risk assessment concluded that there is no significant risk to ecological receptors.

-------
            TABIiE  6-4
CONTAMINANTS OF  POTENTIAL CONCERN
               OU  5

CHEMICAL
Metals
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Selenium
Silver
Sodium
Vanadium
Zinc
SURFACE
SOIL

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X


X
X
X
SUBSURFACE
SOIL

X
X

X
X
X
X
X
X
X
X

X
X
X
X



X
X
                                  SURFACE
                        SEDIMENT          WATER
                          X          X
                          X
                          X          X
                          X          X
                          X
                          X
                          X
                          X          X
                          X          X
                          X
                          X          X
                          X          X
                          X
                          X          X
                          X          X
                                                    GROUNDWATER
                          X
                          X

-------
                                    TABIiE 6-4
                        CONTAMINANTS OF POTENTIAL CONCERN
                                      OU 5

                          SURFACE    SUBSURFACE               SURFACE
        CHEMICAL             SOIL   SOIL       SEDIMENT WATER    GROUNDWATER

Pesticides/ PCBs

alpha-BHC                                      X
alpha-Chlordane                    X
gamma-Chlordane                    X                  X
p,p'-DDD
p,p'-DDE                                       X
p,p'-DDT                    X
Dieldrin
Endosulfan, B                      XX
Endrin                                                X
Heptachlor
Heptachlor epoxide                             X
PCB 1254                    X
PCB 1260                    X       X
Semivolatile Organics
Bis(2-ethylhexyl)phthalate  X                              X
Butylbenzylphthalate        X       X
Di-n-octylphthalate                 X
Acenaphthene
Benzo(b)fluoranthene               X
Chrysene
Fluoranthene                X                  X
2-Me thyInaphthy1ene
Phenanthrene
Pyrene                             X                  X

-------
                              TABIiE 6-4
                  CONTAMINANTS OF POTENTIAL CONCERN
                                OU 5

                 SURFACE  SUBSURFACE                SURFACE
    CHEMICAL      SOIL      SOIL      SEDIMENT     WATER    GROUNDWATER

Volatile Organics

Toluene                                       X

Other Organics

Total petroleum           XXX                    X
hydrocarbons

Note:  Groundwater COPC selection is based on unfiltered  groundwater  data.

Key:

X = Selected as a COPC for the human health risk assessment.

Source:  Ecology and Environment, Inc. 1994.

-------
6.2 SUMMARY OF RISKS AT OU 5

6.2.1 Human Health Risk Assessment Summary

Contaminants of potential concern at OU 5, listed in Table 6-4, were selected for evaluation in the human
health risk assessment of the RI Report. These COPCs were selected to represent potential site-related
hazards based on toxicity, concentration, frequency of detection, and mobility and persistence in the
environment. A detailed discussion of the human health risk assessment approach and results is presented
in Volume III, Section 6.0 of RI Report.

Tables 6-5 and 6-6 summarize the human health risks at OU 5 identified in the RI Report. These tables also
show which exposure pathways are most responsible for the estimated risks.

Under the current USEPA Superfund policy, acceptable exposures to carcinogens are those that represent an
excess upper bound lifetime cancer risk of between 10-4 to 10-6. For noncarcinogenic effects, acceptable
exposure levels are those with an HI of 1.0 or less.

The estimated potential cancer risk for RMEs to contaminants at OU 5 are 1.1x10-5 for the adolescent site
trespasser's exposure to soil and 1.1x10-6 for the adolescent site trespasser's exposure to sediment.
These are within the acceptable USEPA 10-5 to 10-6 risk range. The RME case assumes that all of a
receptor's exposure is to the maximum contaminant concentrations observed at the site.

His for potential reasonable maximum exposures to noncarcinogenic COPCs in soil and sediment are below
USEPA's benchmark value to 1.0.

Under a possible future residential scenario, the estimated potential cancer risks from RMEs to site soil
contamination are 1.6x10-4 for adult residents and 1.2x10-4 for children, both above the 10-4 to 10-6 range
deemed acceptable by USEPA. The estimated cancer risks for the average exposure case are lower by
approximately an order of magnitude. Noncancer His associated with residential RMEs to soil contaminants
total 0.77 for adults and 3.7 for children; the child's HI is above the acceptable HI of 1.0.

Potential cancer risks to adolescent site residents from exposure to sediments are estimated to be 3.8x10-6
for the RME case and 1.7x10-6 for the average exposure case. Noncancer His associated with sediment
exposures were well below 1.0, indicating that sediment contaminants are unlikely to cause adverse health
effects.

Estimated potential cancer risks from consumption of unfiltered groundwater under the RME case are 2.1x10-3
for adults and 9.9x10-4 for children, above the 10-4 to 10-6 range. Average case risk estimates were
approximately one quarter as great. When metals data from filtered groundwater samples are used to remove
the effects of suspended sediment, estimated RME cancer risks drop by a factor of 50 to 4.5x10-5 and
2.1x10-5 for adults and children, respectively.

Total His for non-cancer effects from consumption of groundwater based on data from unfiltered groundwater
samples are 9.2 for adults and 21 for children under the RME case; His are approximately one-quarter as
great for the average exposure case. When the risks are recalculated using metals data from filtered
groundwater samples, the total His for the RME case drop to 0.29 for adults and 0.34 for children,
indicating that non-cancer efforts are unlikely.

Although estimated potential cancer risks from contact with site soil were greater than 10-4, and total His
from contact with site soil were greater than one, action is not warranted. As stated above, no action is
warranted for soil because exposures under recreational use would be much less than residential use.

-------
                                                             TABLE 6-5
                                        SUMMARY OF EXCESS CANCER RISKS ASSOCIATED WITH OU 5
          PATHWAY
                                CASE
                                             ADULT
                                                     RECEPTOR
                                                      ADOLESCENT
                                                                      CHILD
                                                    RISK CONTRIBUTION  BY
                                                     EXPOSURE ROUTEA
                                                             RISK CONTRIBUTIONS
                                                        BY CHEMICAL A
Exposure Pathways Potentially Complete Under Current Site Conditions
Trespasser Soil Contact
Trespasser Sediment Contact
RME
Average
RME
Average
1.1x10-5
1.8x10-6
1.1x10-6
5.1x10-7
Dermal Contact - 77%
Soil Ingestion - 23%


Sediment Ingestion - 100%
Exposure Pathways Potentially Complete Under Possible Future Site Conditions
Future Resident Soil Contact    RME      1.6x10-4
                               Average   1.8x10-5
                                 1.2x10-4
                                 2.1x10-5
Future Resident Sediment
Contact
RME
Average
3.8x10-6
1.7x10-6
Future Residential Groundwater RME       2.1x10-3
Usage, Unfiltered              Average   5.0x10-4

Future Residential groundwater RME       4.5x10-5
Usage, Filtered                Average   2.4x10-5
                                 9.9x10-4
                                 2.3x10-4
                        Dermal  contact - 82%
                        Soil  ingestion - 18%
Sediment ingestion - lOOt


Water ingestion - 100%
                                 2.1x10-5      Water ingestion - 100%
                                 1.1x10-5
PCBs - 86%
Arsenic - 12%
Beryllium - 1%

Arsenic - 93%
Beryllium - 6%
PCBs - 89%
Arsenic - 9%
Beryllium - 1%

Arsenic - 93%
Beryllium - 6%

Arsenic - 100%
                                                         Arsenic - 100%
a  Reasonable Maximum Exposure (RME) case for the receptor showing the greatest risk.

-------
                                                         TABIiE 6-6
                                          SUMMARY OF ESTIMATED HAZARD INDICES FOR
                                        NONCARCINOGENIC EFFECTS ASSOCIATED WITH OU 5
           PATHWAY
                                  CASE
                                                 RECEPTOR
                                                 ADOLESCENT
                                        ADULT

Exposure Pathways Potentially Complete Under Current Site Conditions

Trespasser Soil Contact
                                        RISK CONTRIBUTION BY
                                CHILDA     EXPOSURE  ROUTEB
Trespasser Sediment Contact
RME
Average

RME
Average
         0.12
         0.16

        0.014
        0.007
       Dermal Contact - 66%
       Soil Ingestion - 34%

       Sediment Ingestion - > 99%
       Dermal Contact - < 1%
Exposure Pathways Potentially Complete Under Possible Future Site Conditions
Future Resident Soil Contact
Future Resident Sediment
Contact
 RME
Average

RME
Average
0.77
0.67
        0.047
        0.022
Future Residential Groundwater RME
Usage, Unfiltered              Average
Future Residential Groundwater RME       0.20
Usage, Filtered                Average   0.11
3.7
0.49
                               21
                                5.0
Dermal Contact - 63%
Soil Ingestion - 37%

Sediment Ingestion - > 99%
Dermal Contact - < 1%

Water Ingestion - 100%
                               0.46   Water Ingestion - 100%
                               0.26
                                                             HAZARD INDEX BY
                                                                CHEMICALB
PCB-1254 - 1.6
Cadmium - 0.8
                                                                                                       Arsenic - 21
a  Hazard indices for the child were calculated using subchronic RfDs.
b  RME case for the receptor showing the greatest risk.
c  Hazard indices are based on RfDs taken from MADEP Residential Shortform  (MADEP 1992) which are not USEPA approved.

-------
6.2.2 Ecological Risk Assessment Summary

The following metals and organic compounds were selected as ecological COPCs in surface water, sediments,
and surface soils potentially affected by the activities at OU 5:

• lead and zinc in surface water;

• arsenic in sediments; and

• cadmium, copper, lead, zinc, and Aroclor 1260 in the surface soils.

In this section, ecological risks identified in Volume III, Section 7.0 of the RI Report are summarized.
Ecological risk characterization involves two major steps: risk estimation and risk description. Risks
are estimated using HQs calculated with estimated exposure and toxicity reference values for each endpoint
species.

The wildlife HQs for the average exposure case were all less than 1, with the exception of a slight
exceedance of the arsenic TRV for the meadow vole. These results indicate that the mean concentrations of
these COPCs are unlikely to pose a risk to wildlife at OU 5. HQs greater than 1 were calculated for the
RME case for the white-footed mouse for cadmium and zinc, for the American robin for zinc, and for the
meadow vole for arsenic. These results indicate that, at their maximum concentrations, these metals in
surface soil have the potential to result in adverse effects to birds and small mammals residing at the
site. The HQs for the RME case for the raccoon and red fox were less than or egual to 1 for all of the
COPCs. The results indicated that the COPCs are unlikely to pose a risk to these species.

Potential risks to aguatic organisms were calculated for the average exposure case and for the RME case.
The average and maximum surface water concentrations of lead exceed the TRV, suggesting that lead may pose
a potential risk to sensitive species of aguatic life. The maximum concentration of zinc exceeded the TRV,
but the HQ was less than 1 for the average concentration in surface water. The HQ for arsenic in sediment
was less than 1 for the average exposure case and only slightly greater than 1 for the RME case, indicating
that this COPC does not pose a risk to aguatic life at OU 5.

Potential risks to terrestrial vegetation were calculated for the average exposure case and for the RME
case. The average and maximum detected concentrations of zinc exceeded the reference values available for
this contaminant (HQ greater than 1). The average concentrations of the other contaminants in soils were
below the toxicity reference values (HQ less than 1), but maximum cadmium and upper concentrations exceeded
the TRV. Phytotoxicity reference values were not available for Aroclor 1260 and therefore the potential
risk of this COPC to plants was not evaluated. Aroclor 1260 did not pose a risk to any of the other
endpoint species; therefore, no risks to plants are anticipated.

Metals and organic chemicals in soils, surface water, and sediment at OU 5 are not considered to pose
significant risks to populations of plants or wildlife. Levels of metals in soils exceed reference values
for animals and plants but primarily for the maximum detected concentrations of these chemicals. These
exceedances are not likely to be ecologically significant due to the limited extent of contamination and
the disturbed nature of the habitat. Lead and zinc found in the unfiltered surface water exceeds reference
values for sensitive species of aguatic life. However, aguatic life in the vicinity of the site doe not
appear to be impacted and the lead and zinc AWQC for aguatic life is likely to be overly conservative for
the site.

The risk assessment concluded that there is no significant risk to ecological receptors.

7.0 DESCRIPTION OF THE NO ACTION ALTERNATIVE

Based on the results of the RI and Baseline Risk Assessments, No Action is necessary for OU 4 and OU 5. No
five-year site reviews will be conducted.

Although there are no actions associated with the No Action decision, the Army will close the septic tank
behind Building T104 at OU 5 under state regulations.

8.0 DOCUMENTATION OF NO SIGNIFICANT CHANGES

The U.S. Army prepared a Proposed Plan for OU 4 and OU 5 (ABB-ES, 1996). The Proposed Plan described the
Army's decision to pursue No Action under CERCLA at OU 4 and OU 5. There have been no significant changes
made to the No Action under CERCLA decision stated in the Proposed Plan.

-------
9.0 STATE ROIiE

The Commonwealth of Massachusetts has reviewed the Proposed Plan and concurs with the decision for No
Action at OU 4 and OU 5.  The Commonwealth has also reviewed the RI to determine if the decision complies
with applicable or relevant and appropriate laws and regulations of the Commonwealth.  A copy of the
declaration of concurrence is attached as Appendix D.

-------
                 GLOSSARY OF ACRONYMS AND ABBREVIATIONS
ABB-ES     ABB Environmental Services, Inc.
AST        above ground storage tanks
AWQC       Ambient Water Quality Criteria
BRAG       Base Realignment and Closure Act
CERCLA     Comprehensive Environmental Response, Compensation, and Liability Act
COPCs      Contaminants of Potential Concern
DDD        2,2-bis(para-chlorophenyl)-1,1-dichloroethane
DDE        2, 2-bis(para-chlorophenyl)-1,1-dichloroethene
DDT        2,2-bis(para-chlorophenyl)-1.1,1-trichloroethane
DERP       Defense Environmental Restoration Program
DoD        Department of Defense
E&E        Ecology and Environment,  Inc.
FEMA       Federal Emergency Management Agency
FS         Feasibility Study
HI         Hazard Index
HQ         Hazard Quotient
MADEP      Massachusetts Department of Environmental Protection
MCL        Maximum Contaminant Level
MEP        Master Environmental Plan
MFFA       Massachusetts Fire Fighting Academy
NCP        National Contingency Plan
NPL        National Priorities List
OHM        OHM Remediation Services Corp.
OU         Operable Unit
PA/SI      preliminary assessment/site investigation
PAH        polynuclear aromatic hydrocarbons
PCB        polychlorinated biphenyl
ROD        Record of Decision
RfD        Reference Dose
RFTA       Reserve Forces Training Area
RME        Reasonable Maximum Exposure
RI         remedial investigation
SA         study areas
SARA       Superfund Amendments and Reauthorization Act of 1986
SI         site investigation
TPHC       total petroleum hydrocarbons
TRC        Technical Review Committee
TRV        Toxicity Reference Values
jlg/L       micrograms per liter
USAEC      U.S. Army Environmental Protection Center
UESCOE     U.S. Army Corp of Engineers
USEPA      U.S. Environmental Protection Agency
USFWS      U.S. Fish and Wildlife Service
UST        underground storage tanks
VOC        volatile organic compound

-------
                                        APPENDIX A

                          TRANSCRIPT OF THE PUBLIC MEETING
                                 (SEPTEMBER 11,  1996)

                                       U.S. ARMY

                              BASE REALIGNMENT  AND CLOSURE

                           FT. DEVENS SUDBURY TRAINING ANNEX
                                     PUBLIC HEARING

                   BEFORE:  Thomas Strunk, Environmental Coordinator


                                       *****

                                        held at
                                   Stow Town Building
                                     380 Great Road
                                  Stow, Massachusetts
                             Wednesday, September 11,  1996
                                       7:40 p.m.


                           (Carol H. Kusinitz, Court Reporter)

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 1               PROCEEDINGS





 2           MR.  STRUNK:   This is the formal comment





 3  time.  If there are any formal comments that anyone





 4  wants to make on this plan for no action on these





 5  sites,  the Army will be glad to respond to you in





 6  writing.  It reguires that now, after Tom's





 7  presentation of the information,  that if you have





 8  any comments you would like to go into the record,





 9  please feel free to make them now and we will





10  respond.





11            (No response)





12           MR.  STRUNK:   Okay.  Is that sufficient for





13   everyone?  Then that's over.





14             (Whereupon the hearing was





15               concluded at 7:42 p.m.)





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              DORIS 0. WONG ASSOCIATES

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 1             CERTIFICATE





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 3     I,  Carol H.  Kusinitz,  Registered





 4   Professional Reporter, do hereby certify that the





 5   foregoing transcript, Volume I, is a true and





 6   accurate transcription of my stenographic notes





 7   taken on September 11, 1996.





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              DORIS 0.  WONG ASSOCIATES

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            PUBLIC HEARING


       7:00 P.M.  Stow Town Building
                 Stow, MA
            September 11,  1996

               SIGN-IN SHEET

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                                     APPENDIX B
                               RESPONSIVENESS SUMMARY

No verbal or written comments on the decision for No Action at Operable Units 4 and 5, Sudbury Training
Annex, were received at the public hearing or during the 30-day public comment period.  As a result, no
responses to comments were necessary and no Responsiveness Summary was prepared.

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                                    APPENDIX C
                            ADMINISTRATIVE RECORD INDEX

                            Fort Devens - Sudbury Annex

                        Operable Unit 4 (Areas Pll and P13)
                                         and
                     Operable Unit 5 (Areas A12, P36, and P37)

                             Administrative Record File

                                       Index

                                    Prepared by
                          ABB Environmental Services, Inc
     Corporate Place 128, 107 Audubon Road, Wakefield, MA 01880  (617) 245-6606

                                    Introduction

This document is the Index to the Administrative Record File for the Record of Decision for Operable Units
(OUs)  4 (Areas Pll and P13)  and 5 (Areas A12, P36, and P37) at the fort Devens Sudbury Annex.  Section I of
the Index lists site-specific documents and Section II lists guidance documents used by U.S. Army in
selecting response actions at the site. Some documents in this Administrative Record File Index have been
cited but not physically included (for example, draft versions of reports that have been superseded by
final reports). In come cases, however, comments were only included as part of the response package.

The Administrative Record File is available for public review at the office of the BRAG Environmental
Coordinator,  Fort Devens, Massachusetts and at the Sudbury Town Hall, Sudbury, Massachusetts.  Questions
concerning the Administrative Record should be addressed to the BRAG Environmental Coordinator.

The Administrative Record is reguired by the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA),  as amended by the Superfund Amendment and Reauthorization Act  (SARA).

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ADMINISTRATIVE RECORD FIIiE INDEX

for

Record of Decision for
Operable Unit 4 (Areas Pll and P13)
and
Operable Unit 5 (Areas A12, P36, and P37)

Fort Devens - Sudbury Annex

Compiled: September 16, 1996

1.0 Pre-Remedial

1.2 Preliminary Assessment

Reports

1. "Installation Assessment NARADCOM Research and Development Laboratory, Massachusetts," EPA
Environmental Monitoring Systems Laboratory (March 1982).
2. "Installation Assessment of U.S. Army Natick Research and Development Command - Report No. 170,"
U.S. Army.
3. "PCB Spill Remediation Report at Building 104, Area A-12."

1.3 Site Inspection

Reports

4. "Phase II Site Investigations Report (Draft Final), Volume I-III, Fort Devens Sudbury Training
Annex, Massachusetts," Ecology & Environment, Inc. (July 1994).
5. "Final Phase II Site Investigations Report, Vol. I of III, General Annex Wide Information, Fort
Devens Sudbury Training Annex, Massachusetts," Ecology & Environment, Inc. (September 1994).

Comments

6. Comments Dated April 29, 1994 from Lorna Bozeman, Department of Health and Human Services,
Agency for Toxic Substances and Disease Registry, Atlanta, Georgia on the "Draft Phase II site
Investigation," (Ecology and Environment, Inc.).
7. Comments Dated May 16, 1994 from Robert Lim, USEPA, on the "Draft Phase II Site Investigations
Report, Volumes 1-3," Ecology and Environment, Inc. (March 1994).
8. Comments Dated June 14, 1994 from Jay Naparstek, Commonwealth of Massachusetts Department of
Environmental Protection on the March 1994 "Phase II Site Investigations Report Vol 1-3, Sudbury
Training Annex, Massachusetts," Ecology and Environment, Inc.
9. Comments Dated June 27, 1994 from Robert Lim, USEPA, on the Draft Groundwater Model Report (as
included in the Final Phase II Site Investigation Report.
10. Comments Dated August 22, 1994 from Jay Naparstek, Commonwealth of Massachusetts Department of
Environmental Protection on the July 1994 "Phase II Site Investigations Report Vols 1-3, Fort
Devens Sudbury Training Annex, Massachusetts," Ecology and Environment, Inc.
11. Comments Dated August 23, 1994 from Robert Lim, USEPA, on the July 1994 "Draft Final Phase II
Site Investigations Report, Vol 1-3, Fort Devens Sudbury Training Annex," Ecology and
Environment, Inc.

Responses to Comments

12. Responses Dated June 1994 from U.S. Army Environmental Center on the Draft Phase II Site
Investigations Report, Fort Devens Sudbury Training Annex, Fort Devens, Massachusetts (Ecology
and Environment, Inc.).
13. Responses Dated September 1994 from Ecology and Environment, Inc. on the Draft Phase II Site
Investigation Report, Fort Devens Sudbury Training Annex (Ecology and Environment, Inc.)

2.0 Removal Response

2.1 Correspondence

1. "Record of Environmental Consideration," (November 9, 1992).

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2. "3 Bills of Lading," (May 6, 1993).

2.2 Removal Response Reports

1. "Removal of Underground Storage Tanks," Environmental Application, Inc. (May 1989).
2. "Post Removal Report - Underground Storage Tank Closure UST No. 0097- Building 407 - SA P13,"
ATEC Environmental Consultants (June 3, 1992) .
3. "Post Removal Report - Underground Storage Tank Closure - UST No. 0098- Building 408 - SA P13,"
ATEC Environmental Consultants (June 3, 1992) .
4. "Post Removal Report - Underground Storage Tank Closure UST No. 0093- Building 410 - SA P13 -
Gas Station," ATEC Environmental Consultants (June 3, 1992).
5. "Post Removal Report - Underground Storage Tank Closure UST No. 0100- Building 409 - SA P13,"
ATEC Environmental Consultants (June 8, 1992).
6. "Post Removal Report - Underground Storage Tank Closure - UST No. 0095- Building 405," ATEC
Environmental Consultants (November 4, 1992).

3.0 Remedial Investigation (RI)

3.1 Correspondence

1. Letter from Robert Lim, USEPA, to Tom Strunk expressing the approval of the Final Remedial
Investigation Report for Sites P11/P13 and A12/P36/P37, Ft. Devens Sudbury Training Annex, MA.

3.6 Remedial Investigation (RI) Reports

1. "Final Remedial Investigations of the Sudbury Annex," Dames & Moore (November 1986).
2. "Draft Phase II Remedial Investigations Report, Sites P11/P13 and A12/P36/P37, Fort Devens
Training Annex, Maynard, Massachusetts, Vol I-IV," Ecology & Environment, Inc. (November 1994)
3. "Draft Final Phase II Remedial Investigation Report, Sites P11/P13 and A12/P36/P37, Fort Devens
Training Annex, Maynard, Massachusetts, Vol I-IV," Ecology and Environment, Inc. (June 1995)
4. "Final Phase II Remedial Investigations Report, Vol. I-III Sites P11/P13 and A12/P36/P37, Ft.
Devens Sudbury Training Annex, MA," Ecology and Environment, Inc. (December 1995).

Comments

5. Comments Dated January 3, 1995 from Robert Lim, USEPA, on the November 1994 " Phase II Draft
Remedial Investigation Report - Sites P11/P13 and A12/P36/P37".
6. Comments Dated January 12, 1995 from Jay Naparstek, Commonwealth of Massachusetts Department of
Environmental Protection on the "Phase II Remedial Investigations Report, Volumes 1-3 for Sites
P11/P13 and P36/A12/P37 for the Sudbury Annex Site".
7. Comments dated August 7, 1995 from Robert Lim, USEPA, on the Draft Final Remedial Investigation
Report for Sites P11/P13 and A12/P36/P37, Ft. Devens Sudbury Training Annex.

Responses to Comments

8. Responses Dated February 1995 from U.S. Army Environmental Center on the Draft Phase II Remedial
Investigations Report, Fort Devens Sudbury Training Annex, Fort Devens, Massachusetts (Ecology
and Environment, Inc.).

Responses to Responses to Comments

9. Rebuttals Dated March 30, 1995 from Robert Lim, USEPA, on the Response to the Army's Response
to Comments on the Draft Remedial Investigation Report for Sites P11/P13 and A12/P36/P37
(Ecology and Environment, Inc.).

3.7 Work Plans and Progress Reports

Reports

1. "Draft Master Quality Assurance Project Plan," Ecology and Environment, Inc. (June 1993).
2. "Draft Technical Plan Addenda, Phase II Site Inspections, Remedial Investigations, "Ecology and
Environment, Inc. (June 1993).
3. "Final Technical Plan Addenda, Phase II Site Inspections, Remedial Investigations, Fort Devens
Sudbury Training, Massachusetts," Ecology & Environment, Inc. (January 1994).

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Comments

4. Comments dated July 7, 1993 from Jack McKenna, Metcalf & Eddy on the June 1993 "Draft Technical
Plan Addenda, Phase II Site Inspections, Remedial Investigations," Ecology and Environment,
Inc. and the June 1993 "Draft Final Addendum to the Final Technical Plans - Phase II
Feasibility Study," OHM Remediation Services Corp.
5. Comments Dated July 23, 1993 from Molly J. Elder for D. Lynne Chappell, Commonwealth of
Massachusetts Department of Environmental Protection on the June 1993 " Draft Master Quality
Assurance Project Plans," Ecology and Environment, Inc.
6. Preliminary Comments Dated July 25, 1993 from Cindy Svec Ruzich of Four Town Focus on the
"Technical Plan Addenda, Phase II Site Inspections, Remedial Investigations," Ecology and
Environment, Inc.
7. Comments Dated August 5, 1993 from Lynne Chappell, Commonwealth of Massachusetts Department of
Environmental Protection on the June 1993 "Technical Plans Addenda Phase II Site Inspections,
Remedial Investigations, Fort Devens Sudbury Training Annex, Massachusetts," Ecology and
Environment, Inc."
8. Comments Dated August 6, 1993 from James P. Byrne, USEPA, on the "Draft Work Plan, Field
Sampling Plan, Quality Assurance Project Plan, and Health and Safety Addenda for the Phase II
Site Investigations and Remedial Investigations," Ecology and Environments, Inc.

Responses to Comments

9. Responses Dated September 1993 from U.S. Army Environmental Center on the Technical Plan
Addenda Phase II Site Investigation/Remedial Investigations, Fort Devens Sudbury Training
Annex, Massachusetts (Ecology and Environment, Inc.).

Responses to Responses to Comments

10. Rebuttals Dated November 2, 1993 from D. Lynne Welsh, Commonwealth of Massachusetts Department
of Environmental Protection on the June 1993 "Draft Technical Plan Addenda, Phase II Site
Investigation/Remedial Investigation, Sudbury Training Annex," Ecology and Environment, Inc.

4.0 Feasibility Study (FS)

4.9 Proposed Plan for Selected Remedial Action

Reports

1. "Draft Proposed Plan: No Further CERCLA Action at OU4 and OU5, Ft. Devens Sudbury Training
Annex," Sudbury Annex BEG (July 1996).
2. "Proposed Plan: No Further CERCLA Action at OU4 (Sites P11/P13) and OU5 (Sites A12/P36/P37) Ft.
Devens Sudbury Training Annex, MA," Sudbury Annex BEG (August 1996).

Comments

3. Comments dated August 6, 1996 from Robert Lim, USEPA on Draft Proposed Plan for OU4 (P11/P13)
and OU5 (A12/P36/P37), Ft. Devens Sudbury Training Annex, MA (Sudbury Annex BEG, July 1996).

5.0 Record of Decision (ROD)

5.4 Record of Decision

1. "Draft Record of Decision: Operable Units OU4 and OU5, Ft. Devens Sudbury Training Annex, MA",
ABB Environmental Services, Inc. (September 1996).

10.0 Enforcement

10.16 Federal Facility Agreements

Reports

The document cited below as entry number 1 may be reviewed, by appointment only, at Fort Devens.

1. "Draft Federal Facility Agreement Under CERCLA Section 120," EPA Region I and U.S. Department
of the Army (March 1991).

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2. "Final Federal Facility Agreement Under CERCLA Section 120," EPA Region I and U.S. Department
of the Army (November 15, 1991).

Comments

3. Comments Dated July 12, 1991 from Edmond G. Benoit, Commonwealth of Massachusetts Department of
Environmental Protection on the March 1991 "Draft Federal Facility Agreement Under CERCLA
Section 120," EPA Region I and U.S. Department of the Army.

Responses to Comments

4. Response Dated September 5, 1991 from James P. Byrne, EPA Region I to the Comments Dated July
12, 1991 from Edmond G. Benoit, Commonwealth of Massachusetts Department of Environmental
Protection on the March 1991 "Draft Federal Facility Agreement Under CERCLA Section 120," EPA
Region I and U.S. Department of the Army.

13.0 Community Relations

13.2 Community Relations Plans

Reports

The document cited below as entries 1 and 2 may be reviewed, by appointment only, at Fort Devens.

1. "Draft Community Relations Plan," Dames & Moore (August 1991).
2. "Draft Final Community Relations Plan," Dames & Moore (December 1991).
3. "Final Community Relations Plan," Dames & Moore (April 1992).

Comments

4. Comments Dated September 30, 1991 from Cindy Svec Ruzich and Deborah Schumann, Four Town FOCUS
on the August 1991 "Draft Community Relations Plan," Dames & Moore.
5. Comments Dated February 14, 1992 from Cindy Svec Ruzich and Deborah Schumann, Four Town FOCUS
on the December 1991 "Draft Final Community Relations Plan," Dames & Moore.
6. Comments Dated March 17, 1992 from D. Lynne Chappell, Commonwealth of Massachusetts Department
of Environmental Protection on the December 1991 "Draft Final Community Relations Plan," Dames
& Moore.
7. Comments from James P. Byrne, EPA Region I on the December 1991 "Draft Final Community
Relations Plan," Dames & Moore.
8. Comments Dated May 13, 1992 from James P. Byrne, EPA Region I on the April 1992 "Final Work
Plan, Final Field Sampling Plan, Final Heath and Safety Plan, Final Quality Assurance Project
Plan," OHM Remediation Corp. and the April 1992 "Final Community Relations Plan," Dames &
Moore.

Responses to Comments

9. Response to the EPA Comments on the August 1991 ""Draft Community Relations Plan," Dames &
Moore.
10. Response to the Commonwealth of Massachusetts Department of Environmental Protection Comments
on the August 1991 "Draft Community Relations Plan," Dames & Moore.

13.11 Technical Review Committee Documents

1. Technical Review Committee Meeting Summary, List of Attendees, and Handouts (May 14, 1991).
2. Technical Review Committee Meeting Summary and List of Attendees (July 31, 1991).
3. Technical Review Committee Meeting Summary and List of Attendees (October 23, 1991).
4. Technical Review Committee Meeting Summary and List of Attendees (January 15, 1992).
5. Technical Review Committee Meeting Summary, Agenda, Handouts, Overheads, and List of Attendees
(April 28, 1992).
6. Technical Review Committee Meeting Summary, Agenda, Handouts, Overheads, and List of Attendees
(July 14, 1992).
7. Technical Review Committee Meeting Summary, Agenda, Handouts, Overheads, and List of Attendees
(October 17, 1992) .
8. Agenda and Attendance List for Sudbury Annex Working Meeting (November 23, 1992).
9. Technical Review Committee Meeting Summary, List of Attendees, and Handouts (February 2, 1993).

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10. Letter from Richard D. Dotchin, U.S. Army to James P. Byrne, EPA Region I (March 3, 1993).
Concerning follow-up to the February 2, 1993 Technical Review Committee Meeting.
11. Technical Review Committee Meeting Summary, List of Attendees, and Handouts (June 9, 1993).

17.0 Site Management Records

17.6 Site Management Plans

The document cited below as entries number 1 and 2 may be reviewed, by appointment only, at the Fort
Devens Environmental Management Office.

Reports

1. "Draft Master Environmental Plan," OHM Remediation Services Corp. (May 1991).
2. "Draft Final Master Environmental Plan," OHM Remediation Services Corp. (October 1991).
3. "Final Master Environmental Plan," OHM Remediation Services Corp. (January 1992).
4. "Draft Master Environmental Plan, Fort Devens Sudbury Training Annex, Massachusetts," Ecology &
Environment, Inc. (May 1994).
5. "Draft Master Environmental Plan, Ft. Devens Sudbury Training Annex, MA," ABB Environmental
Services, Inc. (December 1995).

Comments

6. Comments Dated July 11, 1991 from James P. Byrne, EPA Region I on the May 1991 "Draft Master
Environmental Plan," OHM Remediation Services Corp.
7. Comments Dated July 15, 1991 from D. Lynne Chappell, Commonwealth of Massachusetts Department
of Environmental Protection on the May 1991 "Draft Master Environmental Plan," OHM Remediation
Services Corp.
8. Comments from James P. Byrne, EPA Region I on the January 1992 "Final Master Environmental
Plan," OHM Remediation Services Corp.
9. Comments Dated June 27, 1994 from Robert Lim, USEPA, on the May 1994 "Master Environmental
Plan, Update, Fort Devens Sudbury Training Annex, Massachusetts," Ecology & Environment, Inc.

Responses to Comments

10. Response Dated August 28, 1991 from OHM Remediation Services Corp. to the Comments Dated July
11, 1991 from James P. Byrne, EPA Region I on the May 1991 "Draft Master Environmental Plan,"
OHM Remediation Services Corp.
11. Response Dated August 28, 1991 from OHM Remediation Services Corp. to the Comments Dated July
15, 1991 from D. Lynne Chappell, Commonwealth of Massachusetts Department of Environmental
Protection on the May 1991 "Draft Master Environmental Plan," OHM Remediation Services Corp.

Responses to Responses to Comments

12. Response Dated September 12, 1991 from James P. Byrne, EPA Region I to the Response Dated
August 28, 1991 from OHM Remediation Services Corp.

17.8 Federal and Local Technical and Historical Records

The document cited below as entry number 1 may be reviewed, by appointment only, at the office of the
BRAG Environmental Coordinator, Fort Devens, MA.

1. "An Intensive Archeological Survey of the Sudbury Training Annex," The Public Archaeology
Laboratory, Inc. (April 1985).

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GUIDANCE DOCUMENTS

The following guidance documents were relied upon during the Fort Devens - Sudbury Annex 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 from Preparation of Combined Work/Quality Assurance
Project Plans for Environmental Monitoring: OWRS QA-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. Test Methods for Evaluating Solid Waste: EPA SW-846 Third
Edition, September 1986.
9. 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 9355.5-01, EPA/540/3-89/004), 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/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.
12. U.S. Army. Environmental Quality - Environmental Protection and Enhancement, (Army Regulation
200-1) , April 23, 1990) .
13. U.S. Environmental Protection Agency, 1991. Design and Construction of RCRA/CERCLA Final Covers;
Office of Research and Development; Washington, DC; EPA/625/4-91/025; May.
14. U.S. Environmental Protection Agency, 1991. Risk Assessment Guidance for Superfund: Volume I - Human
Health Evaluation Manual (Part B, Development of Risk-Based Preliminary Remediation Goals) Interim;
Office of Emergency and Remedial Response, Washington, DC; Publication 9285.7-01B; October.

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                                        APPENDIX D
             MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL PROTECTION
                            LETTER OF CONCURRENCE



The Massachusetts Department of Environmental Protection  (the Department) has reviewed the September 20,
1996 Record of Decision (ROD) for Operable Units 4 and 5 at the US Army Sudbury Training Annex.  The ROD,
consistent with the recommendations contained in the Proposed Plan, requires no further remedial actions
under CERCLA for Study Areas P11/P13  (Operable Unit 4) and Study Areas A12/P36/P37  (Operable Unit 5).
These Study Areas were grouped together into these Operable Units due to their proximity to each other.

The Department has reviewed the Army's proposed no action remedy for its consistency with Massachusetts
General Law Chapter 21E and the Massachusetts Contingency Plan.  Based upon this review, the Department
concurs with the selected remedial action.  Conditions of these two Operable Units are now, and will remain
in the future, protective of human health, welfare,  and the environment without additional response
actions.  The no action decision meets state ARARs and helps facilitate the timely transfer of the property
to the US Fish and Wildlife Service.

The Department looks forward to continuing to work with EPA and the Army in this common endeavor and we are
pleased to assist in the transfer of Army property in a manner is protective of human health, welfare, and
the environment. If you have any guestions, please feel free to contact me at (617) 292-5648.

                                          Very truly yours,

                                         

SEP.-30'96(MON.)  11:04   DEP-BWSC                 TEL.:617-292-5530                 P.002

cc:    Mr. Bob Lim, US EPA
       Mr. Stephen Johnson, DEP, BWSC, NERO
       Sudbury BOH, Attn:  Bob Leopold, 278 Old Sudbury Road,   Sudbury MA 01776
       Stow Selectman's Office,  Attn:   Thomas Ruggiero, Town Hall,  Stow,  MA 01775
       Hudson BOH,  Attn:  Robert Steere,  Town Hall,  Hudson, MA 01749
       Maynard BOH, Attn:  Jerry Collins,  Town Hall,  Maynard,  MA      01754
       FOCUS,  Attn.: Cindy Ruzich,  11  Pleasant Street, Maynard, MA    01754

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