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EPA/ROD/R01-02/017 2002 EPA Superfund Record of Decision: OTIS AIR NATIONAL GUARD BASE/CAMP EDWARDS EPA ID: MA2570024487 OU 23 FALMOUTH, MA 02/07/2002
Transcript

 

   

EPA/ROD/R01-02/0172002

  EPA Superfund

   

Record of Decision:

   

OTIS AIR NATIONAL GUARD BASE/CAMP EDWARDSEPA ID:  MA2570024487OU 23FALMOUTH, MA02/07/2002

Massachusetts Military ReservationPLUME RESPONSE PROGRAM

Final Record of Decisionfor Area of Contamination

Fuel Spill-2

February 2002

Prepared for:AFCEE/MMR

Installation Restoration Program322 E. Inner Road

Otis ANGB, MA 02542

Prepared by:Jacobs Engineering Group Inc.

Document No.: A3P-J23-35Z01302-M26-0004

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TABLE OF CONTENTS

ACRONYMS AND ABBREVIATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv1.0 DECLARATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1

1.1 SITE NAME AND LOCATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-11.2 STATEMENT OF BASIS AND PURPOSE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-11.3 DESCRIPTION OF SELECTED REMEDY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-11.4 STATUTORY DETERMINATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-21.5 AUTHORIZING SIGNATURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-2

2.0 DECISION SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-12.1 SITE NAME, LOCATION, AND BRIEF DESCRIPTION . . . . . . . . . . . . . . . . . . . 2-1

2.1.1 Cape Cod and the Massachusetts Military Reservation . . . . . . . . . . . . . . . . . 2-12.1.2 The Fuel Spill-2 Site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2

2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES . . . . . . . . . . . . . . . . . . . . . 2-32.3 COMMUNITY PARTICIPATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-52.4 SCOPE AND ROLE OF AREA OF CONTAMINATION (AOC) . . . . . . . . . . . . . . 2-72.5 SITE CHARACTERISTICS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-8

2.5.1 Conceptual Model of FS-2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-102.5.2 Sampling Strategy and Contamination Assessment . . . . . . . . . . . . . . . . . . . 2-11

2.6 CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES . . . . . 2-142.6.1 Land Use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-142.6.2 Water Resource Use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-14

2.7 SUMMARY OF SITE RISKS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-152.7.1 Summary of Human Health Risk Assessment . . . . . . . . . . . . . . . . . . . . . . . 2-15

2.7.1.1 Identification of Contaminants of Concern . . . . . . . . . . . . . . . . . . . 2-162.7.1.2 Exposure Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-172.7.1.3 Toxicity Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-182.7.1.4 Risk Characterization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-192.7.1.5 Uncertainty Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-22

2.7.2 Summary of Ecological Risk Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . 2-232.7.2.1 Identification of Chemicals of Potential Ecological Concern . . . . . 2-242.7.2.2 Exposure Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-242.7.2.3 Ecological Effects Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-262.7.2.4 Ecological Risk Characterization . . . . . . . . . . . . . . . . . . . . . . . . . . 2-27

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TABLE OF CONTENTS

2.7.2.5 Ecological Risk Assessment Conclusions . . . . . . . . . . . . . . . . . . . . 2-29

2.8 DOCUMENTATION OF SIGNIFICANT CHANGES . . . . . . . . . . . . . . . . . . . . . 2-30

3.0 RESPONSIVENESS SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1

4.0 REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1

FiguresFigure 2-1 Regional Surficial Geology Map, the Massachusetts Military Reservation and AOC

FS-2

Figure 2-2 AOC FS-2 and Surrounding Area

Figure 2-3 AOC FS-2

Figure 2-4 Locations of Soil Sampling Points Used for Pre-2000 Investigations, AOC FS-2

Figure 2-5 Locations of Groundwater Sampling Points, AOC FS-2

Figure 2-6 Worst-Case Scenario of Historical Contaminant Transport (primarily EDB) from AOCFS-2

Figure 2-7 Distribution of Selected SVOCs in Soil at AOC FS-2 Supplemental RI Locations32BH0005-32BH0010

Figure 2-8 Distribution of Selected SVOCs in Soil Along the Former Header Pipes at AOC FS-2

Figure 2-9 Distribution of Total Arsenic in Soil at AOC FS-2

TablesTable 2-1 RAGS Part D Standard Table 3.1, Medium-Specific Exposure Point Concentration

Summary, Soils (0 to 2 feet bgs), AOC FS-2

Table 2-2 RAGS Part D Standard Table 3.2, Medium-Specific Exposure Point ConcentrationSummary, Soils (0 to 10 feet bgs), AOC FS-2

Table 2-3 RAGS Part D Standard Table 3.3, Medium-Specific Exposure Point ConcentrationSummary, Soils (0 to 20 feet bgs), AOC FS-2

Table 2-4 RAGS Part D Standard Table 2.3, Occurrence, Distribution and Selection of Chemicalsof Potential Concern – Groundwater, AOC FS-2

Table 2-5 RAGS Part D Standard Table 1.0, Selection of Exposure Pathways, AOC FS-2

Table 2-6 RAGS Part D Standard Table 4.1, Values Used for Daily Intake Calculations –Trespasser, AOC FS-2

Table 2-7 RAGS Part D Standard Table 4.2, Values Used for Daily Intake Calculations - ChildResident, AOC FS-2

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TABLE OF CONTENTS

Table 2-8 RAGS Part D Standard Table 4.3, Values Used for Daily Intake Calculations - AdultResident, AOC FS-2

Table 2-9 RAGS Part D Standard Table 4.4, Values Used for Daily Intake Calculations -Construction Worker, AOC FS-2

Table 2-10 Non-Cancer Toxicity Data Summary, AOC FS-2 Soils

Table 2-11 Cancer Toxicity Data Summary, AOC FS-2 Soils

Table 2-12 Human Health Risk Summary, AOC FS-2 Soils

Table 2-13 Occurrence and Distribution of Contaminants of Potential Ecological Concern forTerrestrial Receptors, AOC FS-2 Surface Soils (0-2 feet bgs)

Table 2-14 Selection of Contaminants of Potential Ecological Concern for Terrestrial Receptors,AOC FS-2 Surface Soils (0-2 feet bgs)

Table 2-15 Surface Soil Exposure Point Concentrations for COPECs, AOC FS-2 Soils (0 to 2 feetbgs)

Table 2-16 Life History Parameters for Selected Endpoint Species, AOC FS-2

Table 2-17 Bioaccumulation Factors for Selected Ecological Receptor Groups, AOC FS-2

Table 2-18 Ecological Screening of Terrestrial Plants for Surface Soil Exposure, AOC FS-2

Table 2-19 Background Surface Soil Concentrations for Urban Areas in Massachusetts, AOC FS-2

Table 2-20 Ecological Screening of Terrestrial Invertebrates for Surface Soil Exposure, AOC FS-2

Table 2-21 Hazard Index Summary for Surface Soil Exposure, AOC FS-2

Appendixes

Appendix A Massachusetts Department of Environmental Protection Concurrence Letter

Appendix B Administrative Record Index

Appendix C Transcript of Public Hearing

Appendix D Summary of Data from E.C. Jordan Site Investigation Report, 1990-1991

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ACRONYMS AND ABBREVIATIONS

AFCEE Air Force Center for Environmental Excellence

AOC area of contamination

AVGAS aviation gasoline

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CERCLIS Comprehensive Environmental Response, Compensation, and Liability IdentificationSystem

COC contaminant of concern

COPC contaminant of potential concern

COPEC contaminant of potential ecological concern

CS Chemical Spill, as in CS-4

CSF cancer slope factor

CY Coal Yard, as in CY-2

DEP Massachusetts Department of Environmental Protection

DOD U.S. Department of Defense

ELCR excess lifetime cancer risk

EPA U.S. Environmental Protection Agency

EPH extractable petroleum hydrocarbon

ERA ecological risk assessment

FFA Federal Facility Agreement

FS Fuel Spill, as in FS-13

ft bgs feet below ground surface

FTA Fire Training Area, as in FTA-1

HI hazard index

HQ hazard quotient

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ACRONYMS AND ABBREVIATIONS

IRP Installation Restoration Program

JP-4 jet propellant fuel

JPAT Joint Process Action Team

LF Landfill, as in Landfill-1

LOAEL lowest observed adverse effect level

MCP Massachusetts Contingency Plan

mg/day milligrams per day

mg/kg milligrams per kilogram

mg/L milligrams per liter

MMR Massachusetts Military Reservation

msl mean sea level

NCP National Oil and Hazardous Substances Contingency Plan

NGB National Guard Bureau

NOAEL no observed adverse effect level

NPL National Priorities List

PAH polyaromatic hydrocarbon

PCT Plume Cleanup Team

PFSA petroleum fuels storage area

PRG preliminary remediation goal

RfD reference dose

RI remedial investigation

RME reasonable maximum exposure

ROD Record of Decision

SARA Superfund Amendment and Reauthorization Act

SD Storm Drain, as in SD-5

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ACRONYMS AND ABBREVIATIONS

SVOC semivolatile organic compound

SWOU Southwest Operable Unit

TPH total petroleum hydrocarbons

UCL upper confidence limit

USCG U.S. Coast Guard

VOC volatile organic compound

VPH volatile petroleum hydrocarbon

µg/kg micrograms per kilogram

µg/L micrograms per liter

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1.0 DECLARATION

1.1 SITE NAME AND LOCATION

The Massachusetts Military Reservation (MMR) on Cape Cod Massachusetts lies within the

boundaries of the towns of Bourne, Mashpee, Sandwich, and Falmouth. This site is listed on the

National Priorities List (NPL) as Otis Air National Guard/Camp Edwards in Falmouth,

Massachusetts. This Record of Decision (ROD) addresses the area of contamination (AOC) Fuel

Spill-2 (FS-2), which consists of 5.5 acres of land located at the end of Guenther Road, adjacent to

the southern boundary of the MMR golf course. The Comprehensive Environmental Response,

Compensation and Liability Identification System (CERCLIS) number for the site is

MA2570024487.

1.2 STATEMENT OF BASIS AND PURPOSE

This ROD presents the selected No Further Action decision for the soil and groundwater at the FS-2

site at MMR, chosen in accordance with the Comprehensive Environmental Response,

Compensation, and Liability Act (CERCLA) of 1980, as amended by the Superfund Amendment and

Reauthorization Act (SARA), and to the extent practicable, the National Oil and Hazardous

Substances Contingency Plan (NCP). This decision is based on the administrative record for this site.

The U.S. Department of Defense (DOD) is the lead agency for CERCLA remedial actions at MMR.

The U.S. Environmental Protection Agency (EPA) and the DOD (U.S. Air Force) are parties to the

Federal Facility Agreement (FFA) for the MMR. These parties, along with the Commonwealth of

Massachusetts Department of Environmental Protection (DEP), concur with the No Further Action

decision for the FS-2 site.

1.3 DESCRIPTION OF SELECTED REMEDY

Soils containing contamination that posed unacceptable human health risks were removed from the

site in 1996 and treated at the thermal treatment plant at FTA-1. The U.S. Air Force, with

concurrence from the EPA and the DEP, has determined that no further

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action is necessary to address the contamination at the FS-2 site. Petroleum-related semivolatile

organic compounds (SVOCs) and metals were subsequently detected in soil and groundwater

samples collected from the site. However, these compounds occur at concentrations below applicable

action levels. Because the compounds remaining at the FS-2 site are at concentrations below those

considered to pose human health or ecological risks, no further action is appropriate.

1.4 STATUTORY DETERMINATIONS

The selected remedy is consistent with CERCLA and to the extent practicable, the NCP; is protective

of human health and the environment; and is cost-effective. Because the selected remedy is No

Further Action, there are no applicable or relevant and appropriate requirements with which to

comply. Because the levels of contaminants remaining at AOC FS-2 are within the levels that allow

for unlimited use and unrestricted exposure, a five-year review is not required for this remedial

action.

1.5 AUTHORIZING SIGNATURES

The following represents the decision for No Further Action for soil and groundwater at the FS-2

site by the U.S. Air Force and the EPA with the concurrence of the DEP (Appendix A).

Concur and recommend for immediate implementation.

U. S. AIR FORCE

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2.0 DECISION SUMMARY

This section describes the setting, risk analysis, and basis for no further action at AOC FS-2.

2.1 SITE NAME, LOCATION, AND BRIEF DESCRIPTION

The MMR, listed on the NPL as Otis Air National Guard/Camp Edwards, lies within the towns of

Bourne, Mashpee, Sandwich and Falmouth, Massachusetts (Figure 2-1). MMR was formally added

to the NPL in 1989. The FFA between the DOD, the EPA and the U.S. Department of Transportation

(Coast Guard) was signed in 1991. The CERCLIS number for the site is MA2570024487. In

accordance with Executive Order 12580, DOD is the lead agency for remedial actions at MMR. EPA

and DEP are the support agencies for this action. In 1995, the FFA was amended to add the U.S. Air

Force as the lead agent for the cleanup at MMR. The FFA, as amended, requires the U.S. Air Force

to implement CERCLA requirements at MMR.

2.1.1 Cape Cod and the Massachusetts Military Reservation

The MMR occupies approximately 22,000 acres on Cape Cod and provides facilities for several

operating command units: the Massachusetts Air National Guard, the Massachusetts Army National

Guard, the U.S. Air Force, the U.S. Coast Guard (USCG), and the Veterans Administration. Past

military training and maneuvers, military aircraft operations, and maintenance and support activities

have resulted in releases of hazardous materials at MMR.

MMR has a year-round population of approximately 2,300, which increases by several thousand due

to seasonal military training activities. Property use in towns surrounding MMR is primarily

residential, light industrial and agricultural.

MMR is located on two distinct sedimentary units that were deposited by a lobe of the Laurentian

ice sheet. MMR lies primarily on a broad, flat, gently southward-sloping glacial outwash plain

known as the Mashpee Pitted Plain and to a lesser extent on the

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Buzzards Bay Moraine (Figure 2-1). The Mashpee Pitted Plain consists of stratified outwash sand

underlain by either silty glaciolacustrine sediment and/or basal till. The topography of the Mashpee

Pitted Plain gradually slopes from 140 feet above mean sea level (msl) in the north to 70 feet msl in

the south and is pocked with numerous kettle ponds. The Buzzards Bay Moraine, located to the west

of the Mashpee Pitted Plain, consists of a north-south ridge of bouldery till overlying reworked drift

deposits. The surface of the Buzzards Bay Moraine is hummocky with a complex topography that

can vary from approximately 80 to 220 feet msl. There are few ponds located within the Buzzards

Bay Moraine.

The single groundwater flow system that underlies western Cape Cod, including MMR, is known

as the Sagamore Lens. This sole-source aquifer is primarily unconfined and recharged by infiltration

of precipitation. Groundwater flow is generally radial from the recharge area toward the ocean,

which forms the lateral boundary of the aquifer on three sides; the Bass River in Yarmouth forms

the eastern boundary of the Sagamore Lens. Flow direction within the aquifer is generally horizontal

with stronger vertical gradients near surface water bodies. Ponds are generally an expression of the

water table and are hydraulically connected with the aquifer. Water table elevations fluctuate from

1 to 4 feet per year.

2.1.2 The Fuel Spill-2 Site

AOC FS-2 (Figures 2-2 and 2-3) consists of 5.5 acres of flat, unvegetated, unimproved land located

near the southern boundary of the MMR, directly south of the MMR golf course. The area contains

one main-line railroad track and several rail sidings. AOC FS-2 was originally used for unloading

and distributing jet fuel and aviation gasoline. Before decommissioning, the site contained a

petroleum unloading rack, a pump house and associated underground piping. Fuels were unloaded

from tanker truck and railroad tank cars and conveyed through the underground piping to the MMR

petroleum fuels storage area (PFSA). The unloading facility was taken out of service in 1965, and

the header and associated underground piping were drained and abandoned in place (E. C. Jordan

1991). At various dates prior to 1993, the pump house, transfer and header pipes,

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and subsurface fuel transfer pipes were removed (Figure 2-3). Railroad tracks still exist on the site,

and trains pass through the site twice per day.

2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES

Military use of MMR has occurred since 1911. The most intense periods of activity occurred from

1940 to 1946 and 1955 to 1970. Sources of contamination resulting from a variety of military

operations include historical chemical spills, motor pools, landfills, fire training areas, and drainage

structures such as dry wells and drainage swales.

The MMR site history is defined by a series of complex interactions between various federal

agencies and the Commonwealth of Massachusetts. These interactions are described in the MMR

Strategic Plan (AFCEE 1996). Activities resulting in CERCLA actions are summarized below.

In 1982, the DOD initiated the Installation Restoration Program (IRP) at the Otis Air National Guard

Base area of the MMR. The National Guard Bureau (NGB) was responsible for implementing the

IRP at MMR. In 1986, the IRP was expanded to include all potential hazardous waste sites at MMR.

The IRP investigatory process continued with review and interaction from the DEP. In 1989, MMR

was formally added to the NPL. An FFA among the DOD, the EPA, and the U.S. Department of

Transportation (Coast Guard) was signed in 1991. The FFA provides a framework for EPA oversight

and enforcement of the MMR investigations and cleanup activities and identifies a schedule for

cleanup activities. A Community Relations Plan is included as an attachment to the FFA. In 1996,

the EPA Region I Administrator requested that DOD provide a new management structure for the

MMR IRP. In response to that request, the U.S. Air Force assumed the lead role in the execution of

the IRP and assigned AFCEE to manage the program (Amendment 1 to the FFA). Under

Amendment 2, additional enforceable milestones and the Plume Response Decision Criteria and

Schedule were added to the FFA. More recently, the U.S. Department of Transportation (Coast

Guard) has been removed from its status as a party to the FFA (Amendment 3 to the FFA).

Amendment 4 added Section 7003 of the Resource Conservation and Recovery Act

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(RCRA) to the FFA in order to address contamination caused solely by petroleum releases that fall

within the scope of the CERCLA “petroleum exclusion” described in the last sentence of CERCLA

Section 101(14).

Because of the reported spills of fuel at the FS-2 study area, it was identified as a potential hazardous

waste site (Metcalf and Eddy, Inc. 1983). Investigative activities at AOC FS-2 taken before and

during the 1991 remedial investigation (RI) at FS-2 included reviewing historical site records,

excavating test pits, conducting a soil-gas survey, drilling borings to sample subsurface soil and

groundwater, sampling surface soil, mapping the nature and extent of contamination, and conducting

human health and ecological risk assessments. The 1991 draft RI report for FS-2 (E.C. Jordan 1991)

concluded that no further groundwater and subsurface soil sampling was necessary and that a No

Further Action alternative was appropriate for these media; it also concluded, however, that some

of the surface soil at the site posed human health risks that should be the focus of a feasibility study

for AOC FS-2.

At the same time the draft FS-2 RI report was being reviewed (1991-1992), remedial alternatives for

three other MMR sites (Chemical Spill [CS]-4, FS-25, and Fire Training Area [FTA]-1, which had

completed RIs) were evaluated collectively in one engineering evaluation and cost analysis (EE/CA)

due to similarities in site conditions and contamination. With public input, excavation and thermal

treatment of soil was selected as the remedy for these AOCs. Design and construction of a

low-temperature thermal treatment system began at MMR to thermally treat the contaminated soil

from CS-4, FS-25 and FTA-1. In 1993, a technical memorandum recommended including the

contaminated surface soil from FS-2 in the thermal treatment project (ABB 1993). The

recommendation was implemented because the FS-2 surface soil contamination could be destroyed

successfully by thermal treatment, and including AOC FS-2 in the project would not significantly

increase the project schedule or costs. In 1996, approximately 520 tons of soil were removed from

FS-2 and treated at the low-temperature thermal treatment system (EHRT 1996).

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The Southwest Operable Unit (SWOU) RI conducted in 1998 concluded that groundwater flowing

from the AOC FS-2 did not pose any unacceptable risks to human health or the environment

(AFCEE 1999c). However, the SWOU RI identified a former maintenance pit at FS-2 where

subsurface soil had not been sampled during the previous investigations. In addition, when the 1991

FS-2 RI report was reviewed in 1999, sufficient uncertainties were identified to warrant a

supplemental RI to confirm the absence of contamination in surface and subsurface soils.

AFCEE conducted a supplemental RI at FS-2 in 2000 (ATCEE 2001b). This investigation focused

on evaluating the nature and extent of petroleum-based organic contaminants that may have

remained in surface and shallow subsurface soils, sampling surface and subsurface soils within the

former maintenance pit, and evaluating the level of risk site contaminants might pose to human

health and ecological receptors.

The supplemental RI concluded that no further assessment or remedial action is warranted for site

soils. Although the initial 1991 FS-2 RI report was not finalized, comments from the regulatory

agencies were resolved in 2000. The Final FS-2 Supplemental RI Report (AFCEE 2001b) was issued

in January 2001, and the Proposed Plan (AFCEE 2001a) was issued in May 2001.

2.3 COMMUNITY PARTICIPATION

The MMR IRP has a very robust community involvement program that provides many opportunities

for the public to become involved in the investigation and decision-making process. Public meetings

and poster board sessions are held, display ads are placed in newspapers to announce significant

events and meetings, news releases are issued, tours of the sites and treatment facilities are

conducted, neighborhood notices are distributed to notify people of events impacting their

neighborhoods, and public notices of other kinds are issued.

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In addition, several citizen teams advise the IRP and the regulators about the program. They include

the Senior Management Board and the Plume Cleanup Team (PCT)1. The PCT is composed of the

Plume Containment Team, the Long-Range Water Supply Team, and the Public Information Team.

All these teams are composed of citizen volunteers and government representatives working together

to resolve problems and complete the cleanup. All citizen team meetings are open to the public.

Certain teams are decision-making teams. They include the Executive Review Group, the

Management Review Group, and the Remedial Project Managers. A technical advisory team called

the Technical Review and Evaluation Team advises the decision-making teams. Assumptions about

reasonably anticipated future land use and potential beneficial uses of groundwater and surface water

are regularly discussed in these meetings.

The public has been kept up to date on the progress of FS-2 investigation and assessment activities

through the various public and citizen team meetings described above. The original RI report (E. C.

Jordan 1991) presented the assessment of contamination at AOC FS-2 prior to the excavation and

treatment of soil. The public comment period for the supplemental RI work plan was conducted from

17 April to 01 May 2000. The supplemental RI report (AFCEE 2001b) describes the extent of

contamination at AOC FS-2 and was made available to the public in January 2001. These documents

can be found in the Administrative Record file maintained at the MMR IRP office, the Falmouth,

Bourne, Mashpee, and Sandwich public libraries, and at the USCG library located on MMR.

Appendix B of this report presents an index of the Administrative Record for AOC FS-2.

The notice of availability of the Proposed Plan was published on 04 May 2001 in the Falmouth

Enterprise, the Bourne Enterprise, the Mashpee Enterprise, and the Sandwich Enterprise, and on 10

May 2001 in the Cape Cod Times. The public comment period was from 16 May 2001 to 14 June

2001. A public meeting was held on 15 May 2001 to present the proposed plan to a broad

community audience. At this meeting,

_________________________

1 Prior to June 2001, the PCT was known as the Joint Process Action Team (JPAT).

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representatives from AFCEE presented the justification for no further action and answered questions

from the audience. On 07 June 2001, a public hearing was held to receive formal public comment,

which is included in the official record (Appendix C). The proposed plan for FS-2 was also presented

and discussed at two PCT meetings (09 May and 13 June 2001). AFCEE’s responses to all the

comments received during the comment period are included in the Responsiveness Summary, which

is Section 3.0 of this ROD.

2.4 SCOPE AND ROLE OF AREA OF CONTAMINATION (AOC)

The remedy for soil and groundwater at AOC FS-2 is part of the overall cleanup program for soil and

groundwater at MMR. The overall MMR environmental cleanup program goal for groundwater is

100 percent capture of all plumes above maximum contaminant levels or other risk-based levels, and

treatment of contaminants to background levels if technically and economically feasible. The

program’s principles include pursuing remedial action strategies that are cost-effective while being

fully protective of human health and the environment.

Examples of remedial actions that support this strategy are documented in:

• Record of Decision for Interim Remedial Action: West Truck Road Motor Pool (AOC CS-4)Groundwater Operable Unit (HAZWRAP 1992).

• Final Record of Decision, Area of Contamination FS-1 (AFCEE 2000a)

• Final Record of Decision for the CS-4, CS-20, CS-21, and FS-13 Plumes (AFCEE 2000c).

Numerous source control actions have been undertaken as part of MMR’s strategy to promptly

remove sources of continuing groundwater contamination. Examples of source area removal/control

actions that support this strategy are documented in:

• Final Record of Decision, Area of Contamination CS-10/FS-24 Source Areas (AFCEE 1999b)• Final Record of Decision, Areas of Contamination CS-16/CS-17 Source Areas (AFCEE 1999d)

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• Final Record of Decision, Areas of Contamination FTA-2/LF-2, PFSA/FS-10/FS-11,SD-2/FS-6/FS-8, SD-3/FTA-3/CY-4, SD-4, and SD-5/FS-5 Source Areas (AFCEE 1998a).

When analysis of the environmental data at a site indicates that the remaining contamination poses

no significant risk to human health or the environment, the site is removed from the overall MMR

cleanup program. The decision for No Action or No Further Action has been made for several sites

at MMR, and examples are documented in:

• Final Decision Document, Study Area CS-14 (AFCEE 2000b)

• Final Record of Decision, Area of Contamination FS-17 and Area of Contamination FS-19(AFCEE 1999a)

• Record of Decision, AOC CS-3 (USCG) 3-in-1 Store (AFCEE 1998b).

This ROD for AOC FS-2 is consistent with CERCLA and the overall cleanup strategy for MMR, and

is fully protective of human health and the environment.

2.5 SITE CHARACTERISTICS

AOC FS-2 is located within the Mashpee Pitted Plain. This unit, consisting of well to poorly sorted,

fine- to coarse-grained sand, forms a broad outwash plain located between the Sandwich Moraine

and the Buzzards Bay Moraine, situated to the north and west, respectively. The shallow subsurface

geology beneath FS-2 was further defined during soil boring advancement. The area is underlain

primarily by medium-dense, medium-grained sand (Unified Soil Classification System designation

SP), containing a trace to little fine and coarse sand, silt, and fine gravel. This deposit is part of the

upper section of the Mashpee Pitted Plain.

The land at the FS-2 source area is not identified as a high priority site for rare species or as an

exemplary natural community. No state-listed rare plants or animals have been observed at the

project site during field surveys.

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AOC FS-2 consists of 5.5 acres of land located at the end of Guenther Road, adjacent to the southern

boundary of the MMR golf course. Currently, the site exists as flat, unvegetated, unimproved land,

traversed by two railway lines that parallel the golf course. There are no surface water features in the

vicinity of the FS-2 source area. A concrete roadway lies to the south of the tracks. To the south of

the roadway is undeveloped land consisting of thick pine, scrub, oak and brush. The site is not

currently being used, and access is unrestricted. Trains traveling to and from the local waste transfer

station pass through the site twice per day.

From 1955 to 1965, the site was used to operate a petroleum unloading and transfer station. Aviation

gasoline (AVGAS) and jet propellant fuel (JP-4) were unloaded from railroad tank cars and tanker

trucks and conveyed through underground piping to the MMR PFSA. Previous historical record

searches indicated that as much as 110,000 gallons of petroleum product might have been released

during the operational life of the station (E. C. Jordan 1990). Field investigations have detected

petroleum compounds (volatile organic compounds [VOCs], SVOCs, extractable petroleum

hydrocarbons [EPHs], volatile petroleum hydrocarbons [VPHs], polyaromatic hydrocarbons

[PAHs]), and metals in soils at AOC FS-2.

The sampling strategy for the FS-2 investigations conducted from 1985 to 2000 included geologic,

hydrogeologic, and chemical characterization of groundwater and soil. Several tasks were performed

to improve the understanding of the source study area geology and hydrology, including test pitting,

drilling, and well installation. Detailed elements of the field investigations are summarized in the

original remedial investigation documents (E. C. Jordan 1991; AFCEE 2001b).

Figures 2-4 and 2-5 show the locations of surface soil sampling points, test pits, soil borings, and

monitoring wells used for the pre-2000 field investigations discussed in Section 2.5.2.

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2.5.1 Conceptual Model of FS-2

Some of the fuel spilled at the AOC FS-2 volatilized before infiltrating into the ground, and some

of the fuel that infiltrated into the ground at FS-2 adhered to the soil matrix and was chemically

degraded over time. The compounds that presently remain in subsurface soils are weathered and

relatively immobile. The more mobile compounds in the fuel spilled at AOC FS-2 entered the

aquifer through infiltration of precipitation. At AOC FS-2, the water table is approximately 45 feet

below ground surface (ft bgs), and groundwater flows in a south-southwesterly direction As

precipitation passed through the unsaturated (vadose) zone, contaminants bound in the soil matrix

were dissolved and carried down by gravity to the water table. The contaminated water then entered

the aquifer and migrated downgradient to form a plume. As the plume migrated further

downgradient, clean precipitation accumulated at the water table above the plume, forming a wedge

of clean water over the plume. This wedge of clean water forces the plume deeper into the aquifer

with increasing distance from the source area. Through natural processes such as dissolution and

degradation and by subsequent remedial action, contaminants were removed from the source area.

These processes caused the plume to detach from the source area as clean water flushed through the

aquifer in the source area. Presently, there is no plume of fuel-related groundwater contamination

beneath or immediately downgradient of AOC FS-2. Figure 2-6 depicts the path of water that would

have originated at the FS-2 source area. AFCEE managed the investigation and remedy selection for

the area downgradient of AOC FS-2, using a regional approach (rather than a plume-specific

approach) in the designation of this area as the Southwest Operable Unit (SWOU). The source areas

for the FS-28, FS-29, CS-20 and CS-21 SWOU plumes have not been identified. The investigations

concluded that the ethylene dibromide (EDB) within the FS-28 plume probably originated from fuels

spilled at more than one specific area of MMR. It is likely that AOC FS-2 is one of the sites that

contributed to the FS-28 plume. It is also possible that fuel contamination originating at FS-2

discharged to Coonamessett Pond.

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2.5.2 Sampling Strategy and Contamination Assessment

This section describes the historical sampling efforts and applicable contaminant results from FS-2.

Data from the initial RI (E. C. Jordan 1991) are summarized in Appendix D, and the pertinent data

from the more recent supplemental RI (AFCEE 2001b) are summarized in Figures 2-7 through 2-9.

It is noteworthy that data from older investigations are approximately a decade old. As such, they

contribute minimally to the basis for the selected remedy of No Further Action. Significant natural

(e.g., biological degradation) and anthropogenic (e.g., soil removal and treatment) activities have

modified the contamination characteristics at AOC FS-2, so pre-treatment measurements are not

considered in the summary of site risks discussed in Section 2.7.

R. F. Weston Inc. conducted a site inspection in 1985, which included excavating 18 test pits and

installing two monitoring wells (R. F. Weston, Inc. 1985). Weston’s study did not identify fuel

contamination in near-surface soils, but liquids sampled from header pipe openings contained

naphthalene, ethylbenzene, toluene and xylenes. Groundwater from one well located downgradient

of AOC FS-2 (03MW0603D) contained ethylbenzene, xylenes and 4-methyl-2-pentanone.

In 1989, a soil-gas survey and soil sampling at two test pits and four soil borings were completed.

One groundwater monitoring well was installed in each of the borings. The soil-gas survey involved

the advancement of 42 sampling points throughout AOC FS-2 to a maximum depth of 5 ft bgs. Trace

concentrations of trichloroethene (TCE), toluene, and xylenes were reported. It was concluded that

no discernable contaminant pattern was present and that the results did not indicate the presence of

significant shallow soil contamination (E. C. Jordan 1990). SVOCs were present in the surface soil

sample recovered from the boring (32MW0003) (Figure 2-4) drilled to the east of the pump house

(Appendix D). Trace SVOCs were detected in the surface soil samples taken from borings drilled

adjacent to the pump house (32MW0001), and adjacent to the northernmost rail line (32MW0002

and 32MW0004). The pesticide dieldrin was measured at 25 micrograms per kilogram (µg/kg) in

the surface soil sample collected from the boring drilled adjacent to the former pump house

(32MW0001). The following

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metals were detected in the samples: aluminum, arsenic, chromium, iron, lead, and mercury (only

one sample). The highest metal concentrations were reported for the surface soil samples.

Based on the investigation work conducted in 1989, it was concluded that soil at the FS-2 source

area did not show a significant impact from historical fuel-handling activities. The elevated

concentrations of SVOCs in one of the surface samples were attributed to the mixture of fine coal

particles within the soil matrix and not to fuel-handling practices. The analytes detected in FS-2 soil

were similar to those detected in shallow soil samples collected from a former coal yard in another

section of the MMR (E. C. Jordan 1991). This coal yard was located immediately southeast of AOC

FS-2, along the tracks that crossed FS-2.

The draft RI report was completed in February 1991 (E. C. Jordan 1991). RI fieldwork included the

sampling and analyses of groundwater, surface soil, subsurface soil, and the residual liquid from the

header pipes. Residual liquid in one of the header pipes was sampled and analyzed for VOCs, total

petroleum hydrocarbons (TPH), and lead. This sample contained 180 milligrams per liter (mg/L) of

TPH. Based on visual inspections, water/fuel mixtures occurred in two of the headers. It was

subsequently concluded that the header piping was not a continuous source of contamination and that

the piping did not appear to be leaking (E. C. Jordan 1991). This piping was removed from the

ground in 1992.

During the sampling of surface soil in the vicinity of 32MW0003, a thin, 1- to 2-inch layer of

oil-stained soil was identified adjacent to the well. This layer extended beyond the immediate

vicinity of 32MW0003. In one surface soil sample collected adjacent to the well (SS-1), individual

SVOCs were present in concentrations ranging from 10 to 51 milligrams per kilogram (mg/kg). A

number of surface soil samples were also tested for TPH and metals. TPH was not detected. The

following metals were detected: aluminum, arsenic, copper, iron, lead, manganese, vanadium, and

zinc.

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Two surface soil samples were collected adjacent to the former pump house (SS-7 and SS-8) (Figure

2-4). SVOCs similar to those found in soil adjacent to 32MW0003 were detected in these samples

at concentrations ranging from 0.38 to 5.2 mg/kg. In addition to the sampling, hand digging was

completed in this area to determine the extent of discolored soil that was identified in test pits dug

in 1985. Based on the results of the RI and previous work, it was concluded that historical fuel spills

had caused the near-surface soil stains and contributed to the petroleum contamination of shallow

soil near the pump house and adjacent to 32MW0003. Aluminum, arsenic, chromium, lead,

manganese, vanadium, and zinc were detected at concentrations 10 times the established background

level. The elevated concentrations of lead and the occurrence of the other metals were attributed to

spills of lead-containing AVGAS and the use of the area as a railroad yard (E. C. Jordan 1991).

Following soil excavation and treatment in 1996 (Section 2.2), groundwater sampling was completed

in May 1998 as part of the SWOU RI (AFCEE 1999c). Groundwater samples were collected from

eight shallow wells (02MW1202C,E, 02MW1203A, 03MW0603D, 32MW0003, 32MW1302,

32MW1307, and 32MW1308) located in and around AOC FS-2 (Figure 2-5). Concentrations of the

fuel-related VOCs ethylbenzene (11 micrograms per liter [µg/L]) and xylenes (20 µg/L) were

detected in groundwater sampled from one well (02MW1202E) located 450 feet south and

hydraulically downgradient of FS-2. The concentrations were well below the respective 700- and

10,000-µg/L drinking water standards established for these compounds. Risks to human health

associated with FS-2 groundwater, as quantified during the SWOU RI, are discussed in Section 2.7

of this report.

A supplemental RI was carried out in April 2000 to investigate the extent of any remaining

petroleum contamination in surface and shallow subsurface soil at FS-2. This investigation involved

the advancement of 10 soil borings across AOC FS-2 to a depth of 20 ft bgs, the recovery of soil

samples, field screening for volatiles, and laboratory analyses. Results of these investigations showed

that some petroleum-derived SVOCs remained in the soil at AOC FS-2 (Figures 2-7 and 2-8). The

highest concentrations were

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detected in samples collected near the former AVGAS and JP-4 header pipes and at the former

railroad maintenance pit. At the header locations, total SVOC concentrations in soils between 0 and

20 ft bgs ranged from 638 to 13,479 µg/kg. At the former maintenance pit, total SVOCs were

detected at 8,598 µg/kg. Lower concentrations of total SVOCs ranging from 526 to 1,205 µg/kg were

detected in samples collected adjacent to the former pump house and 32MW0003. These detections

did not extend below 6 feet at these locations. These soil SVOCs are expected to remain relatively

immobile, and lighter compounds are expected to continue weathering over time.

Analyses for metals were also part of the supplemental RI. Metals were found in FS-2 soils at levels

equivalent to background levels, and given the physical and chemical site conditions, the metals are

not expected to migrate from the site. As discussed in Section 2.7.1, arsenic in the surface soil

(Figure 2-9) was evaluated because of the potential for this metal to pose human health risks.

2.6 CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES

This section discusses the current and reasonably anticipated future land uses and current and

potential beneficial groundwater uses in the vicinity of the FS-2 source area.

2.6.1 Land Use

The FS-2 site is currently undeveloped. Future land use most likely will be recreational or industrial.

It is possible, although unlikely, that future land use could be residential or agricultural.

2.6.2 Water Resource Use

The aquifer throughout upper Cape Cod, referred to as the Sagamore Lens, is generally highly

transmissive and is a potentially productive aquifer. Because the Sagamore Lens is designated as a

sole-source aquifer, all future groundwater use, regardless of location, is considered residential from

a regulatory perspective.

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Current groundwater uses in the town of Falmouth include residential, agricultural, and commercial.

All residences potentially impacted by contaminants from the FS-2 source area are connected to

public water supplies. Some residences also have private wells for nonpotable purposes. Agricultural

uses include those associated with cranberry bogs and small farms in the area. Surface water bodies,

which are generally fed by groundwater, provide recreational opportunities, including wading,

swimming, and fishing.

AFCEE has developed a working relationship with the water commissioners of the town of Falmouth

to ensure that future development of the groundwater resource is coordinated with planned and

ongoing remediation at MMR.

2.7 SUMMARY OF SITE RISKS

The baseline risk assessments estimate what risks the site poses if no action were taken. If

contaminants and exposure pathways need to be addressed by remedial action, they are identified

by the risk assessments. This section of the ROD summarizes the results of the human health and

ecological baseline risk assessments for the FS-2 site, which were conducted as part of the

supplemental RI based on soil data collected in 2000 and groundwater data collected in 1998. These

risk assessments form the basis for the No Further Action decision.

2.7.1 Summary of Human Health Risk Assessment

This section summarizes the baseline human health risk assessment conducted as part of the FS-2

supplemental RI. The following subsections focus primarily on exposure pathways, environmental

media, and contaminants of potential concern that contributed to potential unacceptable site risks.

A complete description of the methods and results of the baseline human health risk assessment is

presented in Section 7.1 of the Final Fuel Spill-2 Supplemental Remedial Investigation Report

(AFCEE 2001b).

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2.7.1.1 Identification of Contaminants of Concern

Contaminants of concern (COCs) are those chemicals identified in the risk assessment that pose a

significant current or future risk, and are sometimes referred to as risk-drivers. The process of

identifying COCs for human health began with the identification of contaminants of potential

concern (COPCs). In accordance with EPA Region I guidance, COPCs are identified as compounds

detected at concentrations greater than Region IX risk-based preliminary remediation goals (PRGs).

Exceeding a PRG suggests that further evaluation of the potential risks that may be posed by site

contaminants is appropriate (EPA 1999). Infrequently detected compounds and essential nutrients

were not retained as COPCs. For organic compounds, background concentrations are not used in the

process of selecting COPCs; although after risks have been quantified, background concentrations

are considered in the process of selecting COCs.

Benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, dibenzo(a,h)anthracene,

ideno(1,2,3-cd)pyrene, C11-C22 aromatic hydrocarbons, and arsenic were identified as COPCs in

FS-2 soil. Of the seven COPCs, only benzo(a)pyrene and arsenic could be considered possible COCs

for FS-2 soil because human health risks were well below acceptable levels for the five COPCs.

Because different receptor types could be exposed to site soil in different ways, the risks were

calculated separately for soils 0 to 2 ft bgs, 0 to 10 ft bgs, and 0 to 20 ft bgs. The risk calculations

utilized the 95 percent upper confidence limit (UCL) of the detected concentrations for the exposure

point concentration, which were calculated separately for each depth range (Tables 2-1, 2-2, and

2-3).

The SWOU RI investigated and evaluated groundwater quality beneath and downgradient from the

southwest portion of the cantonment area. In an area larger than 7 square miles, the SWOU RI

evaluated historical data for groundwater beneath known and suspected potential source areas

(including AOC FS-2) and investigated groundwater quality beneath known and suspected detached

groundwater plumes. The SWOU RI specifically included sampling eight shallow wells to evaluate

the potential risks associated with FS-2 groundwater. Table 2-4 shows the occurrence, distribution

and selection of COPCs for

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the FS-2 groundwater data from which arsenic was identified as a COPC, but not a COC.

Throughout the entire SWOU area, arsenic was detected in seven out of 112 dissolved fraction

(filtered) samples and in five out of 106 total fraction samples. No discernable pattern was identified

by the distribution of the detected arsenic. However, the following observations were noted in the

SWOU RI:

• The three highest detections were more than a mile away from any other detections. Thedistribution of arsenic is irregular and not particular to any VOC plume(s).

• The highest detection (11.1 µg/L) was within the FS-13 plume.

• The second highest detection (7.5 µg/L) was downgradient of FS-2.

• All wells with detectable concentrations of arsenic were located north of Route 151, suggestingthat if arsenic is related to past waste practices, it has not migrated far from the base.

When remedial action objectives were developed for the SWOU plumes and COCs were identified

on a plume-specific basis, arsenic was not retained as a COC for SWOU groundwater. Arsenic is not

considered a COC for FS-2 groundwater. With no COCs or discernable plumes associated with FS-2

groundwater, it is concluded that there are no unacceptable risks to human health associated with

future residential exposure to FS-2 groundwater and that remedial action is not warranted.

2.7.1.2 Exposure Assessment

Future land use of FS-2 has not been determined. Based on MMR’s historical use as a military base,

it is unlikely that the site would be used for residential or commercial/industrial purposes. A more

likely future use is open space or recreational (e.g., if the golf course was expanded). Therefore,

people who might access the FS-2 site under current land use conditions would likely include

trespassers and/or recreational visitors. The current and future risks posed to a future adolescent

trespasser by inhalation, dermal contact, and ingestion of COPCs in FS-2 soils 0 to 2 ft bgs were

quantified in the risk assessment. According to the conceptual site exposure model, it was assumed

that no current exposure exists to site workers or residents.

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Any future development of the site would necessitate construction and/or utility workers accessing

the site. In the absence of a specific future use development plan, the human health risk assessment

incorporates the assumption that the future site use will be residential to provide a conservative

assessment of risks associated with unrestricted future uses. Under this land use, it is assumed the

residential dwellings could be constructed anywhere within the site boundaries. The risks posed to

a future adult construction worker by inhalation, dermal contact, and ingestion of site COPCs in FS-2

soils 0 to 20 ft bgs were quantified in the risk assessment. Risks were also quantified for future child

and adult residents who may similarly be exposed to FS-2 soils 0 to 10 ft bgs. Tables 2-5, 2-6, 2-7,

2-8, and 2-9 present the route-specific exposure assumptions for these receptors.

2.7.1.3 Toxicity Assessment

Table 2-10 provides non-carcinogenic toxicity information that is relevant to the COPCs for FS-2

soils. Two of the COPCs have toxicity data indicating their potential for adverse non-carcinogenic

health effects in humans. The chronic toxicity data available for oral exposure to both arsenic and

C11-C22 aromatics were used to develop oral reference doses (RfDs). Dermal RfDs for both arsenic

and C11-C22 aromatics were derived from the oral RfDs. No oral or dermal RfDs were available for

EPHs or the five semivolatile COPCs. However, using surrogate dose-response values from similarly

structured PAHs to quantify hazard index (HI) values, the risk assessment concluded that the absence

of published RfDs for the five semivolatile COPCs does not represent an uncertainty that has a large

bearing on the risk assessment. No inhalation reference concentrations were available for any of the

COPCs except for C11-C22 aromatics. However, since the dust inhalation exposures are associated

with very low COPC exposures, inhalation doses, if calculated, would be orders of magnitude lower

than oral and dermal doses. Consequently, even if inhalation toxicity data were available, the results

of the risk assessment would not likely change.

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Table 2-11 provides carcinogenic risk information for the COPCs for FS-2 soils. Oral and inhalation

cancer slope factors were available for the five SVOCs that are probable human carcinogens and for

the human carcinogen arsenic. The dermal cancer slope factors were derived from the oral cancer

slope factors. No cancer slope factor was available for EPHs, and C11-C22 aromatics are not

classifiable as a human carcinogen.

2.7.1.4 Risk Characterization

The potential for noncarcinogenic effects is evaluated by comparing an exposure level over a

specified period of time with an RfD derived for a similar exposure period. An RfD represents a

level that an individual may be exposed to that is not expected to cause any deleterious effect. The

ratio of exposure to toxicity is called a hazard quotient (HQ). An HQ greater than 1 indicates that

a receptor’s dose of a single contaminant is less than the RfD and that toxic noncarcinogenic effects

from that chemical are unlikely. The HI is generated by adding the HQs for all COPCs that affect

the same target organ within a medium or across all media to which a given individual may be

exposed. As previously mentioned, the maximum HI for COPCs in FS-2 soils was 0.2, indicating

that, based on the sum of all HQs from different contaminants and exposure routes, toxic

noncarcinogenic effects from FS-2 soils are unlikely.

For possible exposure to each medium, carcinogenic risk estimates for known or probable human

carcinogens are calculated by multiplying the cancer slope factor (CSF) or UR of the chemical by

the lifetime average daily dose (LADD) or lifetime average daily exposure concentration (LAEC),

respectively. The product of these two values is an estimate of the excess lifetime cancer risk

(ELCR), which is defined as the excess probability that an individual will develop cancer over a

lifetime due to exposure to the COPC. This incremental lifetime risk is over and above what is

considered an individual’s background chances of developing cancer. In the United States,

approximately one in three people develop cancer during their lifetime (American Cancer Society

1997).

The ELCR for each chemical in each medium is calculated as follows:

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ELCRi = LADDi x CSFi

Where:

ELCRi = Excess lifetime cancer risk associated with the exposure to chemicalin each exposure route for the relevant medium.

LADDi = Lifetime average daily dose of substance i in each medium receivedby the theoretical individual.

CSFi = Cancer slope factor for substance i in the appropriate medium.

The ELCR (a unitless value usually expressed in scientific notation) is compared to acceptable risk

ranges for risk management decisions. The EPA risk range for site-related exposures is 1E-04 to

1E-06, and the DEP risk management threshold is 1E-05. Cancer risks calculated for the future

construction worker resulted in a maximum ELCR of 5E-07, which is not considered an

unacceptable risk by the EPA and DEP. Cancer risks to the current/future trespasser and future

residents from exposure to FS-2 soils are summarized in Table 2-12.

In comparison to the oral and dermal exposure pathways, inhalation of FS-2 site contaminants is

insignificant. Inhalation risks were several orders of magnitude below risk management criteria.

The ELCR for the current/future trespasser is 2E-06, below the DEP risk threshold, and near the

lower end of the EPA target range. The maximum ELCRs were calculated as 6E-06 and 1E-05 for

future adult and child residential receptors, respectively. The combined maximum risk for a lifetime

exposure (combined child and adult exposure) is 2E-05, which exceeds the DEP risk limit and is

within the EPA target risk range.

Although the ELCR for the residential scenario of exposure to soils 0 to 10 ft bgs (2E-05) is above

the Massachusetts Contingency Plan (MCP) risk limit (1E-05), the risks were calculated using

methods consistent with EPA Region I risk assessment guidance for Superfund, as opposed to DEP

guidance for disposal site risk characterization. Although

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EPA Superfund risk assessment methods and DEP Method 3 risk characterization methods are

fundamentally very similar, there are a few details concerning exposure input parameters that differ

between the two methods. Those that have the largest bearing on the risk assessment outcome are

as follows:

EPA Region I DEP

Exposure Point Concentration 95% UCL Arithmetic Mean

Soil Ingestion Rate – Child 200 mg/day 100 mg/day

Soil Ingestion Rate – Adult 100 mg/day 50 mg/day

Averaging Time – Cancer 70 years 75 Years

If the default soil ingestion rates used in a DEP Method 3 risk characterization were applied to

estimate risks for the residential scenario (soils 0 to 10 ft bgs) evaluated in this risk assessment, the

ingestion risk estimates would decrease by half. As shown in the comparison below, the use of the

DEP default soil ingestion rates in the residential soils 0 to 10 ft bgs scenario results in cumulative

cancer risk estimates that do not exceed the MCP cumulative receptor risk limit of 1E-05. Had the

other DEP default input parameters listed above also been used (i.e., arithmetic mean concentration

rather than 95 percent UCL as the exposure point concentration, and averaging time of 75 years

rather than 70 years), the risks would be lower than those presented below.

Receptor / Pathway

(Soils 0–10 ft bgs)

ELCR

EPA Parameters a DEP Parameters b

Child – Ingestion 9E-06 4E-06

Child – Dermal 3E-06 3E-06

Child – Inhalation 2E-10 2E-10

Child -TOTAL 1E-05 7E-06

Adult – Ingestion 4E-06 2E-06

Adult – Dermal 2E-06 2E-06

Adult – Inhalation 6E-10 6E-10

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Receptor / Pathway

(Soils 0–10 ft bgs)

ELCR

EPA Parameters a DEP Parameters b

Adult - TOTAL 6E-06 4E-06

Resident - TOTAL 2E-05 1E-05a Risks were calculated using EPA Region 1 default exposure parameters. These values were calculated in the

baseline risk assessment and are presented in Table 2-12.b All risks presented were calculated using the EPA input parameters/methods. However, soil ingestion risks were

multiplied by factors of 100/200 (child) and 50/100 (adult) to reflect recalculated risks using the DEP default soilingestion rates.

This evaluation demonstrates that soils at FS-2 do not pose cancer risks in excess of the MCP

cumulative receptor risk limit of 1E-05. Moreover, the arithmetic mean concentrations of all COPCs

in soils 0 to 10 ft bgs are below their respective MCP Method 1 standards (S-1/GW-1 standards).

This further indicates that the site poses a “Condition of No Significant Risk” in accordance with the

MCP. Therefore, no further remedial action is warranted for site soils.

2.7.1.5 Uncertainty Analysis

Because risk assessments rely not just on measured or certain facts, but also on assumptions and

estimates, risk assessments have historically used highly conservative assumptions in the place of

unavailable data, with the net result often being a substantial overestimation of potential risks.

Common areas of uncertainty include the frequency, duration, and magnitude of possible exposure,

the chemical-specific toxicity values, the one-size-fits-all exposure factors (e.g., body weight and

ventilation rates), and possible synergistic or antagonistic chemical interactions. This section

summarizes how assumptions made in the face of uncertainty may have affected the results and

conclusions of the assessment.

The standard of care for environmental risk assessments for addressing many of the common areas

of uncertainty is to use upper-bound (90th or 95th percentile) estimates of input values, such as

exposure parameters and toxicity values. Some intake variables may not be at their individual

maximum values, but when considered in combination with other variables, will result in estimates

of the reasonable maximum exposure (RME).

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According to EPA (1989), the RME is intended to represent the highest exposure that is reasonably

expected to occur at a site. Thus, the RME will tend to overestimate potential exposures for the

majority of the population.

The primary uncertainties in the risk assessment are identified below:

• Given the current and probable future land use, the selection of frequent and long-term exposureof workers and residents adds conservatism to the assessment.

• Conservative assumptions (e.g., trespasser accessing the FS-2 site four times per week for 11years) were built into the exposure parameters.

• The exposure point concentrations were calculated from an environmental investigation focusedon characterizing the most likely contaminated soils. Additional conservatism results fromassuming that future residents would be exposed to contaminants in soils from 0 to 10 ft bgs.

• Cancer slope factors and non-cancer RfDs were not available for all of the COPCs, so somepotential contributions to total human health risks could not be quantified, although the riskassessment concluded that for the COPCs and pathways of concern, this contributes littleuncertainty to the overall assessment.

• Although the FS-2 groundwater data collected as part of the SWOU RI were used in the SWOUbaseline risk assessment, the risks specific to FS-2 groundwater were not calculated separatelybecause the only COPC retained for consideration (arsenic) was present in just one sample, andthese risks were not attributed to the FS-2 site.

Overall, given the extensive investigation at the site and the application of conservative risk

assessment methods and assumptions, the results and conclusions of the risk assessment represent

a sound, defensible characterization of potential current and future risks to human health.

2.7.2 Summary of Ecological Risk Assessment

The baseline ecological risk assessment (ERA) for the FS-2 study area was completed to provide a

screening-level evaluation of potential risks that contaminants of potential ecological concern

(COPECs) in surface soil may pose to ecological receptors at the site. The following subsections

summarize the baseline ecological risk assessment conducted as part of the FS-2 supplemental RI.

This summary focuses primarily on exposure pathways, environmental media, and contaminants of

potential concern that contributed

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to potential unacceptable site risks. A complete description of the methods and results of the

ecological risk assessment is presented in Section 7.2 of the Final Fuel Spill-2 Supplemental

Remedial Investigation Report (AFCEE 2001b).

2.7.2.1 Identification of Chemicals of Potential Ecological Concern

For the selection of COPECs, supplemental RI data collected from a depth of 0 to 2 ft bgs were

evaluated (Table 2-13). Maximum concentrations of detected compounds were compared to relevant

soil benchmarks (Table 2-14). These screening values for soils are based on toxicological

benchmarks for plants and earthworms developed by Efroymson and others (1997a, 1997b), and

calculated PRGs for wildlife (Sample et al. 1996). Benchmarks for the three types of organisms

(wildlife, plants and soil invertebrates) were compared by Efroymson and others (1997a), and the

lowest value available was selected as the PRG. The comparison indicates that concentrations of

chromiulm, lead, mercury, selenium, vanadium, zinc and manganese exceed the respective PRGs.

Additional compounds were selected as COPECs if no screening levels were available and the

compounds were likely to be associated with historical releases (i.e., PAHs and VPHs/EPHs as

petroleum constituents) at the site.

COPECs for ecological receptors are summarized in Table 2-14.

2.7.2.2 Exposure Assessment

The available habitat at the FS-2 study area provides potential forage and cover for a number of

small mammals and birds, including robins, mockingbirds, and small mammals such as mice and

voles. The site may also provide habitat for the eastern box turtle, a state-listed species known to

inhabit the MMR area, and the upland sandpiper, which is considered an endangered species

according to the Commonwealth of Massachusetts. The forested habitat adjacent to the site may

provide cover for a variety of terrestrial receptors, including mammals and small birds. Passerine

songbirds and other avian receptors may forage in grassed portions of this site.

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No rare plant species, as listed by the Massachusetts Natural Heritage and Endangered Species

Program, have been observed at the FS-2 study area. The eastern box turtle (Terrapena carolina

carolina), a state-listed species of special concern, has been observed nearby and may utilize the

open areas for nesting sites. The following terrestrial wildlife receptors, representing a range of

taxonomic groups and trophic levels, were used to evaluate risk from surface soil contamination in

the FS-2 study area ERA:

• White-footed mouse (granivorous/omnivorous small mammal)

• American robin (omnivorous small bird; year-round resident)

• Upland sandpiper (insectivorous migratory bird)

• Box turtle (omnivorous reptile)

• Short-tailed shrew (vermivorous small mammal).

The white-footed mouse and robin could potentially use the limited habitat at the FS-2 study area.

The short-tailed shrew was included to represent vermivorous (worm-eating) small mammals that

could potentially forage at the site. The shrew typically inhabits forested areas, and may inhabit the

forested areas surrounding the site; it could potentially forage in the open grass areas of the site.

Although the endangered upland sandpiper is not known to inhabit the study area, it was included

in this ERA to represent species of insectivorous or omnivorous birds that may periodically inhabit

the FS-2 study area. The box turtle was included because it is a species of special concern that could

inhabit the site. (The closest observance of a box turtle was 2,000 feet away from the FS-2 study

area; this was documented in 1997.)

Higher trophic level organisms such as predatory birds or manunals were not selected as ecological

receptors for this ERA because of the limited availability of suitable habitat, and the small size and

linear shape of the site relative to the foraging range and habits of these animals. Because they forage

over relatively large areas, they are unlikely to obtain a significant portion of their prey from the FS-2

site, and therefore, their exposures are presumed to be negligible.

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The contaminated medium of potential ecological concern at this site is surface soil. Plants,

terrestrial invertebrates, and several representative terrestrial wildlife species were selccted for

evaluation in this ERA.

Because plants and terrestrial invertebrates were assumed to be in direct contact with or ingesting

surface soil, the exposure evaluation for plants and invertebrates was based on representative

statistical concentrations (e.g., maximum detected concentration, average detected concentration)

to the COPECs. These exposure point concentrations are presented in Table 2-15.

Terrestrial wildlife receptors were assumed to be exposed via incidental ingestion of surface soils,

and via ingestion of prey items that have bioaccumulated contaminants in their tissues. Dermal

exposures were not quantitatively evaluated but are assumed to be negligible due to the presence of

fur, feathers, or a chitinous exoskeleton.

The maximum detected concentration of COPECs was used as the worst-case exposure point

concentration to evaluate direct exposure via incidental ingestion. The maximum concentration was

also used to estimate exposures via the food chain using bioaccumulation factors.

Species-specific ecological exposure parameters, used to estimate potential dietary exposure to

surface soil contaminants at the FS-2 study area are presented in Table 2-16. Total body doses were

calculated using the bioaccumulation and uptake factors for invertebrates, plants, mammals, and

birds are presented in Table 2-17.

2.7.2.3 Ecological Effects Assessment

The primary COPECs are PAHs and several inorganics. PAHs and the majority of the inorganic

COPECs may bioaccumulate in plants or terrestrial invertebrates, but they are unlikely to biomagnify

up the food chain. Mercury is one COPEC, however, that is known to biomagnify. Benchmarks used

to evaluate risks to receptor groups are described below.

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Plants and Terrestrial Invertebrates

Effects to plants and terrestrial invertebrates were evaluated using data compiled by Oak Ridge

National Laboratory (ORNL) — toxicological benchmarks for terrestrial plants (Efroymson et al.

1997a) and soil and litter invertebrates and heterotrophic processes (Efroymson et al. 1997b).

Terrestrial Wildlife

The PAHs and inorganics identified at the study area can cause various effects to terrestrial wildlife

receptors, including reproductive effects, systemic effects (e.g., liver, kidney, and neurological

disorders), and tumors including cancer.

NOAELs (no observed adverse effect levels) for most COPECs could be obtained from the available

literature. When a NOAEL could not be identified, the LOAEL (lowest observed adverse effect

level) (if available) was adjusted to an NOAEL by applying an uncertainty factor of 10. Benchmarks

were then adjusted for each receptor (both avian and mammalian).

2.7.2.4 Ecological Risk Characterization

Ecological risk characterization combines the results of the exposure and effects assessments, to

characterize the risk to ecological receptors from exposure to COPECs. A simple comparison of

concentrations with benchmarks was completed for plants and invertebrates. An HQ method was

used to quantify potential risks to wildlife receptors. This method compares maximum exposure

point concentrations with appropriate toxicity values to calculate an HQ; HQs were summed for each

receptor to calculate an HI. If an HI exceeds 1, then the potential may exist for adverse ecological

effects to receptors, and the ecological significance of the HQs comprising the HI is evaluated.

Adverse effects to ecological receptors are not automatically presumed when an HQ or HI exceeds

1; however, as the magnitude of the exceedance increases, the probability of adverse effects also

increases.

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Naturally occurring or background concentrations of COPECs are also considered in interpreting risk

calculations. Chemical concentrations that are within the range of naturally occurring background

levels are generally not considered to pose an unacceptable ecological risk and are unlikely to

warrant a remedial response.

Risks to Plants

Table 2-18 presents a comparison of maximum detected soil concentrations with phytotoxicity

benchmarks. None of the SVOCs exceed their respective benchmark values. Maximum

concentrations of several inorganics (chromium, lead, selenium, and vanadium) exceed the

benchmarks. With the exception of chromium, the benchmarks were exceeded by less than a factor

of 10. Average concentrations (Table 2-15) for lead (20 mg/kg) and selenium (0.43 mg/kg) are below

benchmarks, but average concentrations of chromium (5.9 mg/kg) and vanadium (6.1 mg/kg) exceed

benchmarks. Both average and maximum concentrations of chromium and vanadium are within the

background concentrations for these analytes (Table 2-19).

Risks to Invertebrates

Table 2-20 presents a comparison of maximum detected soil concentrations and invertebrate

benchmarks. With the exception of chromium and manganese, all COPECs are below their

respective benchmarks. The average concentrations of both of these inorganics are below

benchmarks. Although individual invertebrates at the location where the maximum concentration

was detected could potentially be adversely impacted, the limited area represented by this location

and the average concentrations that represent a more likely exposure concentration suggest that

invertebrate populations as a whole at the site are not likely to be adversely affected.

Risks to Terrestrial Wildlife

For terrestrial wildlife receptors (i.e., white-footed mouse, short-tailed shrew, upland sandpiper,

American robin, and eastern box turtle), risks were evaluated by comparing

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estimated doses with toxicity benchmarks. Table 2-21 summarizes the estimated hazard indices for

each receptor, based on a comparison to both NOAEL and LOAEL benchmarks.

For the white-footed mouse and box turtle, NOAEL-based HIs are below 1, indicating that these

receptors are not at risk from exposure to surface soil COPECs. An HI of 3.26 was estimated for the

short-tailed shrew. The primary risk driver is selenium with a NOAEL-based HQ of 1.7; all other

HQs are below 1 for this receptor. For the American robin, a NOAEL-based HI of 11.8 was

estimated. The primary risk drivers for the robin are chromium, lead, selenium, and zinc.

An evaluation of HIs and HQs calculated based on LOAELs provides additional information

regarding the likelihood or magnitude of potential risks. LOAELs represent the lowest effect dose

reported, and therefore, estimated doses that are below LOAELs are generally considered unlikely

to pose an unacceptable risk. Further evaluation of the short-tailed shrew, upland sandpiper, and

American robin using LOAELs resulted in His below 1 for all receptors. Given that the risk drivers

are inorganics that are present at levels consistent with background levels, and that the

LOAEL-based HIs are all below 1, risks are not elevated above typical background conditions, and

therefore, additional evaluation or remedial response is not warranted.

2.7.2.5 Ecological Risk Assessment Conclusions

The ERA evaluated potential risks to plants, invertebrates, and terrestrial wildlife receptors

associated with possible exposures to COPECs in surface soil at the FS-2 study area.

Plants and Invertebrates

Although the ecological risk assessment showed that maximum concentrations of some inorganics

exceeded the benchmarks for phytotoxicity and invertebrates, adverse effects to the community

structure of both plants and invertebrates are unlikely due to the

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concentration of the inorganics being within the range of urban background concentrations.

Inorganics with maximum concentrations that exceeded plant or invertebrate benchmarks included

chromium, lead, manganese, selenium, and vanadium. With the exception of selenium (detected in

two samples), concentrations of all inorganics were consistent with the urban background

concentrations (Table 2-19). The food source of herbivores and omnivores is not likely to be

affected, due to the abundant foraging areas nearby. Therefore, no further remedial action for site

soils is recommended.

Terrestrial Wildlife

HQs for four inorganic COPECs were greater than 1 for the American robin and the shrew when

evaluated with NOAEL benchmarks; however, when evaluated with LOAEL benchmarks, the HQs

for these inorganics were below 1. Adverse effects are not likely due to the generally low

concentration of the COPECs. Inorganics with maximum concentrations that exceeded terrestrial

wildlife screening values included chromium, lead, selenium, and zinc. With the exception of

selenium (detected in two samples), concentrations of all inorganics were consistent with the urban

background concentrations (Table 2-19). Because concentrations of the COPECs are well within the

range of urban background concentrations, risks associated with the site are negligible. Therefore,

no further remedial action for site soils is recommended.

2.8 DOCUMENTATION OF SIGNIFICANT CHANGES

AFCEE prepared a Proposed Plan for AOC FS-2 (AFCEE 2001a). The Proposed Plan described

AFCEE’s proposal to pursue no further action at AOC FS-2. AFCEE reviewed all formal comments

received during the public comment period and determined that no significant changes to the remedy,

as originally identified in the Proposed Plan, were necessary.

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A3P-J23-35Z01302-M26-0004 3-111/13/01

3.0 RESPONSIVENESS SUMMARY

Please see attached.

RESPONSIVENESS SUMMARY FOR FUEL SPILL 2 (FS-2) 1

RESPONSIVENESS SUMMARY FOR FUEL SPILL 2 (FS-2) 2

Summary Report for FS-2 Comments and Responses

Support No Further Action

Name/Organization Comments (Paraphrased) ResponseNo comments received.

RESPONSIVENESS SUMMARY FOR FUEL SPILL 2 (FS-2) 3

Oppose No Further Action

Name/Organization Comment (Paraphrased) ResponseDavid Dow

Sierra Club – Cape Cod Group

I do not believe the Remedial Investigation(RI) for this source area/groundwater plume isadequate. There is no sufficient account givenfor the missing ethylene dibromide (EDB)contaminant from this source area. There is nopersuasive evidence to support theassumption of a detached EDB plumefollowing the current path of the present FuelSpill 28 (FS-28) plume and dischargingsometime in the past into the CoonamessettRiver and/or Coonamessett Pond. The RIsuffers from too many unproven assumptionsabout the potential for groundwater pollutionfrom the contaminated soil and the lack ofevidence for the absence of detached EDBplume.

The citizens of Cape Cod desire thegroundwater to be returned to backgroundlevels for contaminants, not just below somerisk threshold for human health or ecologicalimpacts.

The relationship between FS-2 and downgradient EDB contamination isnot well explained in the Final FS-2 Supplemental Rl Report because thatreport focuses on the soil data collected at the site in 2000 and thegroundwater data collected beneath and immediately downgradient fromthe site in 1998. When the initial RI was conducted in 1991, EDBgroundwater contamination had not yet been identified in the surroundinggroundwater. It was not in the scope for either of these documents toexplain the relationship between FS-2 and the downgradient EDBcontamination. However, both the FS-28 RI and Southwest Operable Unit(SWOU) RI evaluated the likelihood of FS-2 (and 31 other known orpotential source areas) to have contributed to downgradient groundwatercontamination. Those investigations concluded that it is possible that FS-2 contributed to downgradient EDB contamination, although no clearevidence remains today (e.g. an EDB plume attached to the FS-2 site).

Comment noted. AFCEE’s process for shutting down active treatmentsystems (after the groundwater has been restored to enforceable cleanupstandards) includes an evaluation of the feasibility of cleanup tobackground, as required by the Massachusetts Contingency Plan.

RESPONSIVENESS SUMMARY FOR FUEL SPILL 2 (FS-2) 4

Oppose No Further Action

Name/Organization Comment (Paraphrased) ResponseDavid Dow

Sierra Club – Cape Cod Group

There are heavy metals above backgroundlevels in the soils at FS-2: copper, lead,chromium, cobalt, zinc, arsenic and barium.These heavy metals will slowly move into thegroundwater over time and thus prevent thegroundwater from returning to backgroundcontaminant levels.

The maximum detected concentrations of arsenic, barium, chromium,cobalt, copper, lead, and zinc were higher than the preliminary valuespublished by Ogden Energy Systems in their Draft Completion of Workreport dated July 1998. In the FS-2 Rl, the maximum detectedconcentrations of metals in FS-2 soils were also compared to the rangeof background values from three other sources (EPA, DEP,and the IRP), and only selenium was found at a concentration higherthan the background concentration range. Nonetheless, the RIevaluated the fate and transport of metals at the FS-2 site andconcluded that metals are only slightly mobile under the conditions atFS-2 and are not expected to migrate. This conclusion is consistentwith the SWOU Rl, which also evaluated metals in groundwater. Itconcluded that there were no plumes of groundwater with metalsexceeding background levels in the regional groundwater. Becausethe conditions controlling the mobility of metals (primarily pH andredox potential) are not expected to change in the future to conditionswhich would mobilize the metals currently sorbed to the site soils, it isunlikely that the concentrations of metals in groundwaterdowngradient from FS-2 will increase in the future.

RESPONSIVENESS SUMMARY FOR FUEL SPILL 2 (FS-2) 5

Oppose No Further Action

Name/Organization Comment (Paraphrased) ResponseDavid Dow

Sierra Club – Cape Cod GroupEPA's procedures for using acute/chronictoxicity criteria and hazards indices forecological risk assessments is based on1970's biology and is basically worthless as apredictor of what will happen in the naturalworld. It would be more accurate to actuallyconduct bioassays or conduct measurementsfor bio-effect indicators in field collected biota.

For example, arsenic concentrations in plantscorrelate well with water-extractable arsenic.Thus doing an ecological risk assessment ontotal arsenic concentrations of 7.3 mg/kg is notvery meaningful biologically. Arsenic has agreater availability to plants in coarse soilswith little organic matter and limited ion-exchange capacity such as those found onMMR. Assuming EPA’s ecological riskassessment is accurate, one would expect thatplants or the mycorrhiza associated with pinetrees would be the most sensitive ecologicalreceptors to arsenic exposure. The JPAT hasasked for monitoring of contaminant levels inbiota and extrapolation for effects from realdata, but all we get are risk assessments.

What we need is monitoring of actualcontaminant levels in biota and models toextrapolate the potential ecological effects,rather than poorly formulated ecological riskassessments which are based on questionableassumptions.

In selecting ecological toxicity values, EPA methods prefer chronic levelsto subchronic or acute values, and prefer (NOAELs no observed adverseeffect levels) to LOAELs (lowest observed adverse effect levels). Thescreening-level stage of assessment includes very conservativeassumptions (receptor is exposed to maximum concentration 100 percentof the time; compounds are 100 percent bioavailable; receptor’s diet iscomprised entirely of the most contaminated dietary component;maximum receptor ingestion rate; minimum receptor body weight, etc.).The next level of ecological risk assessment is only warranted if theconservative screening-level risk assessments show that adverseecological effects are possible. The food-web modeling and exposureassessment in the next levels of ecological risk assessment are alsoconservative in nature. Biota sampling is only conducted after initial riskassessment suggest that ecological risks may warrant action. It is alsoused to minimize uncertainties in the modeling.

Hazard Indices (HIs) in the FS-2 ecological risk assessment ranged fromless than one to 12 (for American robin). Similar to human health cancerand non-cancer excess risk estimates, ecological risk HIs ranging fromone to ten don’t immediately warrant action to address ecological risk, butfurther review of site data.

The compounds contributing to the excess ecological risk estimates arechromium, lead, selenium, and zinc. Chromium was detected at amaximum concentration of 16 mg/kg in FS-2 surface soil, which is lowerthan the background level of chromium in soil (18 mg/kg) established forstudies in the MMR Impact Area. Lead was at a maximum estimatedconcentration of 56 mg/kg, which is less than the cleanup level of 99mg/kg used for source area removal actions at MMR. Selenium wasdetected in only two out of 10 FS-2 surface soil samples. Although themaximum detected concentration in FS-2 soils (1.4 mg/kg ) is higher thanthe background level of selenium (1.2 mg/kg) established for studies inthe MMR impact area, it is less than all of the ecological soil targetcleanup levels for selenium (ranging from 8.2 mg/kg to 11,000 mg/kg)used for remedial actions at MMR. Zinc was detected at a maximumconcentration of 19 mg/kg in FS-2 surface soil, which is lower than thebackground level of zinc (25.6 mg/kg) established for studies in the MMRImpact Area.

RESPONSIVENESS SUMMARY FOR FUEL SPILL 2 (FS-2) 6

Oppose No Further Action

Name/Organization Comment (Paraphrased) Response

Joint Process Action Team (JPAT)Consensus

The JPAT does not concur with the generalpreferred remedy of no further action,specifically at the FS-2 source area.

Are the contaminants from the FS-2 sourcearea now part of the FS-28 groundwaterplume?

The EPA and the DEP have established criteria for remedial action basedon protection of human health and the environment. Based on extensiveenvironmental sampling both before and since the FS-2 soil removalaction, the site conditions do not warrant remedial action.

It is likely that FS-2 was one of several sites that contributed to the mostsouthern portion of the FS-28 plume. However, no direct relationshipbetween FS-2 and the FS-28 plume has been proven. The EDB within thenorthern part of the FS-28 plume originated from fuels spilled north of theFS-2 site, and probably at more than one location. The ROD has beenfinalized for FS-28, even though the source area(s) for the FS-28 plumemay never be identified, since the FS-28 is detached from its originalsource area(s).

RESPONSIVENESS SUMMARY FOR FUEL SPILL 2 (FS-2) 7

Oppose No Further Action

Name/Organization Comment (Paraphrased) Response

Joint Process Action Team (JPAT)Consensus

Did the contaminants upwell into theCoonamessett River and/or CoonamessettPond prior to any monitoring? If so, how muchand what were the ecological impacts andhuman health impacts?

Were residents exposed to FS-2 contaminantsvia drinking water from private wells?

The FS-2 site was active 36 to 46 years ago. Environmental sampling atFS-2 began only 16 years ago, and sampling in and aroundCoonamessett Pond and the Coonamessett River began only six yearsago. AFCEE cannot determine with certainty how much of the fuel spilledat FS-2 traveled as far as Route 151, Coonamessett Pond or theCoonamessett River. Using numerical models to simulate the historicaltransport of the fuels with any certainty would require knowledge of howmuch fuel was spilled at what times during the 10 years the site wasoperational. Ecological impacts, if there were any, would have beenlimited to surface water bodies such as Coonamessett Pond or theCoonamessett River, where volatilization and mixing would havesignificantly diluted any fuel contamination entering the surface water.

Some of these questions are addressed in the Public Health Evaluationof Potential Human Exposure to FS-28 Plume Ethylene Dibromide in theGroundwater, Surface Water, and Air of the Hatchville Area,Massachusetts prepared by Agency for Toxic Substances and DiseaseRegistry (ATSDR), which concluded that "in the Hatchville area, there isno past, present, or potential future pathway of human exposure toEDB-contaminated drinking water from private or municipal drinking waterwells" and that "based on current epidemiologic, toxicologic, and medicalinformation, that the EDB-contamination in surface water and air in thecranberry bog area is unlikely to have presented a health hazard tocranberry workers or nearby recreational users of the bog areas."

RESPONSIVENESS SUMMARY FOR FUEL SPILL 2 (FS-2) 8

Oppose No Further Action

Name/Organization Comment (Paraphrased) Response

Joint Process Action Team (JPAT)Consensus

Are FS-2 contaminants further downgradient ofthe FS-28 groundwater plume given theirrelease in the 1950's and 1960's?

AFCEE does not believe that FS-2 contaminants are further downgradientof the FS-28 groundwater plume.

In 1996, the United States Geological Survey (USGS) dated watersamples from ten wells in the FS-28 plume using chlorofluorocarbon andtritium/helium age-date analyses. The dates for the three samplescollected from the southern part of the plume ranged from pre-1940's tomid-1950's, and the dates for the seven samples in the northern part ofthe plume ranged from 1958 to 1976. It does not seem likely that waterinfiltrating at FS-2 between 1955 and 1965 migrated past the currentextent of the FS-28 plume. Even considering that the southern sampleswere deeper (therefore older) than the northern samples, and that thedeeper groundwater infiltrated north of FS-2, and that five years havepassed since the water was dated, it does not seem likely that waterinfiltrating at FS-2 between 1955 and 1965 migrated much past the extentof the FS-28 plume. It is probable that that water (which may or may nothave still been contaminated at that point) already discharged to thesurface.

ATSDR calculated EDB plume arrival dates for several points inHatchville, between the MMR boundary and the limit of the FS-28 plume.Because the FS-2 site was the closest to Hatchville, ATSDRconservatively assumed that EDB was released at FS-2 from 1940 to1945 (rather than from 1955 to 1965), in their calculation of plume arrivaldates for the area. The plume arrival date range ATSDR calculated forthe FS-28 plume limit (which AFCEE mapped in 1996) was 1987 to 1992.Had they used the same assumptions (5 year infiltration time and 1 ft/daygroundwater velocity) for the FS-2 1955 to 1965 activity period, a 2002to 2012 plume arrival would result. Using a the same approach with amore reasonable groundwater velocity (1.4 ft/day) and the 1955 to 1965release period, EDB originating at FS-2 would presumably have arrivedat the mapped limit between 1990 and 2000.

RESPONSIVENESS SUMMARY FOR FUEL SPILL 2 (FS-2) 9

Oppose No Further Action

Name/Organization Comment (Paraphrased) Response

Joint Process Action Team (JPAT)Consensus

The FS-2 ROD should explicitly recognize thatFS-2 is a source of the FS-28 groundwaterplume.

AFCEE should forward the FS-2 ProposedPlan and associated data to the Agency forToxic Substances Disease Registry (ATSDR)for further review into their modeling of EDBexposures in Hatchville.

AFCEE should undertake particle tracking andother appropriate groundwater modeling tobetter understand the potential fate of the fuelsspilled at FS-2, even if current monitoringcannot “identify” a FS-2 plume.

That FS-2 is a source of the FS-28 plume cannot be concluded from theavailable data. The ROD will state that FS-2 is one of several sites thatlikely contributed to the FS-28 plume.

The Public Health Evaluation of Potential Human Exposure to FS-28Ethylene Dibromide in the Groundwater, Surface Water, and Air of theHatchville Area, Massachusetts was completed March 15, 2000. AFCEEdid forward available data (from the FS-28 and SWOU RI reports andother relevant studies that evaluated the relationships between the FS-28plume and upgradient known and potential source areas) to ATSDR fortheir consideration in their EDB exposure modeling in Hatchville.

With the exception of EDB, the organic compounds that comprise AVGASand JP-4 are comparatively short-lived in the regional groundwaterconditions. Modeling would not help AFCEE find these fuels, because themajority of the fuel compounds disappeared a long time ago by naturalprocesses such as dispersion and biodegradation. Only traceconcentrations of fuel-related compounds remain in the groundwaterbeneath the site. It is unclear how modeling the potential past fate of FS-2fuels would relate to the remedial decision for the site, which is based onthe current data and risk assessment.

RESPONSIVENESS SUMMARY FOR FUEL SPILL 2 (FS-2) 10

Oppose No Further Action

Name/Organization Comment (Paraphrased) Response

Joint Process Action Team (JPAT)Consensus

AFCEE should reveiw existing dissolvedoxygen (DO) data and gather additional newDO data to dermine a possible “shadow” of theplume and to determine the degradation ofwater quality in the FS-2 flow path due to lowDO.

Further historical information is needed forpossible spills all along the railroad tracks thatextend through and past FS-2. It is possiblethat this railroad track could have been thesource of spills that have led to SWOU plumesas well as FS-28.

The DO levels in the eight wells sampled during the SWOU RI to evaluategroundwater quality beneath and immediately downgradient of FS-2ranged from 4.54 to 10.02 mg/L. These DO levels are comparable tolevels measured in regional groundwater, and not low enough to degradegroundwater quality.

DO levels were measured in seven of the wells in this area both in 1990and 1998. Compared to the 1990 DO levels, the 1998 levels were higherin five of the wells and lower in two of the wells, and on averageincreased 1.5 mg/L.

The records searches did not identify sites along the tracks other thanthose used for loading and unloading. The SWOU plumes are too deepto have originated from the railroad track.

RESPONSIVENESS SUMMARY FOR FUEL SPILL 2 (FS-2) 11

Other Comments

Name/Organization Comment (Paraphrased) Response(Repeat from above)

None received.

RESPONSIVENESS SUMMARY FOR FUEL SPILL 2 (FS-2) 12

For additional information, please contact:

Doug KarsonCommunity Involvement Specialist

HQ AFCEE/MMR322 East Inner Road

Otis ANGB, MA 02542-5028Phone: (508) 968-4678 ext. 2

FAX:(508) [email protected]

Jim MurphyCommunity Involvement Coordinator

USEPA New England1 Congress St, Suite 1100Boston, MA 02114-2023

Phone: (617) 918-1028 or (888) 372-7341 x 81028FAX: (617) 918-1294

[email protected]

Ellie Grillo Community Involvement Coordinator

Massachusetts DEP20 Riverside Drive

Lakeville, MA 02346Phone: (508) 946-2866FAX: (508) 947-6557

[email protected]

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A3P-J23-35Z01302-M26-0004 4-111/13/01

4.0 REFERENCES

ABB Environmental Services, Inc. 1993. Technical Memorandum, Recommendation for AOCFS-2 Surface Soil Treatment, Massachusetts Military Reservation. Prepared forHazardous Waste Remedial Actions Program, Oak Ridge, TN.

AFCEE (Air Force Center for Environmental Excellence) 2001a (May). Final Proposed Plan forNo Further Action for Soil and Groundwater at the FS-2 Site. A3P-J23-35Z01302-M25-0005. MMR Installation Restoration Program, Otis Air National Guard Base,MA.

2001b (January). Final Fuel Spill-2 Supplemental Remedial Investigation Report. AFC-J23-35U40602-M14-0009. Prepared by Jacobs Engineering Group Inc. forAFCEE/MMR Installation Restoration Program, Otis Air National Guard Base, MA.

. 2000a (May). Record of Decision, Area of Contamination FS-1 Final. DE-AC05-84OR21400. Prepared by Hazardous Waste Remedial ActionsProgram for AFCEE/MMR Installation Restoration Program, Otis Air National GuardBase, MA.

. 2000b (April). Final Decision Document, Study Area CS-14. DE-AC05-84OR21400.Prepared by Harding Lawson Associates for AFCEE/MMR Installation Restoration Program,Otis Air National Guard Base, MA.

. 2000c (February). Final Record of Decision for the CS-4, CS-20, CS-21, and FS-13Plumes. AFC-J23-35Q86101-M26-0004. Prepared by Jacobs Engineering Group Inc. forAFCEE/MMR Installation Restoration Program, Otis Air National Guard Base, MA.

. 1999a (October). Final Record of Decision, Area of Contamination FS-17 and Area ofContamination FS-19. DE-AC05OR21400. Prepared by Hazardous Waste Remedial ActionsProgram for AFCEE/MMR Installation Restoration Program, Otis Air National Guard Base,MA.

. 1999b (July). Final Record of Decision, Area of Contamination CS-10/FS-24 Source Areas.DE-AC05OR21400. Prepared by Hazardous Waste Remedial Actions Program forAFCEE/MMR Installation Restoration Program, Otis Air National Guard Base, MA.

. 1999c (May). Final Southwest Operable Unit Remedial Investigation. AFC-J23-35Q86101-M14-0006. Prepared by Jacobs Engineering Group Inc. for AFCEE/MMRInstallation Restoration Program, Otis Air National Guard Base, MA.

. 1999d (March). Final Record of Decision, Areas of Contamination CS-16/CS-17 SourceAreas. Prepared by Hazardous Waste Remedial Actions Program

I:\35Z01302 - FS-2\ROD\Final ROD Combined.doc

A3P-J23-35Z01302-M26-0004 4-211/13/01

for AFCEE/MMR Installation Restoration Program, Otis Air National Guard Base, MA.

. 1998a (September). Final Record of Decision, Areas of Contamination FTA-2/LF-2,PFSA/FS-10/FS-11, SD-2/FS-6/FS-8, SD-3/FTA-3/CY-4, and SD-5/FS-5 Source Areas.DE-AC05-84OR21400. Prepared by Hazardous Waste Remedial Actions Program forAFCEE/MMR Installation Restoration Program, Otis Air National Guard Base, MA.

. 1998b (September). Record of Decision, AOC CS-3 (USCG) 3-in-1Store. DAHA90-94-D-0008. Prepared by Stone & Webster Environmental Technology &Services for AFCEE/MMR Installation Restoration Program, Otis Air National Guard Base,MA.

. 1996 (July). Strategic Plan. Massachusetts Military Reservation Installation RestorationProgram. Prepared by Jacobs Engineering Inc. for AFCEE/MMR Installation RestorationProgram, Otis Air National Guard Base, MA.

American Cancer Society. 1997. Cancer Facts and Figures.

ANG (Army National Guard) 1995 (September). Final Record of Decision for Interim Action: Containment of Seven Groundwater Plumes (IROD). Prepared by Stone& Webster Environmental Technology & Services for AFCEE/MMR Installation RestorationProgram, Otis Air National Guard Base, MA.

E. C. Jordan Company. 1991 (February). Remedial Investigation Report Railroad FuelPumping Station (FS-2 Study Area), Installation Restoration Program: MassachusettsMilitary Reservation. Prepared for the Hazardous Waste Remedial Actions Program.Portland, ME.

. 1990 (February). Final Report Site Inspection Report Field Investigation WorkConducted Spring-Summer 1988 Task 2-3B, Installation Restoration Program:Massachusetts Military Reservation. Prepared for the Hazardous Waste RemedialActions Program. Portland, ME.

Efroymson, R.A., M.E. Will, G.W. Suter II, A.C. Wooten. 1997a. ToxicologicalBenchmarks for Screening Contaminants of Potential Concern for Effects on TerrestrialPlants: 1997 Revision. ES/ER/TM-85/R3. Oak Ridge National Laboratory, Oak Ridge, TN.

Efroymson, R.A., M.E. Will, and G.W. Suter II. 1997b. Toxicological Benchmarks for Potential Contaminants of Concern for Effects on Soil and Litter Invertebrates and Heterotrophic Process. ES/ER/TM-126/R2. Oak Ridge National Laboratory, Oak Ridge, TN.

EHRT (Environmental Health Research and Testing, Inc.). 1996. Closure Report for InstallationRestoration Program Massachusetts Military Reservation, Cape Cod, Massachusetts,Area of Contamination FS-2.

I:\35Z01302 - FS-2\ROD\Final ROD Combined.doc

A3P-J23-35Z01302-M26-0004 4-311/13/01

EPA (Environmental Protection Agency). 1999 (October). Region IX. Region 9 PreliminaryRemediation Goals.

. 1989 (December). Risk Assessment Guidance for Superfund. Volume. 1: Human HealthEvaluation Manual. Office of Emergency and Remedial Response, Washington, DC.EPA540/1-89/002.

HAZWRAP (HAZWRAP Support Contractor Office). 1992 (May). Final Record of Decision forInterim Remedial Action: West Truck Road Motor Pool (AOC CS-4) Groundwater OperableUnit. Prepared by ABB Environmental Services Inc., Portland, ME for Hazardous WasteRemedial Actions Program, Oak Ridge, TN.

Metcalf and Eddy, Inc. 1983 (January). Installation Restoration Program, Phase I - Records Search.Otis Air National Guard Base, Massachusetts.

R. F. Weston, Inc. 1985 (October). Installation Restoration Program: Phase II, Stage 1 -Confirmation Quantification. Otis Air National Guard Base, Massachusetts; report to theU.S. Air Force Occupational and Environmental Health Laboratory.

Sample, B. E., D. M. Opresko and G. W. Suter II. 1996 (September). Toxicological Benchmarks forWildlife. Oak Ridge National Laboratory, Oak Ridge, TN.

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FIGURES

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TABLES

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Table 2-1RAGS Part D Standard Table 3.1

Medium-Specific Exposure Point Concentration SummarySoils (0 to 2 feet bgs)

AOC FS-2

Scenario Time Frame: Current/Future Land Use Medium: Soil Exposure Medium: Surface Soil Exposure Point: Soil 0-2 feet bgs

Chemical of Potential Concern (1) Units ArithmeticMean

95% UCL of Lognormal

Data

MaximumDetected

Concentration

MaximumQualifier

EPCUnits

Reasonable Maximum Exposure Central Tendency

MediumEPC

Value

MediumEPC

Statistic

MediumEPC

Rationale

MediumEPC

Value

MediumEPC

Statistic

MediumEPC

RationaleSemivolatile OrganicsBENZO(A)ANTHRACENE µg/kg 318 540 760 µg/kg 540 95% UCL (2) NE NE NE

BENZO(A)PYRENE µg/kg 251 382 600 µg/kg 382 95% UCL (2) NE NE NE

BENZO(B)FLUORANTHENE µg/kg 373 598 790 µg/kg 598 95% UCL (2) NE NE NE

DIBENZ(A,H)ANTHRACENE µg/kg 45 69 110 J µg/kg 69 95% UCL (2) NE NE NE

INDENO(1,2,3-C,D)PYRENE µg/kg 194 299 510 µg/kg 299 95% UCL (2) NE NE NE

InorganicsARSENIC (TOTAL) mg/kg 2.0 3.5 7.3 mg/kg 3.5 95% UCL (2) NE NE NE

Extractable Petroleum HydrocarbonsC11-C22 AROMATIC HYDROCARBONS mg/kg 39 269 350 mg/kg 269 95% UCL (2) NE NE NE

Notes: (1) Chemicals of potential concern are selected in Table 7-2 of the Final FS-2 Supplemental RI Report (AFCEE 2001b).

Data summary is based on samples collected from 0-2 feet bgs at locations 32BH0001 through 32BH0010.

2) The EPC is the minimum of the maximum detected concentration and the 95% UCL if there are at least 10 samples; otherwise, the maximum detected concentration was used, per EPA Region I (EPA 1995. Risk Updates. No. 3. EPA Region I, New England, Waste Management Division).

Qualifier Definitions: bgs = below ground surface EPA = U.S. Environmental Protection Agency EPC = exposure point concentration J = estimated value mg/kg = milligrams per kilogram NE = not evaluated UCL = upper confidence limit on the arithmetic meanµg/kg = micrograms per kilogram

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Table 2-2RAGS Part D Standard Table 3.2

Medium-Specific Exposure Point Concentration SummarySoils (0 to 10 feet bgs)

AOC FS-2

Scenario Time Frame: Future Land Use Medium: Soil Exposure Medium: Surface Soil Exposure Point: Soil 0-10 feet bgs

Chemical of Potential Concern (1) Units ArithmeticMean

95% UCL of Lognormal

Data

MaximumDetected

Concentration

MaximumQualifier

EPCUnits

Reasonable Maximum Exposure Central Tendency

MediumEPC

Value

MediumEPC

Statistic

MediumEPC

Rationale

MediumEPC

Value

MediumEPC

Statistic

MediumEPC

RationaleSemivolatile OrganicsBENZO(A)ANTHRACENE µg/kg 288 1857 2300 µg/kg 1857 95% UCL (2) NE NE NE

BENZO(A)PYRENE µg/kg 222 1333 2000 µg/kg 1333 95% UCL (2) NE NE NE

BENZO(B)FLUORANTHENE µg/kg 308 1888 2500 µg/kg 1888 95% UCL (2) NE NE NE

DIBENZ(A,H)ANTHRACENE µg/kg 41 89 360 J µg/kg 89 95% UCL (2) NE NE NE

INDENO(1,2,3-C,D)PYRENE µg/kg 169 967 1600 µg/kg 967 95% UCL (2) NE NE NE

InorganicsARSENIC (TOTAL) mg/kg 1.8 3.8 7.3 mg/kg 3.8 95% UCL (2) NE NE NE

Extractable Petroleum HydrocarbonsC11-C22 AROMATIC HYDROCARBONS mg/kg 20 18 350 mg/kg 350 Maximum (3) NE NE NE

Notes: (1) Chemicals of potential concern are selected in Table 7-2 of the Final FS-2 Supplemental RI Report (AFCEE 2001b).

Data summary is based on samples collected from 0-10 feet bgs at locations 32BH0001 through 32BH0010.

2) The EPC is the minimum of the maximum detected concentration and the 95% UCL if there are at least 10 samples; otherwise, the maximum detected concentration was used,per EPA Region I (EPA 1995. Risk Updates. No. 3. EPA Region I, New England, Waste Management Division).

(3) The data exhibit neither a normal nor a lognormal distribution. Therefore, the maximum detected concentration is selected as a conservative estimate of the EPC.

EPA = U.S. Environmental Protection Agency EPC = exposure point concentration feet bgs = feet below ground surface J = estimated value mg/kg = milligrams per kilogram NE = not evaluated UCL = upper confidence limit on the arithmetic meanµg/kg = micrograms per kilogram

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Table 2-3RAGS Part D Standard Table 3.3

Medium-Specific Exposure Point Concentration SummarySoils (0 to 20 feet bgs)

AOC FS-2

Scenario Time Frame: Future Land Use Medium: Soil Exposure Medium: Surface and Subsurface Soil Exposure Point: Soil 0-20 feet bgs

Chemical of Potential Concern (1) Units ArithmeticMean

95% UCL of Lognormal

Data

MaximumDetected

Concentration

MaximumQualifier

EPCUnits

Reasonable Maximum Exposure Central Tendency

MediumEPC

Value

MediumEPC

Statistic

MediumEPC

Rationale

MediumEPC

Value

MediumEPC

Statistic

MediumEPC

RationaleSemivolatile OrganicsBENZO(A)ANTHRACENE µg/kg 289 1150 4100 µg/kg 1150 95% UCL (2) NE NE NE

BENZO(A)PYRENE µg/kg 204 612 2400 µg/kg 612 95% UCL (2) NE NE NE

BENZO(B)FLUORANTHENE µg/kg 299 881 4200 µg/kg 881 95% UCL (2) NE NE NE

DIBENZ(A,H)ANTHRACENE µg/kg 37 52 410 µg/kg 52 95% UCL (2) NE NE NE

INDENO(1,2,3-C,D)PYRENE µg/kg 150 425 1800 µg/kg 425 95% UCL (2) NE NE NE

InorganicsARSENIC (TOTAL) mg/kg 1.6 4.3 7.3 mg/kg 4.3 95% UCL (2) NE NE NE

Extractable Petroleum HydrocarbonsC11-C22 AROMATIC HYDROCARBONS mg/kg 21 15 360 J mg/kg 360 Maximum (3) NE NE NE

Notes: (1) Chemicals of potential concern are selected in Table 7-2 of the Final FS-2 Supplemental RI Report (AFCEE 2001b).

Data summary is based on samples collected from 0-20 feet bgs at locations 32BH0001 through 32BH0010.

2) The EPC is the minimum of the maximum detected concentration and the 95% UCL if there are at least 10 samples; otherwise, the maximum detected concentration was used,per EPA Region I (EPA 1995. Risk Updates. No. 3. EPA Region I, New England, Waste Management Division).

(3) The data exhibit neither a normal nor a lognormal distribution. Therefore, the maximum detected concentration is selected as a conservative estimate of the EPC.

EPA = U.S. Environmental Protection Agency EPC = exposure point concentration feet bgs = feet below ground surface J = estimated value mg/kg = milligrams per kilogram NE = not evaluated UCL = upper confidence limit on the arithmetic meanµg/kg = micrograms per kilogram

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Table 2-4RAGS Part D Standard Table 2.3

Occurrence, Distribution and Selection of Chemicals of Potential Concern - GroundwaterAOC FS-2

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Table 2-4RAGS Part D Standard Table 2.3

Occurrence, Distribution and Selection of Chemicals of Potential Concern - GroundwaterAOC FS-2

Notes:

Data Source: Jacobs Engineering Group Inc., (November 2000) Site Environmental Evaluation (SEE) database Only the latest results with the most complete analyte lists were used if more than one sample was available. Only normal, validated, non-rejected results for samples collected after 06 January 1996 are used. All analytes detected in any SWOU well associated with FS-2, regardless of detection frequency, are shown. The analyte concentration used for screening is the maximum detected result. The ARAR is the lesser of Safe Drinking Water Act (SDWA) MCLs and Massachusetts Drinking Water MCLs (MMCL). Screening toxicity value is EPA Region IX risk-based tap water standard. COPC flag is Yes if screening result exceeds any of the background, screening toxicity, or ARAR concentrations. COPC flag is Yes if there is no background, screening toxicity, or ARAR value to compare to. Rationale for COPC Yes flag gives the most restrictive of the comparison values.* Indicates that common cations (Al, Ca, Co, Fe, Mg, K, Na, Si) are presented for informational purposes and are not considered to be COPCs. ca indicates a carcinogen as reported in EPA Region IX RBC table. nc indicates a non-carcinogen as reported in EPA Region IX RBC table. Screening toxicity value for hexavalent chromium shown. Background values from SWOU remedial investigation.

Al = aluminum ARAR = applicable or relevant and appropriate requirement Ca = calcium CAS = Chemical Abstract Service Co = cobalt COPC = chemical of potential concern Fe = iron J = estimated result K = potassium MCL = maximum contaminant level Mg = magnesium Na = sodium No. = number RAGS = Risk Assessment Guidance for Superfund (RAGS): Volume I - Human Health Evaluation Manual (HHEM)(EPA 1989) RBC = risk-based concentration Si = silicon SWOU = Southwest Operable Unit TBC = to be considered Tox = measured value exceeded toxicity screening value µg/L = micrograms per liter

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Table 2-5 RAGS Part D Standard Table 1.0 Selection of Exposure Pathways

AOC FS-2

ScenarioTime Frame Medium Exposure

MediumExposure

PointReceptor

PopulationReceptor

AgeExposure

RouteOn-Site/Off-Site

Type of Analysis

Rationale for Selection or Exclusion of Exposure Pathway

Current and Future Soil Soils FS-2 Recreational

User Adolescent

IngestionDermal

Inhalation ofVOCs/particulates

On-Site Quant This site is currently inactive, but access from within MMR is unrestricted.Recreational users, such as golfers, mountain bikers, and walkers, mayaccess the site. Future recreational development of the site may occur, as itis adjacent to the MMR golf course.

Future Soil Soils FS-2 ResidentChild /Adult

IngestionDermal Contact

Inhalation ofVOCs/particulates

On-Site Quant Although future site use has not been determined, the risk assessmentconsiders future use of the site as a residential property to provide aconservative assessment of possible health risks associated withunspecified future use.

Future Soil Soils FS-2Construction/

UtilityWorker

Adult

IngestionDermal

Inhalation ofVOCs/particulates

On-Site Quant The land use of this area is currently inactive and for MMR is consideredmilitary. However, short-term construction/utility activities may occur in thefuture.

Current and Future Soil Soils FS-2 Commercial/Industrial

Site Worker

Adult IngestionDermal

Inhalation ofVOCs/particulates

On-Site None The land use of this area is currently inactive and for MMR is consideredmilitary. Although future land use at MMR has not been fully established, thisarea is not suitable for commercial/industrial development based on itshistorical military use.

Current and Future

Groundwater Groundwater Aquifer-Tap Water On-SiteReceptor /

Future Resident

Child /Adult

Ingestion Dermal Contact

Inhalation ofVOCs

On-Site Quant The land use of this area is currently inactive and for MMR is consideredmilitary. Although future land use at MMR has not been fully established, aresidential use has been used for evaluating risk. SWOU RI groundwaterdata indicate that concentrations present in FS-2 groundwater do not exceeddrinking water standards. With no COCs or discernable plumes identified forFS-2 groundwater, it was concluded that there are no unacceptable risks tohuman health associated with future residential exposure to FS-2groundwater.

Future Groundwater Groundwater Aquifer-Tap Water Off-SiteReceptor /

Future Resident

Child /Adult

Ingestion Dermal Contact

Inhalation of VOCs

Off-Site Quant The SWOU RI groundwater data indicate that concentrations present in FS-2groundwater do not exceed drinking water standards. With no COCs ordiscernable plumes identified for FS-2 groundwater, it was concluded thatthere are no unacceptable risks to human health associated with futureresidential exposure to FS-2 groundwater.

Notes:

COC = chemical of concernFS-2 = Fuel Spill-2MMR = Massachusetts Military ReservationQuant = quantitativeRI = remedial investigationSWOU = Southwest Operable UnitVOC = volatile organic compound

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Table 2-6 RAGS Part D Standard Table 4.1

Values Used for Daily Intake Calculations - Trespasser AOC FS-2

Scenario Time Frame: Current/Future Land UseMedium: SoilExposure Medium: Surface SoilExposure Points: Soil 0-2 feet bgsReceptor Population: TrespasserReceptor Age: Adolescent (7 through 17 years)

Exposure RouteParameter

CodeParameter Definition Units

RMEValue

RMERationale/Reference

CTValue

CTRationale/Reference

Intake Equation/Model Name

Ingestion Css Chemical Concentration in Surface Soil µg/g See EPC Table See EPC Table NE NECF Conversion Factor g/µg 1.00E-06 -- NE NE Intake Ingestion=Css x IR x FI x CF x EF x ED IR Ingestion Rate of Surface Soil mg/day 100 EPA, 1994 NE NE BW x ATFI Fraction Ingested from Source % 100% (2) NE NEEF Exposure Frequency days/year 138 (1) NE NEED Exposure Duration years 11 (1) NE NEBW Body Weight kg 45 EPA, 1997 NE NE

AT-C Averaging Time (Cancer) days 25,550 EPA, 1989 NE NEAT-N Averaging Time (Non-Cancer) days 4,015 EPA, 1989 NE NE

Dermal Css Chemical Concentration in Surface Soil µg/g See EPC Table See EPC Table NE NECF Conversion Factor g/µg 1.00E-06 -- NE NE Intake Dermal = DA event x SA x EF x EDAF Adherence Factor mg/cm2 0.20 EPA, 1999; (3) NE NE BW x AT

AbF Absorption Factor % chemical-specific EPA, 1999; (5) NE NESA Skin Surface Area Available for Contact cm2 3,431 EPA, 1992; (4) NE NEEF Exposure Frequency days/year 138 (1) NE NE Where:ED Exposure Duration years 11 (1) NE NE DAevent = Css x AF x AbF x CFBW Body Weight kg 45 EPA, 1997 NE NE

AT-C Averaging Time (Cancer) days 25,550 EPA, 1989 NE NEAT-N Averaging Time (Non-Cancer) days 4,015 EPA, 1989 NE NE

Inhalation CA Chemical Concentration in Air µg/m3 See Equation See Equation NE NEPEF Particulate Emission Factor kg/m3 1.32E+09 EPA, 1996 NE NE Intake Inhalation = CA x ET x EF x EDET Exposure Time hours/day 2 (2) NE NE 24 hour/day x ATEF Exposure Frequency days/year 138 (1) NE NEED Exposure Duration years 11 (1) NE NE Where:

AT-C Averaging Time (Cancer) days 25,550 EPA, 1989 NE NE CA = Soil EPC x 1/PEF x 1000 µg/mgAT-N Averaging Time (Non-Cancer) days 4,015 EPA, 1989 NE NE

(1) Four days per week during April through November. Exposure duration is 11 years for ages 7 through 17.(2) Value is assumed(3) See Exhibit 3.3 of EPA, 1999. Value based on: Children Playing in wet soil (geometric mean for wet soil).(4) Skin surface area is 25% of the whole body surface for males ages 7 through 17 (EPA, 1999).(5) See Exhibit 3.4 of EPA, 1999. Published AbF values for the COPCs evaluated in this risk assessment are as follows:

Arsenic: 0.03; PAHs: 0.13; the AbF for PAHs is used as a surrogate AbF for C11-C22 aromatic EPH.EPA, 1989 (December). Risk Assessment Guidance for Superfund (RAGS), Volume 1, Human Health Evaluation Manual (Part A). EPA-540/1-89-002

(interim final). Office of Emergency and Remedial Response, Washington, DC.EPA, 1992. Dermal Exposure Assessment: Principles and Applications. EPA-600/8-91/011F. Office of Health and Environmental Assessment.EPA, 1994 (August). Risk Updates No. 2; USEPA Region I, Waste Management Division. Values from Attachment 2 to Risk Updates No. 2.EPA, 1996 (May). Soil Screening Guidance: Technical Background Document. EPA/540/R-95/128.EPA, 1997 (August). Exposure Factors Handbook, Volume 1. EPA-600/P-95/002Fa. Office of Research and Development, Washington, DC.EPA, 1999. Risk Assessment Guidance for Superfund, Volume 1, Human Health Evaluation Manual (Part E) Interim Guidance. EPA-540/R-99-005.

Office of Solid Waste and Emergency Response, Washington, DC.

cm2 = square centimetersCT = central tendancyEPA = U.S. Environmental Protection AgencyEPC = exposure point concentrationEPH = extractable petroleum hydrocarbong/µg = grams per microgramkg = kilogramskg/m3 = kilograms per cubic metermg/cm2 = milligrams per square centimeterNE = not evaluatedPAH = polyaromatic hydrocarbonRME = reasonable maximum exposureµg/g = micrograms per gramµg/m3 = micrograms per cubic meter

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Table 2-7 RAGS Part D Standard Table 4.2

Values Used for Daily Intake Calculations - Child Resident AOC FS-2

Scenario Time Frame: Future Land UseMedium: SoilExposure Medium: Surface SoilExposure Points: Soil 0-2 feet bgs: Soil 0-10 feet bgsReceptor Population: ResidentReceptor Age: Child (1 through 6 years)

Exposure RouteParameter

CodeParameter Definition Units

RMEValue

RMERationale/Reference

CTValue

CTRationale/Reference

Intake Equation/Model Name

Ingestion Css Chemical Concentration in Surface Soil µg/g See EPC Table See EPC Table NE NECF Conversion Factor g/µg 1.00E-06 -- NE NE Intake Ingestion=Css x IR x FI x CF x EF x ED IR Ingestion Rate of Surface Soil mg/day 200 EPA, 1994 NE NE BW x ATFI Fraction Ingested from Source % 100% (1) NE NEEF Exposure Frequency days/year 150 EPA, 1994 NE NEED Exposure Duration years 6 EPA, 1994 NE NEBW Body Weight kg 15 EPA, 1994 NE NE

AT-C Averaging Time (Cancer) days 25,550 EPA, 1989 NE NEAT-N Averaging Time (Non-Cancer) days 2,190 EPA, 1989 NE NE

Dermal Css Chemical Concentration in Surface Soil µg/g See EPC Table See EPC Table NE NECF Conversion Factor g/µg 1.00E-06 -- NE NE Intake Dermal = DA event x SA x EF x EDAF Adherence Factor mg/cm2 0.2 EPA, 1999; (3) NE NE BW x AT

AbF Absorption Factor % chemical-specific EPA, 1999; (2) NE NESA Skin Surface Area Available for Contact cm2 2,800 EPA, 1999; (3) NE NEEF Exposure Frequency days/year 150 EPA, 1994 NE NE Where:ED Exposure Duration years 6 EPA, 1994 NE NE DAevent = Css x AF x AbF x CFBW Body Weight kg 15 EPA, 1994 NE NE

AT-C Averaging Time (Cancer) days 25,550 EPA, 1989 NE NEAT-N Averaging Time (Non-Cancer) days 2,190 EPA, 1989 NE NE

Inhalation CA Chemical Concentration in Air µg/g3 See Equation See Equation NE NEPEF Particulate Emission Factor kg/m3 1.32E+09 EPA, 1996 NE NE Intake Inhalation = CA x ET x EF x EDET Exposure Time hours/day 8 (1) NE NE 24 hour/day x ATEF Exposure Frequency days/year 150 EPA, 1994 NE NEED Exposure Duration years 6 EPA, 1994 NE NE Where:

AT-C Averaging Time (Cancer) days 25,550 EPA, 1989 NE NE CA = Soil EPC x 1/PEF x 1000 µg/mgAT-N Averaging Time (Non-Cancer) days 2,190 EPA, 1989 NE NE

(1) Value Is assumed(2) See Exhibit 3.4 of EPA, 1999. Published AbF values for the COPCs evaluated in this risk assessment are as follows:

Arsenic: 0.03; PAHs: 0.13; the AbF for PAHs is used as a surrogate AbF for C11-C22 aromatic EPH.(3) See Exhibit 3.5 of EPA, 1999.EPA, 1989 (December), Risk Assessment Guidance for Superfund (RAGS), Volume 1, Human Health Evaluation Manual (Part A) EPA-540/1-89-002

(interim final). Office of Emergency and Remedial Response, Washington, DC.EPA, 1994 (August). Risk Updates No. 2; USEPA Region I, Waste Management Division. Values from Attachment 2 to Risk Updates No. 2.EPA, 1996 (May). Soil Screening Guidance: Technical Background Document. EPA/540/R-95/128.EPA, 1997 (August). Exposure Factors Handbook, Volume 1. EPA-600/P-95/002Fa. Office of Research and Development, Washington, DC.EPA, 1999. Risk Assessment Guidance for Superfund, Volume 1, Human Health Evaluation Manual (Part E) Interim Guidance. EPA-540/R-99-005.

Office of Solid Waste and Emergency Response, Washington, DC.

cm2 = square centimetersCT = central tendancyEPA = U.S. Environmental Protection AgencyEPC = exposure point concentrationEPH = extractable petroleum hydrocarbong/µg = grams per microgramkg = kilogramskg/m3 = kilograms per cubic metermg/cm2 = milligrams per square centimeterNE = not evaluatedPAH = polyaromatic hydrocarbonRME = reasonable maximum exposureµg/g = micrograms per gramµg/m3 = micrograms per cubic meterµg/mg = micrograms per milligram

I:\35Z01302 - FS-2\ROD\Draft\Tables\Tables 2-6, 2-7, 2-8, 2-9 (RAGS Part D Tables 4.1, 4.2, 4.3, 4.4).xls Table 4.3 Page 1 of 111/12/2001

Table 2-8 RAGS Part D Standard Table 4.3

Values Used for Daily Intake Calculations - Adult Resident AOC FS-2

Scenario Time Frame: Future Land UseMedium: SoilExposure Medium: Surface SoilExposure Points: Soil 0-2 feet bgs; Soil 0-10 feet bgsReceptor Population: ResidentReceptor Age: Adult

Exposure Route ParameterCode Parameter Definition Units RME

Value

RMERationale/Reference

CTValue

CTRationale/Reference

Intake Equation/Model Name

Ingestion Css Chemical Concentration in Surface Soil µg/g See EPC Table See EPC Table NE NE

CF Conversion Factor g/µg 1.00E-06 -- NE NE Intake Ingestion=Css x IR x FI x CF x EF x ED

IR Ingestion Rate of Surface Soil mg/day 100 EPA, 1994 NE NE BW x AT

FI Fraction Ingested from Source % 100% (1) NE NE

EF Exposure Frequency days/year 150 EPA, 1994 NE NE

ED Exposure Duration years 24 EPA, 1994 NE NE

BW Body Weight kg 70 EPA, 1994 NE NE

AT-C Averaging Time (Cancer) days 25,550 EPA, 1989 NE NE

AT-N Averaging Time (Non-Cancer) days 8,760 EPA, 1989 NE NE

Dermal Css Chemical Concentration in Surface Soil µg/g See EPC Table See EPC Table NE NE

CF Conversion Factor g/µg 1.00E-06 -- NE NE Intake Dermal = DA event x SA x EF x ED

AF Adherence Factor mg/cm2 0.07 EPA, 1999; (3) NE NE BW x AT

AbF Absorption Factor % chemical-specific EPA, 1999; (2) NE NE

SA Skin Surface Area Available for Contact cm2 5,700 EPA, 1999; (3) NE NE

EF Exposure Frequency days/year 150 EPA, 1994 NE NE Where:

ED Exposure Duration years 24 EPA, 1994 NE NE DAevent = Css x AF x AbF x CF

BW Body Weight kg 70 EPA, 1994 NE NE

AT-C Averaging Time (Cancer) days 25,550 EPA, 1989 NE NE

AT-N Averaging Time (Non-Cancer) days 8760 EPA, 1989 NE NE

Inhalation CA Chemical Concentration in Air µg/m3 See Equation See Equation NE NE

PEF Particulate Emission Factor kg/m3 1.32E+09 EPA, 1996 NE NE Intake Inhalation = CA x ET x EF x ED

ET Exposure Time hours/day 8 (1) NE NE 24 hour/day x AT

EF Exposure Frequency days/year 150 EPA, 1994 NE NE

ED Exposure Duration years 24 EPA, 1994 NE NE Where:

AT-C Averaging Time (Cancer) days 25,550 EPA, 1989 NE NE CA = Soil EPC x 1/PEF x 1000 µg/mg

AT-N Averaging Time (Non-Cancer) days 8,760 EPA, 1989 NE NE

(1) Value is assumed.(2) See Exhibit 3.4 of EPA, 1999. Published AbF values for the COPCs evaluated in this risk assessment are as follows:

Arsenic: 0.03; PAHs: 0.13; the AbF for PAHs is used as a surrogate AbF for C11-C22 aromatic EPH.(3) See Exhibit 3.5 of EPA, 1999.EPA, 1989 (December). Risk Assessment Guidance for Superfund (RAGS), Volume 1, Human Health Evaluation Manual (Part A). EPA-540/1-89-002

(interim final). Office of Emergency and Remedial Response, Washington, DC.EPA, 1994 (August). Risk Updates No. 2; USEPA Region I, Waste Management Division. Values from Attachment 2 to Risk Updates No. 2.EPA, 1996 (May). Soil Screening Guidance: Technical Background Document. EPA/540/R-95/128.EPA, 1997 (August). Exposure Factors Handbook, Volume 1. EPA-600/P-95/002Fa. Office of Research and Development, Washington, DC.EPA, 1999. Risk Assessment Guidance for Superfund, Volume 1, Human Health Evaluation Manual (Part E) Interim Guidance. EPA-540/R-99-005.

Office of Solid Waste and Emergency Response, Washington, DC.

cm2 = square centimetersCT = central tendancyEPA = U.S. Environmental Protection AgencyEPC = exposure point concentrationEPH = extractable petroleum hydrocarbong/µg = grams per microgramkg = kilogramskg/m3 = kilograms per cubic metermg/cm2 = milligrams per square centimeterNE = not evaluatedPAH = polyaromatic hydrocarbonRME = reasonable maximum exposureµg/g = micrograms per gramµg/m3 = micrograms per cubic meterµg/mg = micrograms per milligram

I:\35Z01302 - FS-2\ROD\Draft\Tables\Tables 2-6, 2-7, 2-8, 2-9 (RAGS Part D Tables 4.1, 4.2, 4.3, 4.4).xls Table 4.411/12/01 Page 1 of 1

Table 2-9 RAGS Part D Standard Table 4.4

Values Used for Daily Intake Calculations - Construction Worker AOC FS-2

Scenario Time Frame: FutureMedium: SoilExposure Medium: Surface and Subsurface SoilExposure Points: Soil 0-10 feet bgs; Soil 0-20 feet bgsReceptor Population: Construction WorkerReceptor Age: Adult

Exposure Route Parameter Parameter Definition Units RMEValue

RMERationale/Reference

CTValue

CTRationale/Reference

Intake Equation/Model Name

Ingestion Csu Chemical Concentration in Subsurface Soil µg/g See EPC Table See EPC Table NE NECF Conversion Factor g/µg 1.00E-06 -- NE NE Intake Ingestion = Csu x IR x FI x CF x EFIR Ingestion Rate of Subsurface Soil mg/day 200 EPA, 1999a NE NE x ED x BW x ATFI Fraction Ingested from Source % 100% (1) NE NEEF Exposure Frequency days/year 250 (2) NE NEED Exposure Duration years 0.5 (2) NE NEBW Body Weight kg 70 EPA, 1994 NE NE

AT-C Averaging Time (Cancer) days 25,550 EPA, 1989 NE NEAT-N Averaging Time (Non-Cancer) days 183 EPA, 1989 NE NE

Dermal Csu Chemical Concentration in Subsurface Soil µg/g See EPC Table See EPC Table NE NECF Conversion Factor g/µg 1.00E-06 -- NE NE Intake Dermal = DA event x SA x EF x EDAF Adherence Factor mg/cm2 0.2 EPA, 1999b (3) NE NE x BW x AT

AbF Absorption Factor % chemical-specific EPA, 1999b (4) NE NESA Skin Surface Area Available for Contact cm2 5,700 EPA, 1999b (5) NE NEEF Exposure Frequency days/year 250 (2) NE NE Where:ED Exposure Duration years 0.5 (2) NE NE DAevent = Csu x AF x AbF x CFBW Body Weight kg 70 EPA, 1994 NE NE

AT-C Averaging Time (Cancer) days 25,550 EPA, 1989 NE NEAT-N Averaging Time (Non-Cancer) days 183 EPA, 1989 NE NE

Inhalation CA Chemical Concentration in Air µg/m3 See Equation See Equation NE NEPEF Particulate Emission Factor kg/m3 1.32E+09 EPA, 1996 NE NE Intake Inhalation = CA x ET x EF x EDET Exposure Time hours/day 8 (1) NE NE 24 hour/day x ATEF Exposure Frequency days/year 250 (2) NE NEED Exposure Duration years 0.5 (2) NE NE Where:

AT-C Averaging Time (Cancer) days 25,550 EPA, 1989 NE NE CA = Soil EPC x 1/PEF x 1000 µg/mgAT-N Averaging Time (Non-Cancer) days 183 EPA, 1989 NE NE

(1) Value is assumed.(2) (5 workdays/week) X (50 weeks/year) = 250 days/year; it is assumed that construction activities occur each workday over a one-half year period.(3) See Exhibit 3.3 of EPA, 1999. Value based on: Utility Workers (geometric mean value).(4) See Exhibit 3.4 of EPA, 1999. Published AbF values for the COPCs evaluated in this risk assessment are as follows:

Arsenic: 0.03; PAHs: 0.13; the AbF for PAHs is used as a surrogate AbF for C11-C22 aromatic EPH.(5) See Exhibit 3.5 of EPA, 1999. Value for Industrial Workers.EPA, 1989 (December). Risk Assessment Guidance for Superfund, (RAGS) Volume 1, Human Health Evaluation Manual (Part A). EPA-540/1-89-002

(interim final). Office of Emergency and Remedial Response, Washington, DC.EPA, 1994 (August). Risk Updates No. 2: USEPA Region I, Waste Management Division. Values from Attachment 2 to Risk Updates No. 2.EPA, 1996 (May). Soil Screening Guidance: Technical Background Document. EPA/540/R-95/128.EPA, 1997 (August). Exposure Factors Handbook, Volume 1. EPA-600/P-95/002Fa. Office of Research and Development, Washington, DC.EPA, 1999. Value from “Frequently Asked Questions on the USEPA Adult Lead Model" (April), as recommended by USEPA Region I (EPA Comments

on the Draft Fuel Spill-2 Supplemental Remedial Investigation Report dated October 2000).

cm2 = square centimetersCT = central tendancyEPA = U.S. Environmental Protection AgencyEPC = exposure point concentrationEPH = extractable petroleum hydrocarbong/µg = grams per microgramkg = kilogramskg/m3 = kilograms per cubic metermg/cm2 = milligrams per square centimeterNE = not evaluatedPAH = polyaromatic hydrocarbonRME = reasonable maximum exposureµg/g = micrograms per gramµg/m3 = micrograms per cubic meterµg/mg = micrograms per milligram

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Table 2-10 Non-Cancer Toxicity Data Summary

AOC FS-2 Soils

Pathway: Ingestion, Dermal

Chemical of Potential Concern

Chronic/Subchronic

Oral RfDValue

Oral RfDUnits

DermalRfD

Dermal RfDUnits

Primary TargetOrgan

CombinedUncertainty/ModifyingFactors

Sources ofRfD: Target

Organ

Dates of RfD:Target Organ

Semivolatile Organics

Benzo(a)anthracenechronic -- --

subchronic -- --

Benzo(a)pyrenechronic -- --

subchronic -- --

Benzo(b)fluoranthenechronic -- --

subchronic -- --

Dibenzo(a,h)anthracenechronic -- --

subchronic -- --

Indeno(1,2,3-cd)pyrenechronic -- --

subchronic -- --

Inorganics

Arsenicchronic 3.0E-04 mg/kg/day 3.0E-04 mg/kg/day

Skin/Keratosisand

hyperpigmentation 3 IRIS Sept. 2000

subchronic 3.0E-04 mg/kg/day 3.0E-04 mg/kg/day

Skin/Keratosisand

hyperpigmentation 3 HEAST FY 1997

TPH

EPHchronic -- --

subchronic -- --

C11-C22 Aromaticchronic 3.0E-02 mg/kg/day 3.0E-02 mg/kg/day

Kidney/Renaltubular pathology 3,000 DEP (1)

subchronic 3.0E-01 mg/kg/day 3.0E-01 mg/kg/dayKidney/Renal

tubular pathology 300 DEP (1)

Pathway: Inhalation

Chemical of PotentialConcern

Chronic/Subchronic

InhalationRfC

InhalationRfC Unit

InhalationRfD

InhalationRfD Units

Primary TargetOrgan

CombinedUncertainty/ModifyingFactors

Sources ofRfC: RfD:

TargetOrgan

Dates

Semivolatile Organics

Benzo(a)anthracenechronic -- --

subchronic -- --

Benzo(a)pyrenechronic -- --

subchronic -- --

Benzo(b)fluoranthenechronic -- --

subchronic -- --

Dibenzo(a,h)anthracenechronic -- --

subchronic -- --

Indeno(1,2,3-cd)pyrenechronic -- --

subchronic -- --

Inorganics

Arsenic

chronic -- --

subchronic -- --

TPH

EPHchronic -- --

subchronic -- --

C11-C22 Aromaticschronic 7.1E-02 mg/m3

-- Kidney/Renaltubular pathology DEP

subchronic 7.1E-02 mg/m3-- Kidney/Renal

tubular pathology DEP

Notes: (1) Per DEP (1997), the value for pyrene (published in IRIS) is used to evaluate C11-C22 aromatics. -- : no data available DEP = Massachusetts Department of Environmental Protection (Characterizing Risks Posed by Petroleum Contaminated Sites. October 1997) EPH = extractable petroleum hydrocarbons HEAST = Health Effects Assessment Summary Tables: FY 1997 IRIS = Integrated Risk Information System: September 2000 mg/m3 = milligrams per cubic meter mg/kg/day = milligrams per kilogram per day RfC = reference concentrations RfD = reference dose TPH = total petroleum hydrocarbons

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Table 2-11 Cancer Toxicity Data Summary

AOC FS-2 Soils

Pathway: Ingestion, Dermal

Chemical ofPotential Concern

OralCancerSlopeFactor

DermalCancerSlopeFactor

Slope FactorUnits

Weight ofEvidence/

CancerGuideline

Description

Source Date

Semivolatile Organics

Benzo(a)anthracene 7.3E-01 7.3E-01 (mg/kg/day) -1 B2 IRIS September 2000

Benzo(a)pyrene 7.3E+00 7.3E+00 (mg/kg/day) -1 B2 IRIS September 2000

Benzo(b)fluoranthene 7.3E-01 7.3E-01 (mg/kg/day) -1 B2 IRIS September 2000

Dibenzo(a,h)anthracene 7.3E+00 7.3E+00 (mg/kg/day) -1 B2 IRIS September 2000

Indeno(1,2,3-cd)pyrene 7.3E-01 7.3E-01 (mg/kg/day) -1 B2 IRIS September 2000

Inorganics

Arsenic 1.5E+00 1.5E+00 (mg/kg/day) -1 A IRIS September 2000

TPH

EPH -- -- --

C11-C22 Aromatics -- -- D DEP

Pathway: Inhalation

Chemical ofPotential Concern

UnitRisk Units

InhalationCancer Slope

FactorUnits

Weight ofEvidence/

CancerGuideline

Description

Source Date

Semivolatile Organics

Benzo(a)anthracene 8.9E-05 (µg/m3)-1 3.1E-01 B2 NCEA October 1999

Benzo(a)pyrene 8.9E-04 (µg/m3)-1 3.1E+00 B2 NCEA October 1999

Benzo(b)fluoranthene 8.9E-05 (µg/m3)-1 3.1E-01 B2 NCEA October 1999

Dibenzo(a,h)anthracene 8.9E-04 (µg/m3)-1 3.1E+00 B2 NCEA October 1999

Indeno(1,2,3-cd)pyrene 8.9E-05 (µg/m3)-1 3.1E-01 B2 NCEA October 1999

Inorganics

Arsenic 4.3E-03 (µg/m3)-1 1.5E+01 (mg/kg/day)-1 A IRIS September 2000

TPH

EPH -- -- --

C11-C22 Aromatics -- -- D DEP

Notes:-- : No information availableDEP = Massachusetts Department of Environmental ProtectionEPH = extractable petroleum hydrocarbonsIRIS = Integrated Risk Information Systemmg/kg/day = milligrams per kilogram per dayNCEA - National Center for Environmental AssessmentPAH = polynuclear aromatic hydricarbonTPH = total petroleum hydrocarbonsµg/m3 = micrograms per cubic meter

EPA Weight of Evidence Group:A - Human carcinogenB1 - Probable human carcinogen - indicates that limited

human data are availableB2 - Probable human carcinogen - indicates sufficient evidence

in animals and inadequate or no evidence in humansC - Possible human carcinogenD - Not classifiable as a human carcinogenE - Evidence of noncarcinogenicity

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Table 2-12 Human Health Risk Summary

AOC FS-2 Soils

Exposure Scenario Exposure Point Exposure Route HI ELCRCurrent Land Use

Trespasser - Surface Soil 0-2 feet bgs Soil 0-2 feet bgs Ingestion 0.02 1E-06Dermal 0.009 7E-07Dust Inhalation 0.00000009 6E-11

Soil 0-2 ft bgs 0.03 2E-06

Total Receptor Risk 0.03 2E-06

Future Land Use Child Resident - Surface Soil 0-2 feet bgs Soil 0-2 feet bgs Ingestion 0.1 5E-06Dermal 0.02 1E-06Dust Inhalation 0.0000004 1E-10

Soil 0-2 ft bgs 0.1 6E-06

Total Child Risk 0.1 6E-06

Adult Resident - Surface Soil 0-2 feet bgs Soil 0-2 feet bgs Ingestion 0.01 2E-06Dermal 0.004 6E-07Dust Inhalation 0.0000004 6E-10

Soil 0-2 ft bgs 0.02 3E-06

Total Adult Risk 0.02 3E-06

Total Receptor Risk NA 9E-06

Child Resident - Surface Soil 0-10 feet bgs Soil 0-10 ft bgs Ingestion 0.1 9E-06Dermal 0.03 3E-06Dust Inhalation 0.0000005 2E-10

Soil 0-10 ft bgs 0.2 1E-05

Total Child Risk 0.2 1E-05

Ingestion 0.01 4E-06Adult Resident - Surface Soil 0-10 feet bgs Soil 0-10 ft bgs Dermal 0.004 2E-06

Dust Inhalation 0.0000005 6E-10Soil 0-10 ft bgs 0.02 6E-06

Total Adult Risk 0.02 6E-06

Total Receptor Risk NA 2E-05

Construction Worker - Surface Soil 0-10 feet bgs Soil 0-10 ft bgs Ingestion 0.03 3E-07Dermal 0.006 2E-07Dust Inhalation 0.0000009 2E-11

Soil 0-10 ft bgs 0.03 5E-07

Total Receptor Risk 0.03 5E-07

Ingestion 0.03 9E-08Construction Worker - Surface Soil 0-20 feet bgs Soil 0-20 ft bgs Dermal 0.007 7E-08

Dust Inhalation 0.0000009 1E-12Soil 0-20 ft bgs 0.04 2E-07

Total Receptor Risk 0.04 2E-07

Notes: ELCR = Excess Lifetime Cancer Risk ft bgs = feet below ground surface HI = Hazard Index NA = not applicable ND = no dose-response values available for contaminants of potential concern.

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Table 2-13 Occurrence and Distribution of Contaminants of Potential Ecological Concern for Terrestrial Receptors

AOC FS-2 Surface Soils (0-2 feet bgs)

CASNumber Chemical

MinimumConcentration

(1)

MinimumQualifier

MaximumConcentration

(1)

MaximumQualifier Units

Locationof Maximum

Concentration

DetectionFrequency

Range ofDetection

Limits

VOCs67641 Acetone 5 J 61 µg/kg 32BH0009 3/10 2.3-4.275092 Methylene Chloride 6 J 6 J µg/kg 32BH0010 1/10 4.4-16127184 Tetrachloroethene 64 J 64 J µg/kg 32BH0010 1/10 0.4-0.7108883 Toluene 4 J 6 J µg/kg 32BH0010 2/10 0.6-1.1

SVOCs83329 Acenaphthene 31 J 71 J µg/kg 32BH0010 3/10 9.2-10.4208968 Acenaphthylene 18 J 190 J µg/kg 32BH0010 4/10 8.7-9.5120127 Anthracene 32 J 140 J µg/kg 32BH0002 9/10 11-1256553 Benzo(a)anthracene 120 J 760 µg/kg 32BH0002 10/10 11.9-13.150328 Benzo(a)pyrene 110 J 600 µg/kg 32BH0002 10/10 12.1-13.3205992 Benzo(b)fluoranthene 140 J 790 µg/kg 32BH0002 10/10 16.1-17.8191242 Benzo(g,h,i)perylene 58 J 350 J µg/kg 32BH0002 10/10 8.1-8.9207089 Benzo(k)fluoranthene 62 J 300 J µg/kg 32BH0002 10/10 19.7-21.7117817 Bis(2-ethylhexyl)phthalate 22 J 60 J µg/kg 32BH0010 6/10 25.6-28.286748 Carbazole 21 J 100 J µg/kg 32BH0010 8/10 14-15.4218019 Chrysene 120 J 810 µg/kg 32BH0002 10/10 9.1-10.053703 Dibenz(a,h)anthracene 20 J 110 J µg/kg 32BH0002 10/10 9.6-10.5132649 Dibenzofuran 18 J 550 µg/kg 32BH0010 2/10 13.4-14.884742 Di-n-butyl phthalate 43 J 43 J µg/kg 32BH0007 1/10 16.8-18.5206440 Fluoranthene 190 J 1,200 µg/kg 32BH0010 10/10 13.8-15.186737 Fluorene 28 J 85 J µg/kg 32BH0010 3/10 15.4-16.9193395 Indeno(1,2,3-cd)pyrene 90 J 510 J µg/kg 32BH0002 10/10 11-12.191576 2-Methylnaphthalene 1,700 1,700 µg/kg 32BH0010 1/10 17.3-19.191203 Naphthalene 1,100 1,100 µg/kg 32BH0010 1/10 18.1-19.985018 Phenanthrene 30 J 1,200 µg/kg 32BH0010 10/10 12.1-13.3129000 Pyrene 140 J 930 µg/kg 32BH0002 10/10 12-13.2

VPH/EPH Carbon FractionsC11-C22 Aromatics 22 350 mg/kg 32BH0010 2/10 4.5-5.0C19-C36 Aliphatics 7 70 mg/kg 32BH0010 4/10 2.4-2.6C5-C8 Aliphatics 12 12 mg/kg 32BH0010 1/10 2.1C8-C12 Aliphatics 9.1 9.1 mg/kg 32BH0010 1/10 0.6C9-C10 Aromatics 4.4 4.4 mg/kg 32BH0010 1/10 1.3-1.4C9-C18 Aliphatics 78 78 mg/kg 32BH0010 1/10 0.7

Inorganics7429905 Aluminum 1,490 J 6,730 J mg/kg 32BH0002 10/10 2-2.97440382 Arsenic 0.64 J 7.3 J mg/kg 32BH0010 10/10 0.3-0.47440393 Barium 5.3 J 26.2 J mg/kg 32BH0010 10/10 0.17440702 Calcium 141 J 1,690 J mg/kg 32BH0008 10/10 1.0-3.616065831 Chromium 3.3 15.7 mg/kg 32BH0002 10/10 0.1-0.27440484 Cobalt 0.99 J 2.3 J mg/kg 32BH0003 10/10 0.1-0.67440508 Copper 2.0 J 11.4 J mg/kg 32BH0008 10/10 0.3-0.47439896 Iron 3,300 J 9,880 J mg/kg 32BH0010 10/10 0.6-3.77439921 Lead 6.4 J 55.9 J mg/kg 32BH0001 10/10 0.37439954 Magnesium 317 J 1,120 mg/kg 32BH0003 10/10 0.9-1.27439965 Manganese 22.7 144 mg/kg 32BH0008 10/10 0.2-0.37439976 Mercury 0.01 J 0.012 J mg/kg 32BH0010 10/10 0.01-0.127440020 Nickel 2.4 J 4.8 J mg/kg 32BH0003 8/10 0.2-2.57440097 Potassium 127 J 280 J mg/kg 32BH0003 10/10 57-727782492 Selenium 0.69 J 1.4 mg/kg 32BH0010 2/10 0.5-0.77440224 Silver 0.34 J 0.34 J mg/kg 32BH0009 1/10 0.2-0.67440235 Sodium 33 J 33 J mg/kg 32BH0008 1/10 2.6-627440622 Vanadium 6.1 J 10.1 J mg/kg 32BH0009 5/10 0.2-10.57440666 Zinc 4.9 18.7 mg/kg 32BH0007 10/10 0.1-0.3

Notes: Definitions:

(1) Minimum/maximum detected concentration in soils collected from 0 to 2 feet in depth. bgs = below ground surface CAS = Chemical Abstract Service EPH = extractable petroleum hydrocarbons J = estimated value mg/kg = milligrams per kilogram SVOC = semivolatile organic compound VOC = volatile organic compound VPH = volatile petroleum hydrocarbons

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Table 2.14Selection of Contaminants of Potential Ecological Concern for Terrestrial Receptors

AOC FS-2 Surface Soils (0-2 feet bgs)

CASNumber

Chemical MaximumConcentration

(1)

MaximumQualifier Units

Location ofMaximum

Concentration

DetectionFrequency

PreliminaryBackground

Value(2)

(UTL)

Screening Benchmark Concentrations Preliminary Remediation Goals forTerrestrial Ecological

Endpoint (5) COPECFlag

Rationalefor

ContainmentDeletion

or Selection (6)

PlantPhyto-toxicity

(3)

Soil, LitterInvertebratesHeterotrophic

Processes(4)

Soil PRG for Wildlife (5)

White-FootedMouse

Short-TailedShrew

AmericanWoodchuck Conc. Endpoint

VOCs67641 Acetone 61 µg/kg 32BH0009 3/10 NA N LPER75092 Methylene Chloride 6 J µg/kg 32BH0010 1/10 NA N LPER

127184 Tetrachloroethene 64 J µg/kg 32BH0010 1/10 NA N LPER108883 Toluene 6 J µg/kg 32BH0010 2/10 NA 200,000 N LPER

SVOCs83329 Acenaphthene 71 J µg/kg 32BH0010 3/10 ND 20,000 20,000 plant b,c N BSL

208968 Acenaphthylene 190 J µg/kg 32BH0010 4/10 ND Y NSL, HX120127 Anthracene 140 J µg/kg 32BH0002 9/10 ND Y NSL, HX56553 Benzo(a)anthracene 760 µg/kg 32BH0002 10/10 ND Y NSL, HX50328 Benzo(a)pyrene 600 µg/kg 32BH0002 10/10 ND Y NSL, HX

205992 Benzo(b)fluoranthene 790 µg/kg 32BH0002 10/10 ND Y NSL, HX191242 Benzo(g,h,i)perylene 350 J µg/kg 32BH0002 10/10 ND Y NSL, HX207089 Benzo(k)fluoranthene 300 J µg/kg 32BH0002 10/10 ND Y NSL, HX117817 Bis(2-ethylhexyl)phthalate 60 J µg/kg 32BH0010 6/10 ND Y NSL, HX86748 Carbazole 100 J µg/kg 32BH0010 8/10 ND Y NSL, HX

218019 Chrysene 810 µg/kg 32BH0002 10/10 No UTL Y NSL, HX53703 Dibenz(a,h)anthracene 110 J µg/kg 32BH0002 10/10 ND Y NSL, HX

132649 Dibenzofuran 550 µg/kg 32BH0010 2/10 ND Y NSL, HX84742 Di-n-butyl phthalate 43 J µg/kg 32BH0007 1/10 ND 200,000 200,000 plant b,c N BSL

206440 Fluoranthene 1,200 µg/kg 32BH0010 10/10 No UTL Y NSL, HX86737 Fluorene 85 J µg/kg 32BH0010 3/10 ND 30,000 a N BSL

193395 Indeno(1,2,3-cd)pyrene 510 J µg/kg 32BH0002 10/10 ND Y NSL, HX91576 2-Methylnaphthalene 1,700 µg/kg 32BH0010 1/10 ND Y NSL, HX91203 Naphthalene 1,100 µg/kg 32BH0010 1/10 ND Y NSL, HX85018 Phenanthrene 1,200 µg/kg 32BH0010 10/10 No UTL Y NSL, HX

129000 Pyrene 930 µg/kg 32BH0002 10/10 No UTL Y NSL, HXVPH/EPH Carbon FractionsC11-C22 Aromatics 350 mg/kg 32BH0010 2/10 NA Y NSL, HXC19-C36 Aliphatics 70 mg/kg 32BH0010 4/10 NA Y NSL, HXC5-C8 Aliphatics 12 mg/kg 32BH0010 1/10 NA Y NSL, HXC8-C12 Aliphatics 9.1 mg/kg 32BH0010 1/10 NA Y NSL, HXC9-C10 Aromatics 4.4 mg/kg 32BH0010 1/10 NA Y NSL, HXC9-C18 Aliphatics 78 mg/kg 32BH0010 1/10 NA Y NSL, HX

Inorganics7429905 Aluminum 6,730 J mg/kg 32BH0002 10/10 13,016 50 600 b N ELEM7440382 Arsenic 7.3 J mg/kg 32BH0010 10/10 4 10 60 a,100 b 149 9.9 102 9.9 shrew, plant N BSL7440393 Barium 26.2 J mg/kg 32BH0010 10/10 17 500 3000 b 1,775 329 283 283 woodcock b N BSL7440702 Calcium 1,690 J mg/kg 32BH0008 10/10 209 N NUT

16065831 Chromium 15.7 mg/kg 32BH0002 10/10 10 1 0.4 a, 10 b 880 110 16.1 0.4 a earthworm c Y ASL7440484 Cobalt 2.3 J mg/kg 32BH0003 10/10 2 20 1000 b 20 a plant b,c N BSL7440508 Copper 11.4 J mg/kg 32BH0008 10/10 3 100 50 a, 100 b 10,100 370 515 60 d earthworm c N BSL7439896 Iron 9,880 J mg/kg 32BH0010 10/10 14,848 200 b N NUT7439921 Lead 55.9 J mg/kg 32BH0001 10/10 18 50 500 a, 900 b 6,250 740 40.5 40.5 woodcock Y ASL

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Table 2-14Selection of Contaminants of Potential Ecological Concern for Terrestrial Receptors

AOC FS-2 Surface Soils (0-2 feet bgs)

CASNumber Chemical

MaximumConcentration

(1)

MaximumQualifier Units

Location ofMaximum

Concentration

DetectionFrequency

PreliminaryBackground

Value(2)

(UTL)

Screening Benchmark Concentrations PreliminaryRemediation Goals forTerrestrial Ecological

Endpoint (5) COPECFlag

Rationalefor

ContainmentDeletion

or Selection(6)

PlantPhyto-toxicity

(3)

Soil, LitterInvertebratesHeterotrophic

Processes(4)

Soil PRG for Wildlife (5)

White-FootedMouse

Short-TailedShrew

AmericanWoodchuck Conc. Endpoint

7439954 Magnesium 1,120 mg/kg 32BH0003 10/10 1,015 N NUT

7439965 Manganese 144 mg/kg 32BH0008 10/10 24 500 100 b Y ASL

7439976 Mercury 0.012 J mg/kg 32BH0010 10/10 No UTL 0.3 0.1 a, 100 b 7.1 0.146 0.00051 0.00051 e woodcock Y ASL

7440020 Nickel 4.8 J mg/kg 32BH0003 8/10 8 30 200 a, 90 b 1,830 246 121 30 plant c N BSL

7440097 Potassium 280 J mg/kg 32BH0003 10/10 265 N NUT

7782492 Selenium 1.4 mg/kg 32BH0010 2/10 No UTL 1 70 a, 100 b 0.21 0.21 mouse c Y ASL

7440224 Silver 0.34 J mg/kg 32BH0009 1/10 ND 2 50 b 2 a plant c N BSL

7440235 Sodium 33 J mg/kg 32BH0008 1/10 ND N NUT

7440622 Vanadium 10.1 J mg/kg 32BH0009 5/10 28 2 20 b 1,120 55 2 a plant b,c Y ASL

7440666 Zinc 18.7 mg/kg 32BH0007 10/10 17 50 200 a, 100 b 35,000 1,600 8.5 8.5 woodcock c Y ASL

Notes:(1) Minimum/maximum detected concentration(2) Preliminary background data from Ogden Environmental and Energy Services. 1998 (July). Draft Completion of Work Report, Volume 5:

Appendix F - Evaluation of Background Data. Massachusetts Military Reservation, Cape Cod, MA. Prepared for National Guard Bureau, Arlington, VA.(3) Efroymson, RA., M.E. Will, G.W. Suter II, and A. C. Wooten. 1997 (November). Toxicological Benchmarks for Screening Contaminants of Potential Concern for Effects on Terrestrial Plants, 1997 Revision

ES/ER/TM-85/R3. Oak Ridge National Laboratory, Oak Ridge, TN.(4) Efroymson, R.A., M.E. Will, and G.W. Suter II. 1997 (November). Toxicological Benchmarks for Screening Contaminants of Potential Concern for Effects on Soil and Litter Invertebrates and Heterotrophic Process

1997 Revision. ES/ER/TM-126/R2. Oak Ridge National Laboratory, Oak Ridge, TN. a Earthworms b Soil microorganisms and microbial processes

(5) Efroymson, R.A., G.W. Suter II, B.E. Sample and D.S. Jones. 1997 (August). Preliminary Remediation Goals for Ecological EndpointsES/ER/TM-162/R2. Oak Ridge National Laboratory, Oak Ridge, TN.a Efroymson et al. have low confidence in this value.b Toxic concentration benchmarks are not available for earthworms. Therefore, the preliminary remediation goal (PRG) cannot be assumed to protect earthworms.c Soil-plant uptake models, soil-earthworm uptake models or lowest observed adverse effect levels (LOAELs) were not available for this chemical for at least one wildlife endpoint. Therefore, the PRG cannot be assumed to protect wildlife.d Efroymson et al. have moderate confidence in this value.e This value is so low that it may often be within background soil concentrations. Efroymson et al. do not recommend that remedial goals be set within the range of background concentrations.

(6) Rationale Codes Selection Reason: Deletion Reason: Definitions:Above Screening Level (ASL) Below Screening Level (BSL) bgs = below ground surface J = Estimated value ND = not detectedNo Screening Level (NSL) Low Persistence (LPER) CAS = Chemical Abstract Service NA = not analyzed UTL = upper tolerance limitSite History (HX) Essential Nutrient (NUT) Conc. = concentration mg/kg = milligrams per kilogram Y = Yes

Abundant Element in Soil (ELEM) COPEC = chemical of potential ecological concern N = No �g/kg = micrograms per kilogram

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Table 2-15 Surface Soil Exposure Point Concentrations for COPECs

Soils (0 to 2 feet bgs)AOC FS-2

COPEC Units ArithmeticMean

95% UCL ofLognormal

Data

MaximumDetected

Concentration

MaximumQualifier

EPCUnits

Semivolatile Organics2-METHYLNAPTHALENE µg/kg 178 846 1700 µg/kgACENAPHTHYLENE µg/kg 30 151 190 J µg/kgANTHRACENE µg/kg 68 205 140 J µg/kgBENZO(A)ANTHRACENE µg/kg 318 540 760 µg/kgBENZO(A)PYRENE µg/kg 251 382 600 µg/kgBENZO(B)FLUORANTHENE µg/kg 373 598 790 µg/kgBENZO(G,H,I)PERYLENE µg/kg 140 218 350 J µg/kgBENZO(K)FLUORANTHENE µg/kg 132 200 300 J µg/kgBIS(2-ETHYLHEXYL)PHTHALATE µg/kg 25 38 60 J µg/kgCARBAZOLE µg/kg 37 89 100 J µg/kgCHRYSENE µg/kg 336 580 810 µg/kgDIBENZ(A,H)ANTHRACENE µg/kg 45 69 110 J µg/kgDIBENZOFURAN µg/kg 63 213 550 µg/kgFLUORANTHENE µg/kg 616 997 1200 µg/kgINDENO(1,2,3-C,D)PYRENE µg/kg 194 299 510 µg/kgNAPHTHALENE µg/kg 119 389 1100 µg/kgPHENANTHRENE µg/kg 315 886 1200 µg/kgPYRENE µg/kg 423 677 930 µg/kgInorganicsCHROMIUM (TOTAL) mg/kg 5.9 8.2 16 mg/kgLEAD (TOTAL) mg/kg 20 41 56 J mg/kgMANGANESE (TOTAL) mg/kg 56 81 144 mg/kgMERCURY (TOTAL) mg/kg 0.034 0.057 0.12 mg/kgSELENIUM (TOTAL) mg/kg 0.43 0.65 1.4 mg/kgVANADIUM (TOTAL) mg/kg 6.1 8.0 10 mg/kgZINC (TOTAL) mg/kg 11 15 19 mg/kgExtractable Petroleum HydrocarbonsC11-C22 AROMATIC HYDROCARBONS mg/kg 39 269 350 mg/kgC19-C36 ALIPHATIC HYDROCARBONS mg/kg 10 59 70 mg/kgC9-C18 ALIPHATIC HYDROCARBONS mg/kg 8.4 37 78 mg/kgVolatile Petroleum HydrocarbonsC5-C8 ALIPHATIC HYDROCARBONS mg/kg 2.1 3.6 12 mg/kgC8-C12 ALIPHATIC HYDROCARBONS mg/kg 1.2 2.8 9.1 mg/kgC9-C10 AROMATIC HYDROCARBONS mg/kg 0.74 1.3 4.4 mg/kg

bgs = below ground surface COPEC = chemical of potential ecological concern EPC = exposure point concentration J = estimated value mg/kg = milligrams per kilogram UCL = upper confidence limit on the arithmetic mean µg/kg = a micrograms per kilogram

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Table 2-16 Life History Parameters for Selected Endpoint Species

AOC FS-2

Receptor Parameter Value Comment Reference

White-Footed Mouse (Peromyscus leucopus)Body weight (kg) 0.022 Sample and Suter 1994Food consumption rate(g/d)

3.4 Sample and Suter 1994

Soil consumption rate(g/d)

0.068 based on 2% of foodconsumptionrate

Sample and Suter 1994

Diet Composition (%) invertebrates – 50%plants – 48%

Sample and Suter 1994

Home Range (ha) 0.059 Sample and Suter 1994Habitat Requirements wooded, brushy area:

sometimes open areasSample and Suter 1994

Population Density (/ha) 6-57 Sample and Suter 1994Behavior While semi-arboreal,

spends most of time onground. Primarilynocturnal. Enters torpor toreduce metabolicdemands in winter andduring food stress.Exposure duration = 0.67

Sample and Suter 1994

Upland Sandpiper (Bartramia longicauda)Body weight (kg) 0.047 http://www.inhs.uiuc.edu/

chf/pub/virtualbird/species/upland-sandpiper.html

Food consumption rate(g/d)

7.95 calculated EPA 1993

Soil consumption rate(g/d)

0.24 based on 3% offoodconsumptionrate

EPA 1993 (spotted sandpiper)

Diet Composition (%) Invertebrates – 97% EPA 1993 (spotted sandpiper)Home Range (ha) 0.25 EPA 1993 (spotted sandpiper)

Habitat Requirements Inhabits grassy openareas, ranging fromsandy, sparsely vegetatedflats to open, grassy bogsand muskeg.

http://www.npwrc.usgs.gov/resource/1998/forest/species/barlong.hmt

Population Density (/ha) 3-12Behavior Nests in depressions on

the ground among rankgrasses. Prefers to foragewhere the grasses are lowand open enough toprovide good visibility, andwhere grasshoppers andcrickets are mostabundant. Winters in South America. Exposure duration= 0.67.

http://www.npwrc.usgs.gov/resource/1998/forest/species/bartlong.htm

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Table 2-16 Life History Parameters for Selected Endpoint Species

AOC FS-2

Receptor Parameter Value Comment Reference

Shot-Tailed Shrew (Blarina brevicauda)Body weight (kg) 0.017 EPA 1993Food consumption rate(g/d)

7.95 EPA 1993

Soil consumption rate(g/d)

0.159 based on 2%of foodconsumptionrate

Diet Composition (%) plants 13%invertebrates 85%

EPA 1993

Home Range (ha) 0.39 EPA 1993Habitat Requirements wide and diverse – occur

in many habitats, typicallyprefers cool and moistvegetative areas

EPA 1993

Population Density (/ha) 2.3 – 11.4 EPA 1993Behavior active year round – does

not hibernateAmerican Robin (Turdus migratorius)

Body weight (kg) 0.081 average EPA 1993Food consumption rate(g/d)

97.6 average EPA 1993

Soil consumption rate(g/d)

2.91 based on 3%of foodconsumptionrate

EPA 1993

Diet Composition (%) fruit/plants -68%invertebrates -32%

summer,eastern UnitedStates

EPA 1993

Home Range (ha) 0.25 average EPA 1993Habitat Requirements wide and diverse – occur

in many habitats, typicallyprefers cool and moistforests and scrub/shrubhabitats

EPA 1993

Population Density (/ha) 10.3 average ofpairs, timestwo

EPA 1993

Behavior assumed to be a year-round resident

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Table 2-16 Life History Parameters for Selected Endpoint Species

AOC FS-2

Receptor Parameter Value Comment Reference

Eastern Box Turtle (Terrapena carolina carolina)

Body weight (kg) 0.382 EPA 1993a

Food consumptionrate (g/d)

1.29 based onallometricequation foriguana

EPA 1993a

Soil consumption rate(g/d)

0.0773 based on6% of foodconsumptionrate

EPA 1993a

Diet Composition (%) invertebrates 55%plants 45%

summer EPA 1993a

Home Range (ha) 2.61 average EPA 1993a

Habitat Requirements wooded, brushy areas;sometimes open areas usuallymoist

EPA 1993a

Population Density(/ha)

17-35 Maryland forest

EPA 1993a

Behavior Species is diurnal, resting atnight in hollowed-outdepressions; most active intemperate humid conditions,and typically avoids hotweather by burrowing into theground; hibernates fromOctober to April. Exposureduration=0.67.

EPA 1993a

References: EPA (U.S. Environmental Protection Agency. 1993 (December). Wildlife Exposure Factors Handbook. Office of Research and Development, Washington, DC. EPA/600/R-93/187.

Sample, B.E. and G.W. Suter II. 1994 (September). Estimating Exposure of Terrestrial Wildlife to Contaminants. Oak Ridge National Laboratory, Oak Ridge, TN.

g/d = grams per day kg = kilograms

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Table 2-17 Bioaccumulation Factors for Selected Ecological Receptor Groups 1

AOC FS-2

AnalyteSoil-plant

(kg/kg)Soil-invertebrate

(kg/kg)Food-bird

(kg/kg)Food-mammal

(kg/kg)Chromium 6.50E-02 b 2.45E-01 a 7.64E-05 h 7.64E-05 eLead 3.89E-02 b 2.13E-01 a 4.17E-06 h 4.17E-06 eManganese 1.13E-01 b 5.40E-02 a 6.94E-04 c 5.56E-06 eMercury 6.52E-01 b 3.15E+00 a 4.17E-04 c 3.47E-03 eSelenium 6.72E-01 b 1.19E+00 a 1.25E-01 c 2.08E-04 eVanadium 5.00E-03 b 3.36E-02 a 3.47E-05 h 3.47E-05 eZinc 3.66E-01 b 3.03E+00 a 9.72E-02 c 1.39E-03 eAcenaphthylene 1.52E-01 f,g 2.50E-01 m 7.46E-06 h 7.46E-06 f,jAnthracene 1.39E-01 f,g 2.50E-01 m 8.76E-06 h 8.76E-06 f,jBenzo(a)anthracene 2.46E-02 f,g 2.16E-01 l 1.75E-04 h 1.75E-04 f,jBenzo(a)pyrene 7.03E-02 f 2.72E-01 l 3.49E-04 h 3.49E-04 f,jBenzo(b)fluoranthene 6.24E-02 f,g 1.68E-01 l 3.49E-05 h 3.49E-05 f,jBenzo(ghi)perylene 7.41E-03 f,g 2.50E-01 m 1.39E-03 h 1.39E-03 f,jBenzo(k)fluoranthene 6.24E-02 f,g 1.68E-01 l 3.49E-05 h 3.49E-05 f,jBis(2-ethylhexyl)phthalate 5.46E-02 f,g 2.50E-01 m 4.39E-05 h 4.39E-05 f,jCarbazole 8.70E-03 f,g 5.00E-02 m 0.00E+00 h 0.00E+00 f,jChrysene 2.46E-02 f,g 2.50E-01 m 1.75E-04 h 1.75E-04 f,jDibenz(a,h)anthracene 5.68E-03 f,g 2.50E-01 m 2.20E-03 h 2.20E-03 f,jDibenzofuran 1.65E-01 f,g 2.50E-01 m 0.00E+00 0.00E+00Fluoranthene 7.12E-02 f,g 2.50E-01 m 2.77E-05 h 2.77E-05 f,jIndeno(1,2,3-cd)pyrene 7.41E-03 f,g 2.50E-01 m 1.39E-03 h 1.39E-03 f,j2-Methylnaphthalene 5.99E-01 f,g 2.50E-01 m 6.96E-07 h 6.96E-07 f,jNaphthalene 5.99E-01 f,g 2.50E-01 m 6.96E-07 h 6.96E-07 f,jPhenanthrene 1.06E-01 f,g 2.50E-01 m 1.39E-05 h 1.39E-05 f,jPyrene 7.12E-02 f,g 2.50E-01 m 2.77E-05 h 2.77E-05 f,j1 = All transfer factors expressed as dry tissue concentrations. Dry weight calculated by wet wt/ (1-% water in prey). kg/kg = kilograms per kilogram a = Efroymson et al. 1997. Toxicological Benchmarks for Screening Contaminants of Potential Concern for Effects on

Terrestrial Plants. U.S. Department of Energy, Oak Ridge, TN. b = Efroymson et al. 1997. Toxicological Benchmarks for Potential Contaminants of Concern for Effects on Soil and

Litter Invertebrates and Heterotrophic Process. ES/ER/TM-126/R2. Oak Ridge National Laboratory, Oak Ridge, TN. c = IAEA (1994) e = Baes et al. 1984. A Review and Analysis of Parameters for Assessing Transport of Environmentally Released

Radionuclides Through Agriculture. ORNL-5786. Oak Ridge National Laboratory, Oak Ridge, TN. f = Travis. C.C. and A.D. Arms. 1988. Bioconcentrations of Organics in Beef, Milk and Vegetation.

Environ. Sci. Tech. 22: 271-274. g = Plant uptake factor calculated using the following equation presented by Travis and Arms (1988) unless otherwise

noted:log (plant uptake factor) = 1.588 - 0.578 log Kow; if log Kow < 5,bioaccumulation factors (BAF) assumed to be 0.02 assuming plant are 80% water.

h = Surrogate mammal BAF was used. j = Mammal BTF calculated using the following equation presented by Travis and Arms (1988):

log BTF = log Kow - 7.6 where BTF (d/kg wet tissue) can be converted to a BAF by multiplying by the animal's ingestion rate (kg wet food/d)

I = Beyer, W.N. and C. Stafford. 1993. Survey and evaluation of contaminants in earthworms and soils from dredgedmaterial at confined disposal facilities in the Great Lakes region. Environ. Monit. Assess. 24: 151-165.

m = Menzie et al. 1992. Assessment of methods for estimating risk in terrestrial component: A case study at the Baird and McGuire Superfund site in Holbrook, MA. Environ. Toxicol. Chem. 11: 245.260.

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Table 2-18 Ecological Screening of Terrestrial Plants for Surface Soil Exposure

AOC FS-2

Contaminant of Concern

Maximum Soil

Concentration(mg/kg)

PhytotoxicityBenchmark

(mg/kg)Reference

ExceedsMaximum

Benchmark?

SEMIVOLATILEORGANIC COMPOUNDSAcenaphthylene 0.19 20 Efroymson 1997 NoAnthracene 0.14 20 acenaphthylene surrogate NoBenzo(a)anthracene 0.76 20 acenaphthylene surrogate NoBenzo(a)pyrene 0.6 20 acenaphthylene surrogate NoBenzo(b)fluoranthene 0.79 20 acenaphthylene surrogate NoBenzo(g,h,i)perylene 0.35 20 acenaphthylene surrogate NoBenzo(k)fluoranthene 0.3 20 acenaphthylene surrogate NoBis(2-ethylhexyl)phthalate 0.06 100 Hulzebos et al. 1993 NoCarbozole 0.1 NA NoChrysene 0.81 20 acenaphthylene surrogate NoDibenz(a,h)anthracene 0.11 20 acenaphthylene surrogate NoDibenzofuran 0.55 600 Hulzebos et al. 1993 NoFluoranthene 1.2 20 acenaphthylene surrogate NoIndeno(1,2,3-cd)pyrene 0.51 20 acenaphthylene surrogate No2-Methylnaphthalene 1.7 10 Hulzebos et al. 1993 NoNapthalene 0.11 10 Hulzebos et al. 1993 NoPhenanthrene 1.2 20 acenaphthylene surrogate NoPyrene 0.93 20 acenaphthylene surrogate NoINORGANIC ANALYTESChromium 16 1 Efroymson 1997 YesLead 56 50 Efroymson 1997 YesManganese 144 500 Efroymson 1997 NoMercury 0.12 0.3 Efroymson 1997 NoSelenium 1.4 1 Efroymson 1997 YesVanadium 10 2 Efroymson 1997 YesZinc 19 50 Efroymson 1997 NoReferences: Efroymsen, R.A., M.E. Will and G.W. Suter II. 197 (November). Toxicological Benchmarks for ScreeningContaminants of Potential Concern for Effects on Terrestial Plants: 1997 Revision. ES/ER/TM-85/R3. Oak Ridge NationalLaboratory, Oak Ridge, TN.

Hulzebos, E.M., D.M.M. Adema, E.M. Dirven-van Breeman, L. Henzen, W.A. van Dis, H.A. Herbold, J.A. Hoekstra, R.Baearselman, and C.A.M. van Gestel. 1993. Phytotoxicity studies with Lactuca savtiva in soil and nutrient solution. Environ.Toxicol. and Chem. 12:1079-1094.

mg/kg = milligrams per kilogram NA = not available

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Table 2-19Background Surface Soil Concentrations for Urban Areas in Massachusetts

AOC FS-2

Analytes BackgroundConcentrationRange (mg/kg)1

Maximum SoilConcentration At

FS-2 (mg/kg)

ExceedsBackground

Range?

INORGANIC ANALYTES (mg/kg)Aluminum 8930-13000 6730 noAntimony 1.4 - 17.5 - noArsenic 3.6 - 17 7.3 noBarium 10.4 - 45 26 noBeryllium 0.4 - 0.65 - noCadmium 1.5 - 2 - noChromium 6.8 - 29 16 noCobalt 4.1 - 4.4 2.3 noCopper 5.2 - 38 11 noLead 12.05 - 99 56 noManganese 108 - 300 144 noMercury 0.06 - 0.3 0.12 noNickel 5.2 - 17 4.8 noSelenium 0.33 - 0.5 1.4 yesSilver 0.6 - 14 0.34 noVanadium 15.2 - 29 10 noZinc 16 - 116 10 no

1 Values obtained from the Massachusetts Military Reservation Risk Assessment Handbook (ASG 1994) and Guidance for Disposal Site RiskCharacterization (DEP 1996) (Interim Final Policy BWSC/ORS-95-141), Bureau of Waste Site Cleanup and Office of Research and StandardsMassachusetts Department of Environmental Protection.

mg/kg = milligrams per kilogram

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Table 2-20Ecological Screening of Terestrial Invertebrates for Surface Soil Exposure

AOC FS-2

Contaminant of Concern

Maximum SoilConcentration

(mg/kg)

InvertebrateBenchmark

(mg/kg)Reference

ExceedsMaximum

Benchmark?

SEMIVOLATILE ORGANIC COMPOUNDSAcenaphthylene 0.19 34 Neuhauser et al. 1985 NoAnthracene 0.14 34 Neuhauser et al. 1985 NoBenzo(a)anthracene 0.76 34 Neuhauser et al. 1985 NoBenzo(a)pyrene 0.6 34 Neuhauser et al. 1985 NoBenzo(b)fluoranthene 0.79 34 Neuhauser et al. 1985 NoBenzo(g,h,i)perylene 0.35 34 Neuhauser et al. 1985 NoBenzo(k)fluoranthene 0.3 34 Neuhauser et al. 1985 NoBis(2-ethylhexyl)phthalate 0.06 630 Neuhauser et al. 1985 NoCarbazole 0.1 NAChrysene 0.81 34 Neuhauser et al. 1985 NoDibenz(a,h)anthracene 0.11 34 Neuhauser et al. 1985 NoDibenzofuran 0.55 NAFluoranthene 1.2 34 Neuhauser et al. 1985 NoIndeno(1,2,3-cd)pyrene 0.51 34 Neuhauser et al. 1985 No2-Methylnaphthylene 1.7 34 Neuhauser et al. 1985 NoNapthalene 0.11 34 Neuhauser et al. 1985 NoPhenanthrene 1.2 34 Neuhauser et al. 1985 NoPyrene 0.93 34 Neuhauser et al. 1985 NoINORGANIC ANALYTESChromium 16 10 Efroymson et al. 1997 YesLead 56 500 Efroymson et al. 1997 NoManganese 144 100 Efroymson et al. 1997 YesMercury 0.12 30 Efroymson et al. 1997 NoSelenium 1.4 70 Efroymson et al. 1997 NoVanadium 10 20 Efroymson et al. 1997 NoZinc 19 130 Neuhauser et al. 1985 No

References: Efroymsen, R.A., M.E. Will, G. W. Suter II, A.C. Wooten. 1997. Toxicological Benchmarks for ScreeningContaminants of Potential Concern for Effects on Soil and Litter Invertebrates and Heterotrophic Process. ES/ER/TM-126/R2. Oak Ridge National Laboratory, Oak Ridge, TN.

Neuhauser, E.F., R.C. Loehr, M.R. Malecki, D.L. Milligan, and Durkin. 1995. The toxicity of selected chemicals to theearthworm Eisenia foetida. Journal of Environ. Qual. 14: 383-388.

mg/kg = milligrams per kilogramNA = not available

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Table 2-21Hazard Index Summary

for Surface Soil ExposureAOC FS-2

Ecological ReceptorNOAEL HIs for

Maximum ExposureConcentrations

LOAEL HIs for Maximum Exposure

Concentraions

White-Footed Mouse 0.642 0.0639Short-Tailed Shrew

Selenium3.261.72

0.333

Upland Sandpiper 1.46 0.145American Robin

ChromiumLead

SeleniumZinc

11.82.942.182.921.97

0.737

Box Turtle 0.0311 0.00308

Notes:Hazard Indexes (HIs) in bold exceed 1; analytes shown are primary risk drivers.LOAEL = lowest observed adverse effect levelNOAEL = no observed adverse effect level

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APPENDIX A

Massachusetts Department of Environmental Protection Concurrence Letter

COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION SOUTHEAST REGIONAL OFFICE20 RIVERSIDE DRIVE, LAKEVILLE, MA 02347

JANE SWIFT BOB DURANDGovernor Secretary

LAUREN A. LISSCommissioner

February 5, 2002

Mr. Robert M. Gill RE: BOURNE-BWSC-4-0037Remediation Program Manager Massachusetts Military Reservation,HQ AFCEE/MMR Final Record of Decision for Area of322 East Inner Road Contamination Fuel Spill-2,Otis ANG Base, Massachusetts 02542 Concurrence

Dear Mr. Gill:

The Department of Environmental Protection (the “Department”) has reviewed thedocument entitled “Final Record of Decision for Area of Contamination Fuel Spill-2”(the “ROD”) dated November 2001. The ROD was prepared by Jacobs Engineering GroupInc. (“JEG”) for the Air Force Center for Environmental Excellence (“AFCEE”).

The FS-2 Area of Concern (AOC) consists of 5.5 acres located near the southern boundary ofthe Massachusetts Military Reservation (MMR) directly south of the MMR golf course. TheFS-2 AOC was used for unloading and distributing jet fuel and aviation gasoline from tankertrucks and railroad tank cars. The unloading facility was taken out of service in 1965.

A draft Remedial Investigation (RI) report was prepared by E.C. Jordan in 1991. The draft RIconcluded a No Further Action alternative was appropriate for groundwater and subsurfacesoils at the FS-2 AOC. However, it was concluded that some of the surface soil at the siteposed human health risks that should be the focus of a feasibility study for FS-2.

In 1993, a Technical memorandum prepared for the FS-2 AOC recommended thatcontaminated surface soil from FS-2 be excavated and the thermally treated with alow-temperature thermal system designed and constructed for the treatment of contaminatedsoil from three other MMR sites (Chemical Spill-4, Fuel Spill-25 and Fire Training Area-1).Approximately 520 tons of soil were excavated from the FS-2 AOC in 1996 and treated at thelow-temperature thermal treatment system.

A Remedial Investigation was performed for the Southwest Operable Unit (SWOU) in 1998and concluded that groundwater from the FS-2 AOC posed no significant risk to humanhealth or the environment. However, the SWOU RI did identify a former maintenance pit thathad not been evaluated in previous investigations at the FS-2 site. A subsequent evaluation ofthe 1991 FS-2

This information is available in alternate form by calling our ADA Coordinator at (617) 574-6872

DEP on the World Wide Web: http://www.mas.gov/dep

Page 2

RI was performed in 1999. This evaluation concluded that enough uncertainty existed towarrant a supplemental RI to confirm the conclusions made in the 1991 RI. The supplementalRI was performed in 2000 and concluded no further assessment or remedial action wasnecessary for site soils.

The Record of Decision (ROD) concludes that any remaining contamination at the FS-2site is at concentrations below those considered to present a human health or ecological riskand that no further action is necessary. The Department concurs with the Record of Decision.

The Department’s concurrence is based upon representations made to the Department bythe AFCEE and assumes all information provided is substantially complete and accurate.Without limitation, if the Department determines that any material omissions ormisstatements exist, if new information becomes available, or if conditions at the Study Areachange, resulting in potential or actual human exposure or threats to the environment, theDepartment reserves its authority under M.G.L. c. 21E, and the Massachusetts ContingencyPlan, 310 CMR 40.0000 et seq., and any other applicable law or regulation to require furtherresponse actions.

Please incorporate this document into the Administrative Record for Fuel Spill-2. If youhave any questions regarding these comments, please contact Leonard Pinaud at (508)946-2871.

Sincerely,

Paul A. Taurasi, P.E.,Regional Director

P/EJ/mw file:fs2frod.doc

Cc: DEP - SERO ATTN: Leonard J. Pinaud, Chief Federal Facilities Remediation Section

Millie Garcia-Surette, Deputy Regional Director

Distributions: SERO SMB Plume Cleanup Team (IRP) Boards of Selectmen Boards of Health

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APPENDIX B

Administrative Record Index

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MASSACHUSETTS MILITARY RESERVATION

Administrative Record File

FS-2

Railroad Fuel Station

1.0 Pre-Remedial

1.2 Preliminary Assessment

98 Phase I Records Search, Otis Air National Guard Base, Massachusetts, Metcalf & Eddy,Inc. (1/1983). Information about potential contamination at FS-1; FS-2; FTA-1; FTA-2;LF-1; LF-2; SD-5 to determine if further information gathering or analysis is necessary.(2 sections, 130 pages).

202 U.S. Air Force Installation Restoration Program, Phase I Records Search, Air NationalGuard, Camp Edwards (ARNG), U. S. Air Force and Veteran’s Administration Facilitiesat Massachusetts Military Reservation, Massachusetts, Task 6-Text, E. C. JordanCompany, Inc. (12/11/1986). Information about potential contamination at MMR todetermine if further information gathering or analysis is necessary. (2 sections, 190pages).

1362 EPA’s comments dated August 16, 1990 on the December 11, 1986 “Final Report, PhaseI Records Search, ANG, Camp Edwards (ARNG), U. S. Air Force and Veteran’sAdministration Facilities at MMR, Task 6” and “Final Report Phase I Records Search”,Marchessault, Paul, U. S. Environmental Protection Agency Region 1 (8/16/1990). (1section, 1 page).

1113 U. S. Air Force Installation Restoration Program, Phase I: Records Search, Air NationalGuard, Camp Edwards, U. S. Air Force and Veteran’s Administration Facilities atMassachusetts Military Reservation, Massachusetts, Task 6 - Appendices, E. C. JordanCompany, Inc. (12/11/1986). Information about potential contamination at MMR todetermine if further information gathering or analysis is necessary. (3 sections, 223pages).

5969 Final Report, Task 7, Phase I: Records Search, U. S. Coast Guard Facilities atMassachusetts Military Reservation, Massachusetts, E. C. Jordan Company, Inc.(12/11/1986). Information about potential contamination at MMR to determine if furtherinformation gathering or analysis is necessary. (2 sections, 201 pages).

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1.3 Site Inspection

107 Final Report for Phase II, Confirmation/Quantification, Stage 1,Volurne I - Text, Roy F.Weston, Inc. (10/1985). Information related to the initial conditions present at the FS-1;FS-10; FS-11; FS-2; FS-5; FTA-1; FTA-2; LF-1; LF-2; PFSA; SD-5. (2 sections, 140pages).

4961 EPA’s comments dated December 19, 1985 on the October 1985 “Final Report for PhaseII, Confirmation/Quantification, Stage 1”, Mollineaux, George A., U. S. EnvironmentalProtection Agency Region 1 (12/19/1985). (1 section, 14 pages).

5079 Response dated June 5, 1986 to EPA’s Comments on the October 1985 “Final Report forPhase II Confirmation/Quantification Stage I”, Roy F. Weston, Inc. (6/5/1986). (1section, 11 pages).

108 Final Report for Phase II, Confirmation/Quantification Stage 1, Volume II - Appendices,Roy F. Weston, Inc. (10/1985). Information related to the initial conditions present at theFS-1; FS-10; FS-11; FS-2; FS-5; FTA-1; FTA-2; LF-1; LF-2; PFSA; SD-5. (3 sections,329 pages).

3139 MADEP’s comments dated April 3, 1986 on the October 1985 “Final Report for PhaseII, Confirmation/Quantification, Stage 1”, D’Amore, Denis, Commonwealth ofMassachusetts Department of Environmental Protection (4/3/1986). Information relatedto the initial conditions present at the FS-1;FS-10;FS-11;FS-2;FS-5; FTA-1;FTA-2;LF-1;LF-2;PFSA;SD-5. (1 section, 2 pages).

5279 Concerning an evaluation of the Phase II Stage 1 status of the former fire-training area,AVGAS test fuel dump site, the non-destructive inspection lab, and the rail yard fuelpumping station; all were recommended for further study, Allen, Raymond A. III, E. C.Jordan Company, Inc. (4/11/1986). Information related to the initial conditions presentat the FS-1; FS-2; FTA-2; LF-2; SD-5. (1 section, 9 pages).

230 Concerning evaluation of the Phase II Stage 1 Status of Former Fire-Training Area,AVGAS Fuel Test Dump Site, Non-Destructive Inspection Laboratory and the RailyardFuel Pumping Station, Allen, Raymond A. III; Tewhey, John D., E. C. Jordan Company,Inc. (6/3/1986).

Information related to the initial conditions present at the FS-1; FS-2; FTA-2; LF-2;SD-5. (1 section, 9 pages).

90 Final Site Inspection Report, Field Investigation Work Conducted Spring-Summer 1988,Task 2-3B, Volume I - Text, E. C. Jordan Company, Inc. (2/1990). Information relatedto the initial conditions present at the AV; CS-10; CS-13; CS-16; CS-17; CS-3; CS-4;FS-1; FS-2; FS-23; FS-3; FTA-1; FTA-2; LF-1; SD-1; SD-2; SD-5. (3 sections, 241pages).

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147 Final Site Inspection Report, Field Investigation Work Conducted Spring-Summer 1988,Task 2-3B, Volume II - Appendices, E. C. Jordan Company, Inc. (2/1990). Informationrelated to the initial conditions present at the AV; CS-10; CS-13; CS-16; CS-17; CS-3;CS-4; FS-1; FS-2; FS-23; FS-3; FTA-1; FTA-2; LF-1; SD-1; SD-

2;SD-5. (10 sections, 862 pages).

5260 EPA’s comments dated November 5, 1990 on the February 1990 “Final Site InspectionReport, Field Investigation Work Conducted Spring-Summer 1988, Task 2-3B, VolumesI and II”, Marchessault, Paul, U. S. Environmental Protection Agency Region 1(11/5/1990). and the March 1990 “Final Remedial Investigation Field Sampling andAnalysis Plan-Remaining Priority I Sites, Task 2-5B. (1 section, 1 page).

2.0 Removal Response

2.9 Action Memoranda

6728 Technical Memorandum, Recommendation for AOC FS-2 Surface Soil Treatment, ABBEnvironmental Services, Inc. (12/21/1993). Documentation of EE/CA process forselected removal action at source area. (1 section, 5 pages).

3.0 Remedial Investigation (RI)

3.2 Sampling and Analysis Data

2893 Final Technical Memorandum, MW-1202 Groundwater Study, E. C. Jordan Company,Inc. (4/1990). Results of sampling and laboratory analysis for samples collected fromFS-2 and a record of handling samples. (1 section, 21 pages).

165 Final Remedial Investigation Field Sampling and Analysis Plan, Six Priority 1 Sites,Task 2-5, C-E Environmental, Inc. (6/1990). Results of sampling and laboratory analysisfor samples collected from CS-10; FS-1; FS-10; FS-11; FS-2; FTA-1; LF-1; PFSA; SD-2and a record of handling samples. (2 sections, 135 pages).

2627 EPA’s comments dated October 15, 1990 on the June 1990 “Final RemedialInvestigation Field Sampling and Analysis Plan, Six Priority I Sites, Task 2-5”,Marchessault, Paul, U. S. Environmental Protection Agency Region 1 (10/15/1990).

Results of sampling and laboratory analysis for samples collected from CS-10; FS-1;FS-10; FS-11; FS-2; FTA-1; LF-1; PFSA; SD-2 and a record of handling samples. (1section, 1 page).

5036 Comments (date unknown) on the June 1990 “Final Remedial Investigation FieldSampling and Analysis Plan, Priority 1 Sites, Task 2-5”, Hazardous Waste Remedial

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Actions Program (2/18/1993). Results of sampling and laboratory analysis for samplescollected from CS-10; FS-1; FS-10; FS-11; FS-2; FTA-1; LF-1; PFSA; SD-2 and arecord of handling samples. (I section, 5 pages).

166 Final Field Sampling and Analysis Plan, MW-1202 Groundwater Study, E. C. JordanCompany, Inc. (6/1990). Results of sampling and laboratory analysis for samplescollected from FS-2 and a record of handling samples. (1 section, 25 pages).

2622 EPA’s comments dated September 18, 1990 on the June 1990 “Final Field Sampling andAnalysis Plan, MW-1202 Groundwater Study”, Marchessault, Paul, U. S. EnvironmentalProtection Agency Region 1 (9/18/1990). Results of sampling and laboratory analysis forsamples collected from FS-2 and a record of handling samples. (1 section, 1 page).

1040 1,2-Dibromoethane Study Sampling and Analysis Plan, ABB Environmental Services,Inc. (4/1992). Results of sampling and laboratory analysis for samples collected fromFS-1; FS-12; FS-2; FTA-1; FTA-2; LF-2; MMR; PFSA; SD-5; SERGOU and a recordof handling samples. (1 section, 37 pages).

6624 Ethylene Dibromide (EDB) Data Deliverable: 1992 Groundwater Sampling Results,ABB Environmental Services, Inc. (5/1995). Results of sampling and laboratory analysisfor samples collected from FS-12; FS-2; FTA-1; FTA-2; LF-2; MMR; PFSA; SD-5;SERGOU and a record of handling samples. (2 sections, 145 pages).

3.6 Remedial Investigation (RI) Reports

1120 Comments dated October 8, 1991 on the February 1991 “Draft Remedial InvestigationReport, Railroad Fuel Pumping Station (FS-2 Study Area)”, Marchessault, Paul, U. S.Environmental Protection Agency Region 1 (10/8/1991). Describes data and analysis andthe nature and extent of contamination at FS-2. Also presents the risk assessment andinformation to determine the necessity for further action, and identifies technologies andalternatives for cleanup. (1 section, 8 pages).

2658 Comments dated October 8, 1991 on the February 1991 “Draft Remedial InvestigationReport, Railroad Fuel Pumping Station (FS-2 Study Area)”, Hinkle, Gary L., NationalGuard Bureau (10/8/1991). Describes data and analysis and the nature and extent ofcontamination at FS-2. Also presents the risk assessment and information to determinethe necessity for further action, and identifies technologies and alternatives for cleanup.(1 section, 2 pages).

2862 MADEP’s comments dated October 10, 1991 on the February 1991 “RemedialInvestigation Report, Railroad Fuel Pumping Station (FS-2)” and the April 1991“Focused Feasibility Study, AVGAS Fuel Valve Test Dump Site (FS-1)”, Donovan,Robert E., Commonwealth of Massachusetts Department of Environmental Protection(10/10/1991). Describes data and analysis and the nature and extent of contamination atFS-1;FS-2. Also presents the risk assessment and information to

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determine the necessity for further action, and identifies technologies and alternatives forcleanup. (1 section, 4 pages).

2352 Response dated January 30, 1992 to EPA/MADEP Comments of October 1991 on theFebruary 1991 “Draft Remedial Investigation Report, Railroad Fuel Pumping Station(FS-2 Study Area)”, Allen, Douglas C., ABB Environmental Services, Inc. (1/30/1992).Describes data and analysis and the nature and extent of contamination at FS-2. Alsopresents the risk assessment and information to determine the necessity for further action,and identifies technologies and alternatives for cleanup. (1 section, 43 pages).

1117 Response dated March 18, 1992 to NGB’s Response to EPA’s Comments on theFebruary 1991 “Draft Remedial Investigation Report, Railroad Fuel Pumping Station(FS-2) Study Area”, Marchessault, Paul, U. S. Environmental Protection Agency Region1 (3/18/1992). Describes data and analysis and the nature and extent of contaminationat FS-2. Also presents the risk assessment and information to determine the necessity forfurther action, and identifies technologies and alternatives for cleanup. (1 section, 3pages).

3.7 Work Plans and Progress Reports

157 Phase II/IVA, Task 2-3, Remedial Investigation/Feasibility Study Work Plan, E. C.Jordan Company, Inc. (6/1987). Describes the scope of activities and approach for theRemedial Investigation. (2 sections, 156 pages).

4.0 Feasibility Study (FS)

4.1 Correspondence

13914 NGB letter dated 5/11/1992 regarding the FS-2 Feasibility Study., Santos Daniel W., IRPOffice MMR (5/11/1992). NGB will withhold comment on the above referenceddocument until resolution of the additional work required to satisfy EPA’s comments onthe Remedial Investigation. (1 section, 1 page).

9.0 State Coordination

9.1 Correspondence

280 The DEQE has determined that FS-2 is a priority disposal site, pursuant to the InterimSite Classification requirements in the Massachusetts Contingency Plan, 310 CMR40.544., Monte, Gerald A., Commonwealth of Massachusetts Department ofEnvironmental Quality Engineering (12/21/1988). Letters, memos or othercommunications on intra-agency and interagency coordinator for FS-2. (1 section, 2pages).

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13.0 Community Relations

13.1 Correspondence

4352 Concerning the Town of Falmouth request that the rail yard fuel pumping station betested as originally planned., Valiela, Virginia, Town of Falmouth Department of PublicWorks (9/30/1983). Letters, memos or other communications on public participation inFS-2. (1 section, 2 pages).

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MASSACHUSETTS MILITARY RESERVATION

Administrative Record File

FS-2

Railroad Fuel Station

2.0 Removal Response

2.5 Action Memorandum

11505 NGB-ARE’s comments dated July 10, 1998 on the June 1998 “Draft Soil ThermalTreatment Program, Remedial Action Summary Report”, Lumeh, Larry, National GuardBureau-Army (7/10/1998). (1 section, 3 pages).

11506 MADEP’s comments dated July 16, 1998 on the June 1998 “Draft Soil ThermalTreatment Program,Remedial Action Summary Report”, Pinaud, Leonard J.,Commonwealth of Massachusetts Department of Environmental Protection (7/16/1998).(1 section, 3 pages).

12189 AFCEE’s responses dated May 7, 1999 on NGB-ARE’s comments on the June 1998“Draft Soil Thermal Treatment Program,Remedial Action Summary Report”, Snyder,Jim F., IRP Office MMR (5/7/1999). (1 section, 4 pages).

12188 NGB-ARE’s comments dated May 19, 1999 on the June 1998 “Draft Soil ThermalTreatment Program,Remedial Action Summary Report” on the February 1999 “DraftFinal Record of Decision, Areas of Contamination CS-10/FS-24 Source Areas”, Watson,JoAnn S., National Guard Bureau-Army (5/19/1999). (1 section, 3 pages).

12439 EPA’s comments dated August 19, 1999 on the June 1998 “Draft Soil ThermalTreatment Program,Remedial Action Summary Report”, Marchessault, Paul, U. S.Environmental Protection Agency Region 1 (8/19/1999). (1 section, 2 pages).

12485 Final Soil Thermal Treatment Program,Remedial Action Summary Report, HardingLawson Associates (9/1999). Documentation of EE/CA process for selected removalaction at source area. (4 sections, 337 pages).

12458 AFCEE’s responses dated September 14, 1999 on NGB-ARE’s comments on the June1998 “Draft Soil Thermal Treatment Program,Remedial Action Summary Report”,Snyder, Jim F., IRP Office MMR (9/14/1999). (1 section, 4 pages).

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3.0 Remedial Investigation

3.3 Work Plan

12925 Final Fuel Spill-2 (FS-2) Streamlined Remedial Investigation Work Plan, JacobsEngineering Group, Inc. (4/2000). Describes the scope of activities and approach for theRemedial Investigation. (1 section, 69 pages).

13911 Memorandum of Resolution #2 dated 4/12/2000 on the March 2000 “Draft Fuel Spill-2(FS-2) Streamlined Remedial Investigation Work Plan”, Snyder Jim F., IRP Office MMR(4/1/2000). (1 section, 4 pages).

12921 Memorandum of Resolution dated 4/10/2000 on the March 2000 “Draft Fuel Spill-2(FS-2) Streamlined Remedial Investigation Work Plan”, Snyder, Jim F., IRP OfficeMMR (4/10/2000). Describes the scope of activities and approach for the RemedialInvestigation. (1 section, 16 pages).

12922 MADEP’s comments dated 4/13/2000 on the 4/10/2000 Memorandum of Resolution onthe March 2000 “Draft Fuel Spill-2 (FS-2) Streamlined Remedial Investigation WorkPlan”, Pinaud, Leonard J., Commonwealth of Massachusetts Department ofEnvironmental Protection (4/13/2000). MADEP concurs with the resolutions. (1 section,3 pages).

12923 EPA’s comments dated 4/13/2000 on the 4/10/2000 Memorandum of Resolution on theMarch 2000 “Draft Fuel Spill-2 (FS-2) Streamlined Remedial Investigation Work Plan”,Marchessault, Paul, U. S. Environmental Protection Agency Region 1 (4/13/2000). EPAconcurs with the MOR. (1 section, 2 pages).

3.4 Remedial Investigation (RI) Reports

10199 Qualitative Correlation FS-2 to FS-1, Lockheed Martin Energy Systems (10/1996).Describes data and analysis and the nature and extent of contamination at FS-2 and FS-1.Also presents the risk assessment and information to determine the necessity for furtheraction, and identifies technologies and alternatives for cleanup. (1 section, 30 pages).

10200 AFCEE’s comments dated January 8, 1997 on the October 1996 “Qualitative CorrelationFS-2 to FS-1", Snyder, Jim F., IRP Office MMR (1/8/1997). Describes data and analysisand the nature and extent of contamination at FS-1;FS-2. Also presents the riskassessment and information to determine the necessity for further action, and identifiestechnologies and alternatives for cleanup. (1 section, 1 page).

10201 MADEP’s comments dated January 22, 1997 on the October 1996 “QualitativeCorrelation FS-2 to FS-1", Pinaud, Leonard J., Commonwealth of MassachusettsDepartment of Environmental Protection (1/22/1997). Describes data and analysis andthe nature and extent of contamination at FS-1;FS-2. Also presents the risk assessmentand information to determine the necessity for further action, and identifies technologiesand alternatives for cleanup. (1 section, 3 pages).

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10202 EPA’s comments dated March 25, 1997 on the October 1996 “Qualitative CorrelationFS-2 to FS-1", Marchessault, Paul, U. S. Environmental Protection Agency Region 1(3/25/1997). Describes data and analysis and the nature and extent of contamination atFS-1;FS-2. Also presents the risk assessment and information to determine the necessityfor further action, and identifies technologies and alternatives for cleanup. (1 section, 2pages).

13615 EPA’s comments dated 1/12/2000 on the October 2000 “Draft Fuel Spill-2 (FS-2)Supplemental Remedial Investigation Report”, Marchessault Paul, U. S. EnvironmentalProtection Agency Region 1 (1/12/2000). EPA concurs with the MOR. (1 section, 2pages).

13490 EPA’s comments dated 10/30/2000 on the October 2000 “Draft Fuel Spill-2 SupplementalRemedial Investigation Report”, Marchessault Paul, U. S. Environmental ProtectionAgency Region 1 (10/30/2000). (1 section, 8 pages).

13491 MADEP’s comments dated 11/7/2000 on the October 2000 “Draft Fuel Spill-2Supplemental Remedial Investigation Report”, Pinaud Leonard J., Commonwealth ofMassachusetts Department of Environmental Protection (11/7/2000). (1 section, 5 pages).

13492 AFCEE’s responses dated 12/1/2000 to EPA and MADEP’s comments for the October2000 “Draft Fuel Spill-2 Supplemental Remedial Investigation Report”, Gill Robert M.,IRP Office MMR (12/1/2000). (2 sections, 116 pages).

13611 Memorandum of Resolution dated 12/27/2000 on the February 1991 “RemedialInvestigation Report, Rail Road Fuel Pumping Station FS-2 Study Area”, Gill Robert M.,IRP Office MMR (12/27/2000). (1 section, 12 pages).

13614 MADEP’s comments dated 12/28/2000 on the October 2000 “Draft Fuel Spill-2 (FS-2)Supplemental Remedial Investigation Report”, Pinaud Leonard J., Commonwealth ofMassachusetts Department of Environmental Protection (12/28/2000). MADEP concurswith the responses. (1 section, 2 pages).

13612 EPA’s comments dated 12/29/2000 on the MOR for the February 1991 “RemedialInvestigation Report, Rail Road Fuel Pumping Station FS-2 Study Area”, MarchessaultPaul, U. S. Environmental Protection Agency Region 1 (12/29/2000). (1 section, 2 pages).

13617 Memorandum of Resolution dated 12/29/2000 on the October 2000 “Draft Fuel Spill-2(FS-2) Supplemental Remedial Investigation Report”, Gill Robert M., IRP Office MMR(12/29/2000). (1 section, 24 pages).

13618 Final Fuel Spill-2 Supplemental Remedial Investigation Report”, Jacobs EngineeringGroup, Inc. (1/2001). Describes data and analysis and the nature and extent ofcontamination at FS-2. Also presents the risk assessment and information to determine thenecessity for further action, and identifies technologies and alternatives for cleanup. (11sections, 557 pages).

13613 MADEP’s comments dated 1/2/2001 on the MOR for the February 1991 “RemedialInvestigation Report, Rail Road Fuel Pumping Station FS-2 Study Area”, Pinaud LeonardJ.,

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Commonwealth of Massachusetts Department of Environmental Protection (1/2/2001).(1 section, 3 pages).

13619 AFCEE letter dated 2/2/2001 enclosing a copy of the January 2001 “Final Fuel Spill-2(FS-2) Supplemental Remedial Investigation Report”., Gill Robert M., IRP Office MMR(2/2/2001). (1 section, 4 pages).

3.6 Quality Assurance Project Plan (QAPP)

13096 AFCEE-Brooks Air Force Base comments dated August 14, 1996 on the July 1996“Draft Quality Program Plan”, Brooks Air Force Base (8/14/1996). (1 section, 6 pages).

13094 EPA’s comments dated August 15, 1996 on the July 1996 “Draft Quality Program Plan”,Marchessault, Paul, U. S. Environmental Protection Agency Region 1 (8/15/1996). (1section, 16 pages).

13098 MADEP’s comments dated August 15, 1996 on the July 1996 “Draft Quality ProgramPlan”, Papadopoulos, Andrea, Commonwealth of Massachusetts Department ofEnvironmental Protection (8/15/1996). (1 section, 6 pages).

13095 AFCEE-ERC’s comments dated August 16, 1996 on the July 1996 “Draft QualityProgram Plan”, Air Force Center for Environmental Excellence, Consultant OperationsDivision (8/16/1996). (1 section, 5 pages).

13097 AFCEE’s comments dated August 16, 1996 on the July 1996 “Draft Quality ProgramPlan”, Hoda, Bud, IRP Office MMR (8/16/1996). (1 section, 2 pages).

10514 Final Quality Program Plan, Jacobs Engineering Group, Inc. (9/1996) Presents theorganization, objectives, activities, and quality assurance and quality control activitiesto achieve data quality objectives for the investigation at S or P. (5 sections, 422 pages).

10515 Final Quality Program Plan, Appendix A - Health and Safety Plan, Jacobs EngineeringGroup, Inc. (9/1996). Describes the scope and approach to collect additional data to aidin design of remedy of MMR. (4 sections, 396 pages).

10516 Final Quality Program Plan, Appendix B - Standard Operating Procedures, JacobsEngineering Group, Inc. (9/1996). Describes the scope and approach to collect additionaldata to aid in design of remedy of MMR. (4 sections, 387 pages).

10517 Final Quality Program Plan Appendix C, D, Jacobs Engineering Group, Inc. (9/1996).Presents the organization, objectives, activities, and quality assurance and quality controlactivities to achieve data quality objectives for the investigation at S or P. (4 sections,244 pages).

10518 AFCEE’s responses dated September 6, 1996 to EPA’s comments on the August 1996“Draft Quality Program Plan”, Snyder, Jim F., IRP Office MMR (9/6/1996). (1 section,6 pages).

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10519 AFCEE’s responses dated September 6, 1996 to MADEP’s comments on the July 1996“Draft Quality Program Plan”, Snyder, Jim F., IRP Office MMR (9/6/1996). (1 section,12 pages).

10520 AFCEE’s responses dated September 6, 1996 to AFCEE/ERC’s comments on the August1996 “Draft Quality Program Plan”, Snyder, Jim F., IRP Office MMR (9/6/1996). (1section, 6 pages).

10521 AFCEE’s responses dated September 6, 1996 to AFCEE/ERC’s comments on the July1996 “Draft Quality Program Plan”, Snyder, Jim F., IRP Office MMR (9/6/1996). (1section, 3 pages).

13099 AFCEE’s responses dated September 6, 1996 to EPA’s comments on the July 1996“Draft Quality Program Plan”, Snyder, Jim F., IRP Office MMR (9/6/1996). (1 section,6 pages).

13100 AFCEE’s responses dated September 6, 1996 to Booz, Allen and Hamilton, Inc.’scomments on the July 1996 “Draft Quality Program Plan”, Snyder, Jim F., IRP OfficeMMR (9/6/1996). (1 section, 6 pages).

10522 Memorandum of Resolution dated September 17, 1996 on the July 1996 “Draft QualityProgram Plan”, Snyder, Jim F., IRP Office MMR (9/17/1996). (1 section, 5 pages).

10523 Memorandum of Resolution dated September 18, 1996 on the July 1996 “Draft QualityProgram Plan”, Snyder, Jim F., IRP Office MMR (9/18/1996). (1 section, 4 pages).

10524 EPA’s comments dated October 8, 1996 on the Memorandum of Resolution datedSeptember 18, 1996 to the July 1996 “Draft Quality Program Plan”, Marchessault, Paul,U. S. Environmental Protection Agency Region 1 (10/8/1996). (1 section, 2 pages).

10526 AFCEE (Booz-Allen & Hamilton, Inc) comments dated October 15, 1996 on the July1996 “Draft Quality Program Plan”, Hrabovsky, Sharon, Booz Allen & Hamilton Inc.(10/15/1996). (1 section, 3 pages).

10525 AFCEE’s response dated October 17, 1996 to MADEP comments on the July 1996“Draft Quality Program Plan”, Snyder, Jim F., IRP Office MMR (10/17/1996). (1section, 2 pages).

10527 MADEP’s comments dated October 17, 1996 on the July 1996 “Draft Quality ProgramPlan”, Pinaud, Leonard J., Commonwealth of Massachusetts Department ofEnvironmental Protection (10/17/1996). (1 section, 3 pages).

10528 Memorandum of Resolution dated October 22, 1996 on the July 1996 “Draft QualityProgram Plan”, Snyder, Jim F., IRP Office MMR (10/22/1996). (1 section, 2 pages).

11203 Quality Program Plan - Section 1, Jacobs Engineering Group, Inc. (1/1998). Describesthe scope and approach to collect additional data to aid in design of remedy of MMR. (20sections, 1849 pages).

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13718 Letter dated 10/28/1999 regarding Revisions to the Quality Program Plan andIntroduction to the Region I EPA New England Compendium of Quality AssuranceProject Plan Requirements and Guidance, Marchessault Paul, U. S. EnvironmentalProtection Agency Region 1 (10/28/1999). (1 section, 4 pages).

13719 Letter dated 4/7/2000 enclosing a copy of the Draft Quality Program Plan (QPP)Addendum/Health and Safety Plan (HSP) Addendum., Banks Eric W., JacobsEngineering Group, Inc. (4/7/2000). Presents the organization, objectives, activities, andquality assurance and quality control activities to achieve data quality objectives for theinvestigation at S or P. (1 section, 15 pages).

13171 Quality Program Plan (QPP) Volume I of II, Jacobs Engineering Group, Inc. (9/2000).Presents the organization, objectives, activities, and quality assurance and quality controlactivities to achieve data quality objectives for the investigation at MMR. (9 sections,783 pages).

13172 Quality Program Plan (QPP) Volume II of II, Jacobs Engineering Group, Inc. (9/2000).Presents the organization, objectives, activities, and quality assurance and quality controlactivities to achieve data quality objectives for the investigation at MMR. (18 sections,1283 pages).

13912 EPA’s comments dated 10/4/2000 on the September 2000 “Quality Program PlanUpdate”, Marchessault Paul, U. S. Environmental Protection Agency Region I(10/4/2000). (1 section, 5 pages).

13913 AFCEE’s responses dated 11/29/2000 on EPA’s comments for the September 2000“Quality Program Plan Update”, Gill Robert M., IRP Office MMR (11/29/2000). (1section, 9 pages).

13720 EPA’s comments dated 12/12/2000 on the September 2000 “Quality Program Plan (QPP)Update 2000", Marchessault Paul, U. S. Environmental Protection Agency Region 1(12/12/2000). EPA concurs with the responses. (1 section, 2 pages).

13721 Quality Program Plan (QPP) Quarterly Update January 2001, Banks Eric W., JacobsEngineering Group, Inc. (1/19/2001). Presents the organization, objectives, activities, andquality assurance and quality control activities to achieve data quality objectives for theinvestigation at MMR. (4 sections, 232 pages).

13722 EPA’s comments dated 1/30/2001 on the January 2001 “Quality Program Plan (QPP)Quarterly Update January 2001", Marchessault Paul, U. S. Environmental ProtectionAgency Region 1 (1/30/2001). (1 section, 2 pages).

3.8 Correspondence

13101 AFCEE’s letter dated February 6, 1998 advising that the “Quality Program Plan” thatwas issued as a Final in September 1996, has been updated, Snyder, Jim F., IRP OfficeMMR (2/6/1998). (1 section, 4 pages).

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13915 Letter dated 2/18/1999 regarding site conditions at the Railroad Fuel Pumping Station(FS-2 Study Area), Marchessault Paul, U. S. Environmental Protection Agency Region1 (2/18/1999). (1 section, 2 pages).

13916 AFCEE letter dated 3/2/1999 recommending that the FS-2 Study Area remaining withinSWOU and follow the Remedial Investigation Feasibility Study path to the Record ofDecision outlined for other SWOU sites., Snyder Jim F., IRP Office MMR (3/2/1999).(1 section, 2 pages).

12218 EPA proposes that AFCEE revise and resubmit the Draft FS-2 Remedial Investigationreport by incorporation of all information from both the soil removal and groundwaterrisk assessment from the SWOU RI Report., Marchessault, Paul, U. S. EnvironmentalProtection Agency Region 1 (6/17/1999). (1 section, 2 pages).

12924 Letter enclosing a copy of the Record of Environmental Consideration prepared for FS-2Streamlined Remedial Investigation., Banks, Eric W., Jacobs Engineering Group, Inc.(5/4/2000). (1 section, 8 pages).

13254 Memorandum dated 5/16/2000 regarding the October 1996 “Qualitative Correlation FS-2to FS-1", Connolly Beverly, IRP Office MMR (5/16/2000). Comments and responses tocomments on the above report will be included as part of the FS-2 RemedialInvestigation. (1 section, 1 page).

13957 Letter dated 3/27/2001 enclosing a copy of the Quality Program Plan (QPP) QuarterlyUpdate-March 2001., Banks Eric W., Jacobs Engineering Group, Inc. (3/27/2001).(1section, 28 pages).

4.0 Feasibility Study (FS)

4.3 Proposed Plan

13898 EPA’s comments dated 3/15/2001 on the May 2001 “Draft Proposed Plan for No FurtherAction for Soils and Groundwater at the FS-2 Site", Marchessault Paul, U. S.Environmental Protection Agency Region 1 (3/15/2001). (1 section, 6 pages).

13894 AFCEE’s responses dated 3/27/2001 to EPA and MADEP’s comments for the February2001 “Draft Proposed Plan for No Further Action for Soils and Groundwater at the FS-2Site”, Gill Robert M., IRP Office MMR (3/27/2001). (1 section, 11 pages).

13895 Memorandum of Resolution dated 3/30/2001 on the February 2001 “Draft Proposed Planfor No Further Action for Soils and Groundwater at the FS-2 Site”, Gill Robert M., IRPOffice MMR (3/30/2001). (1 section, 5 pages).

13896 EPA’s comments dated 3/30/2001 on the MOR for the February 2001 “Draft ProposedPlan for No Further Action for Soils and Groundwater at the FS-2 Site”, MarchessaultPaul, U. S. Environmental Protection Agency Region 1 (3/30/2001). (1 section, 2 pages).

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13897 MADEP’s comments dated 4/3/2001 on the MOR for the February 2001 “Draft ProposedPlan for No Further Action for Soils and Groundwater at the FS-2 Site”, Pinaud LeonardJ., Commonwealth of Massachusetts Department of Environmental Protection(4/3/2001). MADEP concurs with the MOR. (1 section, 3 pages).

13992 Proposed Plan for No Further Action for Soil and Groundwater at the Fuel Spill-2 (FS-2)Site, Air Force Center for Environmental Excellence, Massachusetts Military Reservation(5/2001).

Fact sheet that briefly presents analysis of cleanup options identifies the option preferredby the lead agency and the rationale for that preference at FS-2. (1 section, 12 pages).

4.5 Correspondence

14022 AFCEE letter dated 5/1/2001 enclosing a copy of the April 2001 “Final Proposed Planfor No Further Action for Soil and Groundwater at the Fuel Spill-2 (FS-2) Site”, GillRobert M., IRP Office MMR (5/1/2001). (1 section, 4 pages).

8.0 Health Assessments

8.4 Reports

13255 Fuel Spill-2 (FS-2) Exposure Assessment Memorandum and Terrestrial Food WebModel, Jacobs Engineering Group, Inc. (8/2000). Health Assessment Reports for FS-2.(1 section, 38 pages).

13.0 Remedial Design

13.2 Access Documents

10389 Analytical Data on FTA-1 and FS-2 soil to be processed through the Onsite AsphaltBatching Facility, Pesce, Edward L., IRP Office MMR (7/23/1996). Information onobtaining access to property to investigate or cleanup contamination at FS-2;FTA-1. (1section, 24 pages).

I:\35Z0103 - FS-2\ROD\Final ROD\Final ROD Combined.docA3P-J23-35Z01302-M26-000411/12/01

APPENDIX C

Transcript of Public Hearing

MARY E. PHILLIPS

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MMR INSTALLATION RESTORATION PROGRAM

----------------------------xIn Re: :

::

Fuel Spill 2 Site ::

----------------------------x

Otis Golf Course (on MMR) Guenther Road Thursday, June 7, 2001 7:07 p.m.

Mary E. Phillips, RPR M&M Phillips Enterprises, Inc.

P.O. Box 160, Sagamore Beach, MA 02562508.888.6717

MARY E. PHILLIPS

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A T T E N D E E S

Douglas Karson AFCEE/MMR

Marty Aker AFCEE/MMR

Ellie Grillo

Robert Lim

Lauren Gossther

James Murphy

LTC Bleakley

Robert Gill

Jennifer Coutinho

David Dow

Evan Reavie

Pam Harting-Barrat

MARY E. PHILLIPS

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P R O C E E D I N G S

THE HEARING OFFICER: I’d like to call this

hearing to order. We’re now starting the public

hearing and the official record is now open.

My name is Douglas Karson. And I am the

Hearing Officer for this evening. I would ask at

this time if anyone wishes to offer oral testimony on

the Proposed Plan for no further action for soil and

groundwater at the fuel spill two site.

I would ask again, does anyone here wish to

offer oral testimony on the Proposed Plan for no

further action for soil and groundwater at the fuel

spill two site.

Since no one wishes to offer oral

testimony, I shall now close the official record and

I thank you all for coming and just a reminder that

you still have until June 14 to submit written

comments. Thank you.

(Whereupon the hearing concluded

at 7:08 p.m.)

MARY E. PHILLIPS

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C E R T I F I C A T E

I, MARY E. PHILLIPS, Registered Professional

Reporter, do hereby certify that the foregoing transcript,

pages 2 through 4 inclusive, was taken by me

stenographically and thereafter under my direction was

reduced to typewriting and is a true record of the testimony

of the proceedings to the best of my ability.

Dated at Bourne, Massachusetts, this 11th

day of July, 2001.

I:\35Z01302 - FS-2\ROD\Final ROD\Final ROD Combined.docA3P-J23-35Z01302-M26-000411/12/01

APPENDIX D

Summary of Data from E.C. Jordan Site Investigation Report,1990-1991

I:\35Z01302 - FS-2\ROD\Draft\Appendices\App D EC Jordan 90-91.xls 3-1 SI Organics Page 1 of 17/24/2001

Appendix D-1Soil Analytical Data - Organic CompoundsE.C. Jordan Final Site Investigation Report

February 1990

Designation Depth (ft bgs) Sample Area Result (mg/kg) S-1/GW-1 Standard (mg/kg)

Test Pit 1 0 - 2 French Drain 1 SVOC ND

Test Pit 2 0 - 2 French Drain 2 SVOC ND

Test Boring 1 0 - 2 Adjacent to SVOC (total) 0.196 j(32MW0001) Former Fuel Dieldrin 0.025 0.03

Pump House

29 - 31 SVOC (total) 0.049

59 - 61 SVOC (total) 0.056 jDieldrin 0.0012 0.03

Test Boring 2 0 - 2 West of the SVOC (total) 1.31(32MW0002) Former Fuel

34 - 36 Header Pipes, SVOC (total) ND

59 - 61Adjacent to CentralRail Line SVOC (total) 0.072

Test Boring 3 0 - 2 East of Former SVOC (total) 868(32MW0003) Fuel Pump House,

64 - 66 South of Former SVOC (total) NDHeader Pipes

69 - 71 SVOC (total) ND

Test Boring 4 0 - 2 Northeast Area of SVOC (total) 1.2(32MW0004) Site, Adjacent to

19 - 21 Current Rail Line SVOC (total) ND

64 - 66 SVOC (total) 0.051 j

ft bgs - feet below ground surfacej - estimated concentration mg/kg - milligrams per kilogram ND - not detected SVOC - semivolatile organic compounds

I:\35Z01302 - FS-2\ROD\Draft\Appendices\App D EC Jordan 90-91.xls 3-2 SI Metals Page 1 of 17/24/2001

Appendix D-2Soil Analytical Data - Metals

E.C. Jordan Final Site Investigation ReportFebruary 1990

Designation Depth Sample Area Result (mg/kg) S-1/GW-1 Standard (mg/kg)

Test Pit 1 0 - 2 French Drain 1 ND

Test Pit 2 0 - 2 French Drain 2 Aluminum 6,930Arsenic 2.2Chromium 6.9

No Standard30

1,000Test Boring 1(32MW0001)

0 - 2

59-61

Adjacent toFormer FuelPump House

Aluminum 9,650Chromium 11Lead 59

ND

No Standard1,000300

Test Boring 2 0 - 2 Western End of Aluminum 3,510 No Standard(32MW0002) Former Fuel Arsenic 2.6 30

Header Pipes Chromium 2.4 1,000(JP-4 Section) Iron 11,900 No Standard

Lead 1.9 300

59-61 NDTest Boring 3 0 - 2 East of Former Aluminum 4,220 No Standard(32MW0003) Fuel Pump House, Chromium 3.6 1,000

South of Former Lead 5.8 300

64 - 66Header Pipes(AVGAS Section) ND

Test Boring 4 0 - 2 Northeast Area of Aluminum 3,530 No Standard(32MW0004) Site, Adjacent to Chromium 3.5 1,000

Current Rail Line Lead 7 30019 - 21 Mercury 0.059 20

mg/kg - milligrams per kilogramND - not detected

I:\35Z01302 - FS-2\ROD\Draft\Appendices\App D EC Jordan 90-91.xls 3-3 SI Surface Organics Page 1 of 17\24\2001

Appendix D-3Surface Soil Analytical Data - Organic CompoundsE.C. Jordan Draft Remedial Investigation Report

February 1991

Sample Location Depth Result (mg/kg) S-1/GW-1 Standard (mg/kg)

SS-1 Surface TPH NDSVOCphenanthrene 21 700fluoranthene 51 1,000pyrene 47 700benzo(a)anthracene 20 0.7chrysene 21 7benzo(b)fluoranthene 19j 0.7benzo(k)fluoranthene 16j 7benzo(a)pyrene 16j 0.7indeno(1,2,3-cd)pyrene 12j 0.7benzo(g,h,i)perylene 10 j 1,000

SS-2 Surface TPH NDSVOC ND

SS-3 Surface TPH NDSVOC ND

SS-4 Surface TPH NDSVOC ND

SS-5 Surface TPH NASVOC ND

SS-6 Surface TPH NASVOC ND

SS-7 SurfaceAdjacent to FormerPump House

VOC NDSVOCphenanthrene 1.6 700anthracene 0.38 1,000fluoranthene 1.8 1,000pyrene 1.4 700benzo(a)anthracene 0.76 0.7chrysene 0.67 7benzo(b)fluoranthene 0.69 0.7benzo(k)fluoranthene 0.71 7benzo(a)pyrene 0.57 0.7indeno(1,2,3-cd)pyrene 0.39 0.7

SS-8 SurfaceAdjacent to FormerPump House

VOC NDSVOCacenaphthene 0.41 20fluorene 0.39 400phenanthrene 4.2 700anthracene 0.85 1,000fluoranthene 5.22 1,000pyrene 4.2 700benzo(a)anthracene 2.1 0.7chrysene 2 7benzo(b)fluoranthene 2.2 0.7benzo(k)fluoranthene 2.5 7benzo(a)pyrene 1.9 0.7indeno(1,2,3-cd)pyrene 1.1 0.7benzo(g,h,i)perylene 0.81 1,000

Samples SS-1 through SS-6 were collected from the vicinity of MW-3.j - estimated concentrationmg/kg - milligrams per kilogramNA - not analyzedND - not detectedSVOC - semivolatile organic compoundTPH - total petroleum hydrocarbonsVOC - volatile organic compound

I:\35Z01302 - FS-2\ROD\Draft\Appendices\App D EC Jordan 90-91.xls 3-4 RI Test Boring Organics Page 1 of 17/24/2001

Appendix D-4Test Boring Soil Analytical Data - Organic Compounds

E.C. Jordan Draft Remedial Investigation ReportFebruary 1991

Designation Depth (ft bgs) Sample Area Result (mg/kg) S-1/GW-1 Standard (mg/kg)

32MW1304 32 - 34 South of TPH ND

60 - 62

Golf CourseMaintenance Shed

VOC NDSVOC NDTIC ND

TPH NDVOC NDSVOC NDTIC ND

32MW1305 60 - 62 Area of Former TPH NDGolf CourseClub House

VOC NDSVOC ND

32MW1306 0 - 2 Adjacent to Former TPH NDFuel Header Pipes(AVGAS Section)

VOC tetrachloroethene 0.021 0.5

60 - 62SVOC ND

TPH ND

65 - 67SVOC ND

VOC NDTIC hexane 0.096 No Standard

32MW1311 32 - 34 Adjacent to Former TPH ND

60 - 62

Fuel Header Pipes(AVGAS Section)

VOC NDSVOC NDTICunknown SVOC 0.49 j

TPH NDVOC NDSVOC NDTIC hexane 0.65 j pentane 0.092 j heptane 0.079 j unknown SVOC 0.18

No StandardNo StandardNo StandardNo Standard

32MW1312 50 - 52 Adjacent to Former TPH ND

60 - 62

Fuel Header Pipes(JP-4 Section)

VOC NDSVOC NDTIC ND

TPH NDVOC NDSVOC NDTIC ND

32MW1313 25 - 27 Adjacent to Former TPH ND

65 - 67

Fuel Header Pipes(JP-4 Section)

VOC NDSVOC NDTICs ND

TPH NDVOC NDSVOC NDTIC trisiloxane 0.0047 No Standard

ft bgs - feet below ground surfacej - estimated concentrationND - not detectedSVOC - semivolatile organic compoundTIC - total inorganic carbonTPH - total petroleum hydrocargonsVOC - volatile organic compound

I:\35Z01302 - FS-2\ROD\Draft\Appendices\App D EC Jordan 90-91.xls 3-5 RI Surface Metals Page 1 of 17/24/2001

Appendix D-5Surface Soil Analytical Data - Metals

E.C. Jordan Final Site Investigation ReportFebruary 1991

Sample Location Depth Result (mg/kg) MCP S-1/GW 1 Standard (mg/kg)

SS-1 Surface Aluminum 6,570Copper 8Iron 5,930Lead 6Manganese 21Zinc 9

No StandardNo StandardNo Standard

300No Standard

2,500SS-2 Surface Aluminum 3,280

Cadmium 2Iron 4,320Lead 7Manganese 33Zinc 9

No Standard30

No Standard300

No Standard2,500

SS-3 Surface Aluminum 5,970Arsenic 4Iron 7,530Lead 12Manganese 29Vanadium 15Zinc 11

No Standard30

No Standard300

No Standard400

2,500SS-4 Surface Aluminum 8,930

Iron 8,250Lead 4Manganese 23Vanadium 12Zinc 8

No StandardNo Standard

300No Standard

4002,500

SS-5 Surface ND

SS-6 Surface ND

These six surface soil samples were collected from the vicinity of MW-3.mg/kg - milligrams per kilogramND - not detected

I:\35Z01302 - FS-2\ROD\Draft\Appendices\App D EC Jordan 90-91.xls 3-6 RI Test Boring Metals Page 1 of 17/24/2001

Appendix D-6Test Boring Soil Analytical Data - Metals

E.C. Jordan Draft Remedial Investigation ReportFebruary 1991

Designation Depth(ft bgs) Sample Area

Result (mg/kg)

MCP S-1/GW-1 Standard(mg/kg)

32MW1304 32 - 34 South of Aluminum 599 No StandardGolf Course Iron 1,280 No StandardMaintenance Shed Lead 1

Manganese 22300

No Standard

60 - 62 Aluminum 608 No StandardIron 2,600 No StandardLead 1Manganese 14

300No Standard

32MW1305 60 - 62 Area of Former Aluminum 1,280 No StandardGolf Course Antimony 21 10Club House Chromium 3 1000

Iron 2,330 No StandardLead 1 300

. Manganese 29 No Standard

32MW1306 0 - 2 Adjacent to Former Aluminum 3 460 No StandardFuel Header Pipes Iron 5,150 No Standard(AVGAS Section) lead 20

Manganese 51300

No StandardZinc 12 2,500

60 - 62 Aluminum 518 No StandardIron 1,470 No StandardLead NDManganese 11

300No Standard

Zinc ND 2,500

32MW1311 32 - 34 Adjacent to Former Aluminum 1,010 No StandardFuel Header Pipes Iron 5,020 No Standard(AVGAS Section) Lead 4

Manganese 51300

No Standard

60 - 62 Aluminum 431 No StandardIron 1,900 No StandardLead NDManganese 6

300No Standard

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Appendix D-6Test Boring Soil Analytical Data - Metals

E.C. Jordan Final Site Investigation ReportFebruary 1991

Designation Depth(ft bgs) Sample Area

Result (mg/kg)

MCP S-1/GW 1 Standard(mg/kg)

32MW1312 50 - 5260 - 62

Adjacent to FormerFuel Header Pipes(JP-4 Section)

AluminumironLeadManganese

AluminumIronLeadManganese

6301,510

212

7912,190

114

No StandardNo Standard

300No Standard

No StandardNo Standard

300No Standard

TB-1313 25-27 Adjacent to Former Aluminum 834 No StandardFuel Header Pipes Iron 3200 No Standard(JP-4 Section) Lead

Manganese1.324

300No Standard

65 - 67 Aluminum 572 No StandardIron 4,060 No StandardLeadManganese

111

300No Standard

ft bgs - feet below ground surface mg/kg - milligrams per kilogram ND - not detected Bold indicates exceedance of Massachusetts Contingency Plan Method 1 Soil Category S-1/GW-1 Standard [310CMR 40.0975 (6) (a)]


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