RECORD OF DECISION BARNUM ROAD MAINTENANCE …

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U.S. Arm!Environmej

Center!

1FORT DEVENSRECORD OF DECISIONAOCs 44 and 52

RECORD OF DECISIONBARNUM ROAD MAINTENANCE YARDSFORT DEVENS, MASSACHUSETTS

IN ACCORDANCE WITH U.S. ARMY REGULATION 200-2.THIS DOCUMENT IS INTENDED BY THE U.S. ARMY TO COMPLY WITH Tf/E

NATIONAL ENVIRONMENTAL POLICY ACT (NEPA) OF 1969.

MARCH 1995

PRINTED ON RECYCLED PAPER

-EC <*5, 1 Feb 93 replaces THAMA Form « which is obsolete.

BARNUM ROAD MAINTENANCE YARDSAOCs 44 & 52

ROD SUMMARY INDEX OF APPENDICES

PAGE1. Appendix A - Figures (Site Maps) 1

2. Appendix B - Tables (Contaminant Distributions, Costs, Etc.)- 21

3. Appendix C - Responsiveness Summary 64

4. Responsiveness Summary Attachment A (Public Hearing Transcript) 80

5. Appendix D - Declaration of State Concurrence 92

6. Appendix E - Administrative Record Index 95

7. Appendix F - Glossary of Acronyms and Abbreviations 119

DECLARATION FOR THE RECORD OF DECISION

BARNUM ROAD MAINTENANCE YARDSAREAS OF CONTAMINATION 44 & 52FORT DEVENS, MASSACHUSETTS

STATEMENT OF PURPOSE

Fort Devens is a Comprehensive Environmental Response,Compensation and Liability Act (CERCLA) National Priorities Listsite which is located in Middlesex and Worcester Counties and iswithin the Towns of Ayer, Harvard, Lancaster and Shirley,Massachusetts. There are 73 Study Areas (SAs) and Areas ofContamination (AOCs) at Fort Devens which are currently underinvestigation.

The Record of Decision relates to the Barnum Road MaintenanceYards (AOCs 44 & 52). The site is situated in the northeastcorner of the Main Post near the Barnum Gate (Figure 1) andapproximately one mile southwest of the Town of Ayer Route 2A/110intersection. This Decision Document presents the selectedremedial action for the Barnum Road Maintenance Yard operableunit, developed in accordance with the CERCLA of 1980, asamended, 42 U.S.C. §§ 9601 et seq. and the National Oil andHazardous Substance Pollution Contingency Plan (NCP), to theextent practicable, as amended, 40 C.F.R. Part 300. The FortDevens Base Realignment and Closure (BRAC) EnvironmentalCoordinator, the Deputy Assistant Secretary of the Army(Environmental, Safety, and Occupational Health), and the USEPARegion I Administrator have been delegated the authority toapprove this Record of Decision.

The Commonwealth of Massachusetts has concurred with the selectedremedy. A copy of the declaration of concurrence is included asAppendix D of this ROD.

STATEMENT OF BASIS

This decision is based on the Administrative Record which hasbeen developed in accordance with Section 113(k) of CERCLA. TheAdministrative Record is available for public review at the FortDevens BRAC Environmental Office, Building P12, Fort Devens,Massachusetts, and at the Ayer Town Hall, Main Street, Ayer,Massachusetts. The Administrative Record Index (Appendix E ofthe ROD) identifies each of the items comprising theAdministrative Record upon which the selection of the remedialaction is based.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from theMaintenance Yards, if not addressed by implementing the responseaction selected in this ROD, may present an imminent andsubstantial endangerment to the public health or welfare or tothe environment.

DESCRIPTION OF THE SELECTED REMEDY

This ROD sets forth the selected remedy for the Maintenance Yardswhich will address the contaminated surface soils and soilsassociated with two known releases (hot spot areas) at theMaintenance Yards.

Manor Components of the Selected Remedy

• Excavate surface soil (top two feet across the site),• Excavate the two hot spot areas,• Stockpile soils for sampling and analysis,• Cold mix asphalt batch soils exceeding site cleanup

levels of 7 ppm (average) total carcinogenicpolynuclear aromatic hydrocarbons (cPAHs) and 500 ppmtotal petroleum hydrocarbon compounds (TPHC),

• Backfill excavations with uncontaminated stockpiledsoil and then place the asphalt batched material,

• Apply a pavement wearing course,• Expand the existing stormwater collection system,• Perform groundwater monitoring,• As a precautionary measure, institute the following

deed restrictions:

1) prohibit residential development/use of theMaintenance Yards,

2) minimize the possibility of long-term (workinglifetime) exposure to subsurface soils, and

3) require management of soils resulting fromconstruction related activities.

The selected remedy involves excavating the top two feet of soilacross the Maintenance Yards and contaminated soils associatedwith two hot spot areas (a reported release of "mogas" [motorvehicle gasoline] and leakage from a 1,000-gallon undergroundwaste oil storage tank). Excavated soil will be placed in pilesat the site for sampling and analysis.

Soils which exceed site cleanup levels will be cold mix asphaltbatched. Cold mix asphalt batching is a technology that entailsrecycling petroleum contaminated soil into bituminous paving orroad base product at ambient temperatures. Soil with contaminant

concentrations below the cleanup criteria will be placed back inthe excavation area. The asphalt batched material will be placedover the backfill as a base/subbase pavement course for parkinglot construction at the Maintenance Yards. Asphalt batching willimmobilize the contaminants exceeding cleanup levels present inthe top two feet, thus minimizing direct contact/ingestion andinhalation of the soils having a carcinogenic risk. Excavatingand asphalt batching soil from the hot spot areas will reduce themobility of contaminants present in the highest concentrations atthe Maintenance Yards. Placement of the asphalt batched soilsonto the surface of the Maintenance Yards will also minimize thepotential migration of contaminants to the groundwater throughthe construction of a low permeable pavement barrier.

The Army has chosen to add a pavement wearing course for avehicle parking surface over the asphalt batched material as partof the selected remedy. Addition of the wearing course willensure the integrity of the asphalt batched material as a parkinglot base for current and future property use.

Applying the asphalt batched material and pavement wearing courseto the Maintenance Yards will increase the amount of runoffduring rain events. Therefore the selected remedy will includeexpansion of the existing stormwater collection system.Potentially, a detention basin and flow reducers will need to beincorporated into the design to minimize wetland impacts.

Sampling and analysis of groundwater from existing wells at theMaintenance Yards will be performed yearly for a period of fiveyears upon commencement of remedial activities.

As a precautionary measure, institutional controls in the form ofdeed restrictions will be implemented to prevent potentialcircumstances which may result in risk of harm to health, safety,public welfare or the environment. These restrictions willinclude:

1. No residential development/use of the Maintenance Yards willbe permitted. The quantitative risk evaluation and establishedcleanup level assume the property will remain zoned forcommercial/industrial use.

2. Removal of the 2-foot cover or an asphaltic barrier from theMaintenance Yards will be prohibited to prevent surface soilexposure to existing subsurface soils (2-foot to 5-foot level).This deed restriction will be implemented as a precautionarymeasure to minimize the possibility of long-term (workinglifetime) exposure to subsurface soils. This restriction willnot apply to excavations undertaken in connection withconstruction of buildings or other structures, utilities,infrastructures or any other construction related purpose wherethe cover is penetrated and/or temporarily removed and protection

from long-term exposure to subsurface soil is not jeopardized.To comply with this deed restriction, the 2-foot layer of covermaterial (which may consist of one or combination of "clean" sitesoil used as backfill, asphalt batched material, off-sitesoils/aggregate and bituminous pavement) will remain over thesubsurface soil (existing 2- to 5-foot soil level) to minimizedirect contact/ingestion to the present subsurface soils. Thecontinuity of the paved surface need not be maintained providingthe cover thickness of 2 feet is provided. As an alternative, acontinuous and maintained paved surface which would preventexposure to subsurface soils could be substituted for the 2-footthick cover.

This restriction also would not apply to excavation and use thatis within the scope of any authorized response action. The deedrestriction may be nullified, as approved by the regulatoryagencies, should there be future evidence showing thatcontaminant levels within the 2- to 5-foot soil zone are belowsite surface soil cleanup levels.

3. Excavation below 2 feet at the Maintenance Yards, subsequentto completion of the remedial action established in this ROD,will require:

a. Development and implementation of a Health and SafetyPlan for the work area; and

b. Development and implementation of a Sampling andAnalysis Plan for management of the excavated soils inaccordance with the following:

Where reuse of soil within the Maintenance Yards isintended, sampling and analysis of stockpiled soilsexcavated below 2 feet will follow criteria detailed in thisROD for hot spot area soils. Soils with contaminantsexceeding the 500 ppm cleanup level for TPHC will be treatedin a manner consistent with this ROD. Soils withcontaminants below the established cleanup level may bereturned to the excavation. Soil excavated below 2 feet butreturned to the top 2 feet (as surface soil) must also besampled, analyzed and, if required, treated for cPAHcontaminants as detailed in this ROD.

Where reuse of soil outside the Maintenance Yards isintended, sampling/analysis and action levels for stockpiledsoils excavated below 2 feet will follow criteria governedby the regulations or policies in effect for the finaldisposal area.

DECLARATION

The selected remedy is protective of the human health and theenvironment, attains federal and state requirements that areapplicable or relevant and appropriate for this remedial action,and is cost effective. This remedy satisfies the statutorypreference for remedies that utilize treatment as a principalelement to reduce the toxicity, mobility, or volume of hazardoussubstances. In addition, this remedy utilizes permanentsolutions and innovative treatment technologies to the maximumextent practicable.

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The foregoing represents the selection of a remedial action bythe Department of the Army and the United States EnvironmentalProtection Agency, Region I, with the Concurrence of theCommonwealth of Massachusetts Department of EnvironmentalProtection. Concur and recommend for immediate implementation:

UNITED STATES DEPARTMENT OF THE ARMY

ES C. CHAMBERS Dateort DevensRAC Environmental Coordinator

The foregoing represents the selection of a remedial action bythe Department of the Army and the United States EnvironmentalProtection Agency, Region I, with the Concurrence of theCommonwealth of Massachusetts Department of EnvironmentalProtection. Concur and recommend for immediate implementation:

UNI THE ARMY

orEdward 6. Nuttall 17Colonel, U.S. ArmyInstallation Commander

Date

The foregoing represents the selection of a remedial action bythe Department of the Army and the United States EnvironmentalProtection Agency, Region I, with the concurrence of theCommonwealth of Massachusetts Department of EnvironmentalProtection. Concur and recommend for immediate implementation:

U.S. ENVIRONMENTAL PROTECTION AGENCY

v I

JOHN P. DEVILLARSRegional Administrator

Date

RECORD OF DECISIONBARNUM ROAD MAINTENANCE YARDSAREAS OF CONTAMINATION 44 & 52FORT DEVENS, MASSACHUSETTS

MARCH 1995

RECORD OF DECISION SUMMARYBARNUM ROAD MAINTENANCE YARDSAREAS OF CONTAMINATION 44 & 52FORT DEVENS, MASSACHUSETTS

TABLE OF CONTENTS

Section Title Page No.

EXECUTIVE SUMMARY 1

I. SITE NAME, LOCATION AND DESCRIPTION 1

II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 2A. Land Use and Response History 2B. Enforcement History 4

III. COMMUNITY PARTICIPATION 6

IV. SCOPE AND ROLE OF THE RESPONSE ACTION 8

V. SUMMARY OF SITE CHARACTERISTICS 8A. Soil 9

1. SI Results 92. SSI Results (Hot Spot Area Investigation) . . 10

B. Groundwater 111. SI Results 112. SSI Results 12

C. Cold Spring Brook Surface Water and Sediment ... 13

VI. SUMMARY OF SITE RISKS 14A. Baseline Risk Assessment Approach and Assumptions . 14

1. Crankcase Releases 152. Mogas Spill 17

B. Baseline Risk Assessment Results 171. Crankcase Releases 182. Mogas Spill 19

C. Ecological Risk Evaluation 20

VII. DEVELOPMENT AND SCREENING OF ALTERNATIVES 20A. Statutory Requirements/Response Objectives .... 20B. Technology and Alternative Development and

Screening 21

VIII. DESCRIPTION OF ALTERNATIVES 22A. Alternative 1: No-Action 22B. Alternative 2: Fencing/Asphalt Batching Hot Spot

Areas 23C. Alternative 3: Capping Site/Asphalt Batching Hot

Spot Areas 24

RECORD OF DECISION SUMMARYBARNUM ROAD MAINTENANCE YARDSAREAS OF CONTAMINATION 44 & 52FORT DEVENS, MASSACHUSETTS

TABLE OF CONTENTS(continued)

Section Title Paae No.

D. Alternative 5: Asphalt Batching Site/AsphaltBatching Hot Spot Areas 25

E. Alternative 7: Bioventing Site and Hot Spot Areas . 26F. Alternative 8: Landfarming Site/Excavating and

Landfarming Hot Spot Areas 27G. Alternative 9: Treatment of Site and Hot Spot Area

Soils at a Central Soil Treatment Facility .... 29

IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES . . 31

X. THE SELECTED REMEDY 41A. Soil Cleanup Levels 42B. Description of Remedial Components 44C. Other Components of the Selected Remedy 50

XI. STATUTORY DETERMINATIONS 51A. The Selected Remedy is Protective of Human Health

and the Environment 51B. The Selected Remedy Attains ARARs 51C. The Selected Remedial Action is Cost-Effective . . 54D. The Selected Remedy Utilizes Permanent Solutions

and Alternative Treatment or Resource RecoveryTechnologies to the Maximum Extent Practicable . . 55

E. The Selected Remedy Satisfies the Preference forTreatment Which Permanently and Significantlyreduces the Toxicity, Mobility or Volume of theHazardous Substances as a Principal Element .... 56

XII. DOCUMENTATION OF NO SIGNIFICANT CHANGES 56

XIII. STATE ROLE 57

APPENDIX A - FIGURESAPPENDIX B - TABLESAPPENDIX C - RESPONSIVENESS SUMMARYAPPENDIX D - DECLARATION OF STATE CONCURRENCEAPPENDIX E - ADMINISTRATIVE RECORD INDEXAPPENDIX F - GLOSSARY OF ACRONYMS AND ABBREVIATIONS

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RECORD OF DECISIONBarnum Road Maintenance Yards, AOCs 44 & 52 Page ES-1

EXECUTIVE SUMMARY

Fort Devens is located in Middlesex and Worcester Counties and iswithin the Towns of Ayer, Harvard, Lancaster and Shirley,Massachusetts. There are 73 Study Areas (SAs) and Areas ofContamination (AOCs) at Fort Devens which are currently underinvestigation for potential environmental restoration.

This Record of Decision (ROD) relates to the Barnum RoadMaintenance Yards (AOCs 44 & 52). The site is situated in thenortheast corner of the Main Post near the Barnum Gate (Figure 1of Appendix A). This ROD sets forth the selected remedy for theBarnum Road Maintenance Yards which addresses the contaminatedsurface soils and soils associated with two known releases (hotspot areas). This decision is based on the Administrative Recordwhich is available for public review at the Fort Devens BaseRealignment and Closure (BRAC) Environmental Office, BuildingP12, Fort Devens, Massachusetts, and at the Ayer Town Hall, MainStreet, Ayer, Massachusetts. The Administrative Record Index(Appendix E) identifies the reports, correspondence and otherdocumentation comprising the Administrative Record upon which theselection of the remedial action is based.

The total area of the Barnum Road Maintenance Yards isapproximately 8.8 acres. The Barnum Road Maintenance Yards aredivided into two study areas which were investigated andidentified as AOCs 44 and 52 (Figure 2 of Appendix A). AOC 44 isknown as the Cannibalization Yard. It is an area where vehicleswere stored before being dismantled for usable parts. AOC 52 isa maintenance yard where vehicles are stored while awaitingrepairs. It was previously known as the TDA Maintenance Yard.Northwest of the Cannibalization Yard is a separately fencedvehicle storage yard known as the RTS Yard. An area that isfenced southeast of the main portion of the TDA Maintenance Yardis known as the K-Yard. All four of these yards have a long andcontinuing history of vehicle storage and possible crankcasereleases and have been combined as one site identified as theMaintenance Yards. The only known significant vehicle releasewas an estimated 20 gallons of "mogas" (motor vehicle gasoline)and hydraulic fluid released near the center of theCannibalization Yard in 1985. Also, a 1,000-gallon undergroundwaste oil storage tank was located in the Cannibalization Yarduntil its removal in May 1992.

The Army conducted a series of field investigations during the1992 to 1993 period. Site investigation and feasibility studyreports were written in 1993 detailing the investigationsperformed, the nature and extent of contamination found at the

RECORD OF DECISIONBarnum Road Maintenance Yards/ AOCa 44 & 52 Page E8-2

Maintenance Yards, and the potential health risks associated withthe site.

In general, contamination at the Maintenance Yards consists ofpollutants commonly associated with used motor oil. Contaminantscreating a potential health risk are located in the surface soil(top two feet) at the site. Additionally, contaminants weredetected in d€>eper soil around the former waste oil storage tankand in the vicinity of the reported mogas spill in theCannibalization Yard (hot spot areas). There is no evidence thatcontaminants found in the Maintenance Yard soils are affectinggroundwater quality.

The Army developed seven remedial options for the MaintenanceYards in a document entitled "Final Feasibility Study Report forUnsaturated Soils at the Maintenance Yards." This reportevaluated each of the alternatives using criteria developed bythe United States Environmental Protection Agency (USEPA) for usein the Superfund process.

Of the seven alternatives, one was chosen as the preferredalternative by the Army. State and community acceptance, wereevaluated following receipt of comments from the MassachusettsDepartment of Environmental Protection (MADEP) and the public onthe Proposed Plan. Details of the preferred alternative wereprovided to the public in a Fact Sheet and Proposed Plan issuedon May 16, 1994. On May 24, 1994, the Army held an informationalmeeting at Fort Devens to discuss the results of the fieldinvestigations; and to present the Army's Proposed Plan. From May25 to June 24,, 1994, the Army held a 30-day public comment periodto accept public comments on the alternatives presented in theFeasibility Study and the Proposed Plan. On June 15, 1994 theArmy held a formal public meeting at Fort Devens to accept anyverbal comments on the preferred alternative. A transcript ofthis meeting and the comments and the Army's response to commentsare included in the responsiveness summary (Appendix C). Thecomments received by the community and local governmentsgenerally support the selected remedy. MADEP has reviewed thevarious alternatives and formally concurs with the selectedremedy for the Maintenance Yards. A copy of the declaration ofconcurrence is attached as Appendix D.

The selected remedy is protective of human health and theenvironment, attains federal and state requirements that areapplicable or relevant and appropriate for this remedial action,and is cost effective. This remedy satisfies the statutorypreference for remedies that utilize treatment as a principalelement to reduce the toxicity, mobility, or volume of hazardoussubstances. In addition, this remedy utilizes permanent

RECORD OF DECISIONBarnum Road Maintenance Yards, AOC3 44 & 52 Page ES-3

solutions and innovative treatment technologies to the maximumextent practicable.

The selected remedy includes the following components:


levels of 7 ppm (average) total carcinogenicpolynuclear aromatic hydrocarbons (cPAHs) and 500 ppmtotal petroleum hydrocarbon compounds (TPHC),

• Backfill excavations with uncontaminated stockpiledsoil and apply the asphalt batched material over thesurface of the site,

• Apply a pavement wearing course for a vehicle parkingsurface,

• Expand the existing stormwater collection system,• Perform groundwater monitoring,• As a precautionary measure, institute the following

deed restrictions: 1) prohibit residentialdevelopment/use of the Maintenance Yards, 2) minimizethe possibility of long-term (working lifetime)exposure to subsurface soils, and 3) requiremanagement of soils resulting from construction relatedactivities.

Site restoration is estimated to take approximately four monthsto complete. Estimated capital cost for remediation is$1,865,000. Total operation and maintenance costs are estimatedto be $72,000. Total present worth cost is $1,937,000.

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RECORD OF DECISION SUMMARYBARNUM ROAD MAINTENANCE YARDSAREAS OP CONTAMINATION 44 & 52

MARCH 1995

I. SITE NAME, LOCATION AND DESCRIPTION

Fort Devens is a Comprehensive Environmental Response,Compensation and Liability Act (CERCLA) National Priorities List(NPL) site which is located in Middlesex and Worcester Countiesand is within the Towns of Ayer, Harvard, Lancaster and Shirley,Massachusetts. There are 73 Study Areas (SAs) and Areas ofContamination (AOCs) at Fort Devens which are currently underinvestigation.

The Record of Decision relates to the Barnum Road MaintenanceYards (AOCs 44 & 52). The site is situated in the northeastcorner of the Main Post near the Barnum Gate (Figure 1)approximately one mile southwest of the Town of Ayer Route 2A/110intersection.

The total area of the site is approximately 8.8 acres (Figure 2).The Maintenance Yards are bordered to the north by MassachusettsArmy National Guard property, which is used for similar vehiclestorage activities as the Barnum Road Maintenance Yards. Bostonand Maine Railroad property and Barnum Road border the site tothe west and east, respectively. Building 3713, located south ofthe site, is a 6-acre building used by the Army for vehiclemaintenance activities. The Maintenance Yards are fenced andpresently used for military vehicle storage. AOC 44 is known asthe Cannibalization Yard. It is an area where vehicles arestored before being dismantled for usable parts. AOC 52 is amaintenance yard where vehicles are stored while awaitingrepairs. It was previously known as the TDA (Table ofDistribution and Allowances) Maintenance Yard. Northwest of theCannibalization Yard is a separately fenced vehicle storage yardknown as the RTS (Regional Training Site) Yard. An area that isfenced-off southeast of the main portion of the TDA MaintenanceYard is known as the K-Yard. All yards show evidence of being atleast partly paved at one time. In areas where pavement isvisible, the pavement has generally been broken-up with age ifnot mostly disintegrated. All four of these yards have a longand continuing history of vehicle storage; hence at the directionof the Army, they were all included as AOCs 44 & 52 and combinedas one operable unit. They are referred to collectively in thisRecord of Decision (ROD) Summary as the Maintenance Yards, or theSite.

Soils in the area of the Maintenance Yards are products ofglacial meltwater deposition in lake and ice-contact environmentsduring the final retreat of Pleistocene glaciers. The yards are

RECORD OF DECISIONBarnum Road Maintenance Yards/ AOCs 44 & 52 Page 2

located on a kame terrace. The deposits consist of stratifiedsands and gravelly sands possibly overlying till.

Groundwater in the aquifer underlying the yards has been assignedto Class I under Commonwealth of Massachusetts regulations.Class I consists of groundwater that is designated as a source ofpotable water supply. Based on a 1992 Site Investigation waterlevel survey, inferred groundwater flow from the MaintenanceYards is northeast toward Grove Pond. The town of Ayer currentlyowns and operates two water supply wells within 150 feet of thesouth side of Grove Pond and approximately one-half mile from theyards (Figure 1). The wells are currently used as a backup tothe town's other supply wells on Spectacle Pond. As part of aplan for meeting future water needs, the town of Ayer is planningto return its well source on Grove Pond to regular service. Thetown engaged a consultant to establish a Zone II area ofinfluence around the wells which is defined as the conceptualzone of contribution to the wells under specific set ofconditions which simulate the most severe pumping and rechargeconditions that can be anticipated realistically. The reportshows the Zone II area as including the Maintenance Yards(Figure 1). The Maintenance Yards are also located approximately1,600 to 1,700 feet from the Fort Devens Grove Pond wellfield,which is within the default Zone II (one-half mile radius) ofthis Army wellfield. Currently there is no evidence thatcontaminants found in the Maintenance Yards1 soils are affectinggroundwater quality.

The Maintenance Yards are located approximately 1,200 feet westof Cold Spring Brook. Surface water from the Maintenance Yardsdrain into part of the Fort Devens stormwater collection systemwhich discharges to Cold Spring Brook (Figure 3). Cold SpringBrook merges with Bowers Brook and flows northeast into GrovePond and then to Plow Shop Pond. Ultimately these ponds draininto Nonacoicus Brook which flows about 1 mile northwest beforeits confluence with the Nashua River.

A more complete description of the Maintenance Yards can be foundin the Site Investigation (SI) Report, April 1993, Sections 2 and4 of Volume I and the Feasibility Study (FS) Report, January1993, Section 1.2.

II. SITE HISTORY AND ENFORCEMENT ACTIVITIES

A. Land Use and Response History

Fort Devens was established in 1917 as Camp Devens, a temporarytraining camp for soldiers from the New England area. In 1931,the camp became a permanent installation and was redesignated as

RECORD OF DECISIONBarnum Road Maintenance Yards, AOCs 44 & 52 Page 3

Fort Devens. Throughout its history, Fort Devens has served as atraining and induction center for military personnel and a unitmobilization and demobilization site. All or portions of thisfunction occurred during World Wars I and II, the Korean andVietnam conflicts, and operations Desert Shield and Desert Storm.The primary mission of Fort Devens is to command, train, andprovide logistical support for non-divisional troop units and tosupport and execute Base Realignment and Closure (BRAC)activities. The installation also supports the Army ReadinessRegion and the National Guard units in the New England area.

As a support for these activities, the Maintenance Yards onBarnum Road have had a long and continuing history of Armyvehicle storage. As a consequence, the soils of the site havebeen exposed to possible crankcase releases over a long duration.Gasoline, motor oil, and other automotive fluids have also likelybeen released during vehicle dismantling operations in theCannibalization Yard. Individual releases are not likely to havebeen of significant volume, but numerous releases during theperiod in which the yard has been used account for the soilcontamination problem. The only recorded significant vehiclerelease was an estimated 20 gallons of "mogas" (motor vehiclegasoline) and hydraulic fluid released near the center of theCannibalization Yard in 1985 during the cannibalization process.Approximately 4 cubic yards (cy) of visibly contaminated soilswere excavated immediately and containerized by Army personnel.

A 1,000-gallon underground storage tank (UST), formerly used tostore waste oil, was located in the Cannibalization Yard untilits removal in May 1992. Visibly contaminated soil wasstockpiled, and laboratory analysis of soil samples from thebottom and one side of the tank excavation showed total petroleumhydrocarbon compound (TPHC) concentrations of 17,600 parts permillion (ppm) and 9,780 ppm, respectively. Laboratory analysiswas also conducted on a waste oil sludge sample obtained frominside the tank. Results revealed the following levels ofsemivolatile organic compounds (SVOCs) and ToxicityCharacteristic Leaching Procedure (TCLP) metals: 110 ppmnaphthalene, 128 ppm bis(2-ethylhexyl)phthalate (B2EHP), 240 ppm2-methylnaphthalene, 0.04 ppm cadmium, 0.4 ppm lead, 0.05 ppmnickel and 3.07 ppm zinc. Analytical results did not reveal thepresence of volatile organic compounds (VOCs) and polychlorinatedbiphenyls (PCBs). Reportedly, the tank was observed to be ingood condition with no holes or severe corrosion. However,inspection revealed that the fill pipe was improperly connectedto the bung of the tank, allowing the pipe contents to leak atthe connection. Later in July 1992, contaminated soilssurrounding the removed tank were excavated. Laboratory tests onsamples collected by the contractor from two sidewalls andstockpile following the over excavation revealed residual TPHC


concentrations ranging from 1,110 to 2,740 ppm. A total of 91tons (an estimated 120 cy) of contaminated soils were removedfrom the waste oil storage tank area in May and July and shippedoff-site for treatment and reuse.

Exploratory test pits were excavated for construction of aconcrete spill-containment basin in the southeast corner of theTDA Maintenance Yard (Figure 2), in July 1991. These test pitsrevealed zones of contaminated soil below the surface. TCLPanalyses detected 3 to 7 micrograms per liter (Mg/1) of benzenein leachate from the soil samples. TPHC was found at 420 to 700ppm concentrations in surface soil samples and at 80 ppm in onesample from a 4-foot depth. TPHC was not detected in the 8-foot-deep soil samples. In November and December 1991 the approximate100-foot by 160-foot proposed spill-containment basin area wasexcavated to begin construction. Excavation continued untilfield screening (non-dispersive infrared analysis [NDIR]) andvisual observation indicated that contaminated soils had beenremoved. It was possible to distinguish the contaminated("dirty", dark brown and black sand and silt) upper layer fromthe non-contaminated ("clean", reddish yellow coarse sand) lowerlayer. The contaminated layer was between 8 and 12 inches thick.The uncontaminated layer extended below the upper layer to theconstruction subgrade limit throughout the spill-containmentbasin's extent. Approximately 1,200 tons of soil were excavatedand stockpiled. Laboratory analysis (USEPA Method 418.1) wasperformed on samples from stockpiled soil. TPHC concentrationsranged from 130 to 800 ppm. In addition, a petroleumidentification analysis (ASTM D 3328) was performed on six of the10 stockpile samples. These samples showed a presence of ahydrocarbon pattern in the C24 to C36 range but the pattern didnot match any of the fuel standards for gasoline, No. 2, 4, and 6fuel oils, kerosene or motor oil/transmission fluid. The soilwas suspected to be an asphalt treated, gravel road base.Samples collected from the proposed basin's subgrade at thebottom of the excavation contained TPHC concentrations rangingfrom nondetect to 7 ppm.

A more detailed description of the site history can be found inthe SI Report, April 1993, Sections 2 and 4 of Volume I and theFS Report, January 1993, Section 1.2.

B. Enforcement History

In conjunction with the Army's Installation Restoration Program(IRP)/ Fort Devens and the U.S. Army Environmental Center (USAEC;formerly the U.S. Army Toxic and Hazardous Materials Agency)initiated a Master Environmental Plan (MEP) in 1988. The MEPconsists of assessments of the environmental status of SAs,specifies necessary investigations, and provides recommendations


for response actions with the objective of identifying prioritiesfor environmental restoration at Fort Devens. AOCs (SAs) 44 & 52were identified as potential sources of contamination in the MEP.The MEP recommended that a record search be conducted to betterdefine past and current activities. It also recommended that theextent of contamination be determined by drilling soil boringsand sampling for the United States Environmental ProtectionAgency (USEPA) hazardous substance list compounds and TPHC. Itsuggested installing monitoring wells if the deeper soils werefound contaminated.

On December 21, 1989, Fort Devens was placed on the NationalPriorities List under CERCLA as amended by the SuperfundAmendments and Reauthorization Act (SARA). The listing of FortDevens as an NPL site was a result of contamination at two othersites (VOC contamination in the groundwater at the Shepley's HillLandfill and metal contamination in the groundwater at the ColdSpring Brook Landfill), and the proximity of both locations topublic water supplies. A Federal Facilities InteragencyAgreement (IAG) was developed and signed by the Army and USEPARegion I on May 13, 1991 and finalized on November 15, 1991. TheIAG provides the framework for the implementation of theCERCLA/SARA process at Fort Devens.

Under Public Law 101-510, the Defense BRAC Act of 1990, FortDevens was selected for cessation of operations and closure. Animportant aspect of BRAC actions is to determine environmentalrestoration requirements before property transfer can beconsidered. As a result, an Enhanced Preliminary Assessment (PA)was performed at Fort Devens to address areas not normallyincluded in the CERCLA process, but requiring review prior toclosure. Although the Enhanced PA covers MEP activities, itsmain focus is to determine if additional areas require detailedrecords review and site investigation and to provide informationand procedures to investigate installation wide areas requiringenvironmental evaluation. A final version of the Enhanced PAreport was completed in April 1992. No additional findings orrecommendations for AOCs 44 & 52 were provided in the PA. Acurrent total of 59 SAs have been identified and placed in 13priority groups defined in the IAG between the Army and USEPA.

In 1992, the Department of Defense (DoD), through USAEC,initiated a SI for AOCs 44 & 52 along with 10 other SAs in SAGroups 3, 5 and 6 at Fort Devens. The Final SI Report was issuedApril 1993. The purpose of the SI was to verify the presence orabsence of environmental contamination and to determine whetherfurther investigation or remediation was warranted. In June1993, a supplemental SI (SSI) was conducted to fill specific datagaps identified during the FS process. The SI and SSI met therequirements of a Remedial Investigation in defining the nature

RECORD OF DECISIONBarnum Road Maintenance Yards/ AOCs 44 S 52 Page 6

and extent of contamination at the Maintenance Yards. As aresult of the SI and SSI, the Maintenance Yards SAs weredesignated as AOCs due to contamination detected in theunsaturated soils. A FS was prepared to evaluate remedial actionalternatives for cleanup of the Maintenance Yards. This studyidentifies and screens 11 remedial alternatives and provides adetailed analysis of seven remedial alternatives to allow thedecision-makers to select a remedy for cleanup of the MaintenanceYards. The Final FS was issued January 1994. The Proposed Plandetailing the Army's preferred remedial alternative was issued inMay 1994 for public comment. Technical comments presented duringthe public comment period are included in the AdministrativeRecord. A summary of these comments as well as the Army'sresponses, which describe how these comments affected the remedyselection, are included in the Responsiveness Summary, Appendix Cof this document.

III. COMMUNITY PARTICIPATION

Throughout the Site's history, community concern and involvementhas generally centered around the fact that the Maintenance Yardsare located in close proximity to the town of Ayer Grove Pondwells. The Army has kept the community and other interestedparties apprised of site activities through regular and frequentinformational meetings, fact sheets, press releases and publicmeetings.

The Army released a community relations plan in February 1992,that had been submitted earlier for public review, outlining aprogram to address community concerns, and to keep citizensinformed about and involved in activities during remedialactivities. As part of this plan, the Army established aTechnical Review Committee (TRC) in early 1992. The TRC, asrequired by SARA Section 211 and Army Regulation 200-1, includesrepresentatives from USEPA, USAEC, Fort Devens, MassachusettsDepartment of Environmental Protection (MADEP), local officialsand the community. The committee generally met quarterly (untilJanuary 1994, when it was replaced by the Restoration AdvisoryBoard [RAB]) to review and provide technical comments on workproducts, schedules, work plans and proposed activities for theSAs at Fort Devens. The SI and FS Reports, Proposed Plan andother related support documents were all submitted to the TRC fortheir review and comment. Additionally, AOCs 44 & 52 activitywas specifically discussed at TRC meetings held March 24, 1992,January 5, 1993, August 2, 1993 and January 26, 1994.

As part of the Army's commitment to involving the affectedcommunities, a RAB is formed when an installation closureinvolves transfer of property to the community. The RAB was


formed in February 1994 to add members of the Citizen's AdvisoryCommittee (CAC) with current TRC members. The CAC was previouslyestablished to address Massachusetts Environmental Policy Act(MEPA)/Environmental Assessment issues concerning the reuse ofproperty at Fort Devens. The RAB consists of 28 members (15original TRC members plus 13 new members) who are representativesfrom the Army, USEPA Region I, MADEP, local governments andcitizens of the local communities. It meets monthly and providesadvice to the installation and regulatory agencies on Fort Devenscleanup programs. Specific responsibilities include: addressingcleanup issues such as land use and cleanup goals; reviewingplans and documents; identifying proposed requirements andpriorities; and conducting regular meetings which are open to thepublic. The proposed plan for AOCs 44 & 52 was presented at theJune 2, 1994 RAB meeting.

On May 16, 1994, the Army issued a fact sheet to more than 100citizens and organizations, providing the public with a briefexplanation of the preferred alternative for cleanup of theMaintenance Yards. It described the opportunities for publicparticipation, and provided details on the public comment periodand public meetings to be held.

On May 16, the Army issued a press release concerning theproposed cleanup at the Maintenance Yards, to the Lowell Sun,Worcester Telegram, Fitchburg-Leominster Sentinel & Enterprise,Harvard Post, Public Spirit (Ayer) and Fort Devens Dispatch.During the week of June 6, 1994, the Army published a publicnotice concerning the Proposed Plan and public hearing in thePublic Spirit, the Fitchburg-Leominster Sentinel & Enterprise,the Lowell Sun, and the Fort Devens Dispatch. The Army also madethe plan available to the public at the information repositorieslocated at the libraries in Ayer, Shirley, Lancaster, Harvard andat Fort Devens.

On May 24, 1994, the Army held an informal informational meetingat Fort Devens to discuss the results of the field investigationand the cleanup alternatives presented in the FS and to presentthe Army's Proposed Plan. This meeting also provided theopportunity for open discussion concerning the proposed cleanup.From May 25 to June 24, 1994, the Army held a 30-day publiccomment period to accept public comments on the alternativespresented in the FS and the Proposed Plan and on other documentsreleased to the public. On June 15, 1994 the Army held a formalpublic meeting at Fort Devens to discuss the Proposed Plan and toaccept any verbal comments from the public. A transcript of thismeeting and the comments and the Army's response to comments areincluded in the attached responsiveness summary (Appendix C).

RECORD OF DECISIONBarnum Road Maintenance Yard3, AOCs 44 & 52 Page 8

All supporting documentation for the decision regarding theMaintenance Yards is placed in the Administrative Record forreview. The Administrative Record is a collection of all thedocuments considered by the Army in choosing the remedy for theMaintenance Yards. On May 27, 1994 the Army made theAdministrative Record available for public review at the FortDevens BRAC Environmental Office, and at the Ayer Town Hall,Ayer, Massachusetts. An index to the Administrative Record wasavailable at the USEPA Records Center, 90 Canal Street, Boston,Massachusetts and is provided as Appendix E.

IV. SCOPE AMD ROLE OF THE RESPONSE ACTION

The remedy selected for the Maintenance Yards will provideprotection of human health and the environment by reducing thetoxicity and mobility of carcinogenic polynuclear aromatichydrocarbons (cPAHs) and TPHC in the surface soil (top two feet)and mogas spill and waste oil storage tank soils (referred to inthis ROD as hot spot area soils) through on-site treatment. Theselected remedy also minimizes the potential migration ofcontamination to the groundwater, reduces the potential of off-site runoff of contaminants to the Cold Spring Brook wetlands,and provides environmental monitoring of groundwater for a periodof five years following remediation. The remediation of theMaintenance Yards will not adversely impact any future responseactions at the Maintenance Yards should they be required.

This remedial action will address the threat to human healthposed from long-term exposure to contaminated surface soils atthe Maintenance Yards and remove known hot spot areas at thesite.

V. SUMMARY OF SITE CHARACTERISTICS

Section 1.0 of the FS contains an overview of the SI and SSIperformed at the Maintenance Yards. In 1992, the USAEC initiateda SI for the Maintenance Yards along with 10 other SAs in SAGroups 3, 5 and 6 at Fort Devens. Field investigations wereconducted from May to October 1992. During the preparation andregulatory review of the FS, specific data gaps were identifiedwhich required supplemental field investigation and datagathering. As a result, a SSI was conducted in June 1993. Thesignificant findings of the SI and SSI regarding soil,groundwater and surface water and sediment are summarized in thefollowing paragraphs.


A. Soil

1. SI Results

The Maintenance Yards are located on a kame terrace. Soil datafrom borings in these yards indicate that the soil in the area isgenerally clean sand with variable gravel and silt content.Grain-size analysis for soils encountered during the drillingprogram at the Maintenance Yards reveal a gravel content rangingbetween 4 and 23 percent; a sand content ranging between 74 and93 percent; and a fine content (percent passing the #200 sieve)ranging between 2 and 19 percent.

During the SI, 16 soil borings were advanced to observe andsample soils throughout the Maintenance Yards (Figure 4). One ofthese borings, G3M-92-04X, was converted to a monitoring well.Soil samples were collected at the 0- to 2-foot, 5- to 7-foot and10- to 12-foot depths. (Except G3M-92-04X where samples werecollected at 0- to 2-foot, 12- to 14-foot, and 26- to 28-footdepths.) The SI focused on sampling soil for analysis of avariety of organic and inorganic analytes and for TPHC. Tables 1and 2 present the laboratory results for organic compounds fromeach of the 16 soil borings. Tables 3 and 4 present the resultsfor inorganic analytes. Figures 5, 6, and 7 show thedistribution of total VOCs, SVOCs and TPHC in soils collected atthe three depth intervals. Figures 8, 9 and 10 show thedistribution of total cPAHs, total polynuclear aromatichydrocarbons (PAHs) and total SVOCs at the same three depthintervals. Figures 11, 12, and 13 show the distribution ofinorganic analytes at the three depth intervals exceedingcalculated background concentrations for typical Fort Devenssoils.

Aromatic VOCs (ethylbenzene, toluene and xylenes at maximumconcentrations of 0.5 ppm, 0.05 ppm, and 4.0 ppm, respectively)were detected in three out of a total of 48 soil samples. One ofthe three samples was from boring 44B-92-06X, which is believedto be associated with the 1985 mogas spill. There appears to beno obvious lateral or vertical distribution pattern of VOCs insoil. SVOCs, predominantly PAHs, were detected in 34 of 48samples throughout the Maintenance Yards. Carcinogenic PAHconcentrations ranged from nondetect to 220 ppm. SVOCconcentrations are typically higher in surface samples and aregenerally absent or of lower concentration with depth. TPHCappears to mimic the vertical distribution of SVOCs. The averageTPHC concentrations across the site at the 0- to 2-foot, 5- to 7-foot and 10- to 12-foot ranges are 315 ppm, 52 ppm and 33 ppm,respectively. Maximum concentrations are 1210 ppm, 170 ppm and119 ppm, respectively. These values exclude the TPHCconcentrations at boring 44B-92-06X (that may be associated with


the mogas spill) and TPHC concentrations associated with thewaste oil UST. No lateral distribution pattern for SVOCs or TPHCis evident. No chlorinated solvents were detected.

Generally, the same vertical trend in concentrations found forthe SVOCs and TPHC appears to exist with the inorganic analytes(i.e., higher concentrations of inorganic analytes are found nearthe ground surface). Soils near the surface exhibit inorganicanalyte concentrations generally two to three times higher thansoils at 5-foot and 10 foot depths. Chromium, copper, nickel,zinc, sodium and beryllium are analytes that show a pattern ofconsistent exceedances above background concentrations. Theappearance of chromium, copper, nickel and zinc in almost allsurface soil samples could be the result of vehicle maintenanceactivity. Sodium is likely attributable to road salting.Beryllium occurs on a more random basis (in instances at higherconcentration at greater depth) and is believed to be naturallyoccurring. Surface soils that appear to contain the mostinorganic analytes were found at sampling locations 44B-92-06X,44B-92-01X, 52B-92-01X and 52B-92-06X.

Motor oil is a potential source of the organic and inorganicanalytes detected. Cutting and welding activities may be anadditional source of the inorganic analytes associated with metalalloys. The potential routes of contaminant migration whichcould occur at the Maintenance Yards include downward migrationvia precipitation infiltration to the groundwater and bystormwater discharge via the stormwater collection system to ColdSpring Brook (Figure 3). Sampling of groundwater and Cold SpringBrook surface water and sediments was performed as part of the SIand SSI to assess these potential migration routes. A summary ofthese sampling results are discussed in later paragraphs in thissection.

2. SSI Results (Hot Spot Area Investigation)

Defining the vertical and horizontal extent of contaminationaround the former underground waste oil tank and spill areas wasrequired to better assess the remedial alternatives to beevaluated in the FS. Although soil removal actions have takenplace around the excavated tank, the extent (specifically depth)of remaining contamination was not readily defined due to thelack of conclusive analytical data at the time of the soil over-excavation. The horizontal and vertical extent of contaminationfrom the mogas spill was unknown except perhaps in the vicinityof existing boring 44B-92-06X. This boring may have been locatedonly at the periphery of the spill or not in the spill area atall. An Army Pollution Incident Report located the mogas spillcloser to the center of the Cannibalization Yard.

RECORD OP DECISIONBarnvun Road Maintenance Yards, AOCa 44 & 52 Page 11

The SSI entailed drilling a total of four borings, (44B-93-07X,-08X, -09X and -10X), in the Cannibalization Yard in the vicinityof the excavated underground tank area and mogas spill area(Figure 14) and then sampling soil from these borings to betterdefine the extent of contamination. Soil analyses were conductedfor inorganics (only lead in 44B-93-09X and -10X) SVOCs, TPHC,and PCBs. Table 5 presents the laboratory results for organicand inorganic compounds for each of the four borings. Figures 15through 18 show the distribution of SVOCs, TPHC, PCBs andinorganics at four depth intervals (5, 10, 15 and 25 feet belowground surface [bgs]).

TPHC was detected in only two of 16 samples; 121 ppm in boring44B-93-08X at 10 feet bgs and 38.1 ppm in boring 44B-93-09X at 5feet bgs. Boring 44B-93-08X is located near the southeast end ofthe excavated UST. The TPHC detected at the 10-foot levelgenerally corresponds with the location of the tank bottom and islikely due to residual contamination from the excavated UST.Boring 44B-93-09X is located in the Cannibalization Yardapproximately 25 feet north of the area where the mogas spill wassuspected of occurring. The duplicate of this sample revealed aconcentration below the detection level (29.6 ppm). It is notconclusive if this detected concentration is a result of themogas spill. The only SVOC compounds detected were B2EHP at 1.4ppm in 44B-93-09X at the 25-foot depth and trace concentrationsof fluoranthene, phenanthrene and pyrene (0.25, 0.09, and 0.12,respectively) in 44B-93-09X at the 5-foot depth. The duplicateof the 5-foot depth sample revealed concentrations belowdetection level for these PAHs.

Inorganics which exceed background concentrations includearsenic, beryllium, copper, nickel and sodium. Of theseanalytes, only arsenic is a typical constituent of usedautomotive oil. Nickel was also detected in a waste oil sludgesample taken from the UST. These five inorganic analytes arepresent in the mogas spill and waste oil storage tank area soilsat concentrations which are the same order of magnitude abovebackground as detected on an AOCs 44 and 52 site-wide basis.

B. Groundwater

1. 81 Results

During the SI, seven monitoring wells were installed (one in theTDA Maintenance Yard, as shown in Figure 4). Well locations wereselected to provide circumferential coverage of the Group 3 SAsand to provide for evaluation of the Maintenance Yards impact ongroundwater. Groundwater at well location G3M-92-04X, located inthe TDA Maintenance Yard, is approximately 28.5 feet bgs.

RECORD OF DECISIONBarnum Road Maintenance Yards, AOCs 44 & 52 Paga 12

Monitoring wells were sampled in July 1992 and October 1992.Only chloroform was detected in the samples collected frommonitoring well G3M-92-04X. The chloroform is likely to be alaboratory contaminant since it was also detected in half of themethod blanks at a similar concentration. Of the inorganicanalytes detected, only manganese was detected at a concentrationabove its drinking water standard. However, only a secondaryMaximum Contaminant Level (MCL) exists for manganese. No health-based drinking water standard exists for this analyte. Based ongroundwater sampling conducted during the SI, there is noevidence that contaminants found in Maintenance Yards soils areaffecting groundwater quality.

2. SSI Results

The need to investigate groundwater directly downgradient of theformer waste oil tank and mogas spill was discussed during adraft FS review meeting held at Fort Devens on May 5, 1993.During the meeting it was suggested that the existing wellslocated in and around the area of the Maintenance Yards may notbe positioned to readily detect the full impact of the tank andspill contamination sources on the groundwater.

To assess groundwater conditions near these two potentialcontamination sources, two additional groundwater monitoringwells, G3M-93-10X and -11X, were installed downgradient of theremoved underground waste oil storage tank and mogas spill in theCannibalization Yard, respectively (Figure 14). Table 6 presentsthe results for two rounds of sampling from these monitoringwells for organic and inorganic analytes. Analysis was performedfor VOCs, SVOCs, TPHC, inorganics and total suspended solids(TSS). Figure 19 shows the distribution of organic and inorganicanalytes detected in these two wells.

Results from Round 1 (June 1993) show no detectableconcentrations of TPHC or VOCs present. The only organiccontaminant detected was B2EHP at 22 ng/i in G3M-93-10X.Historically, B2EHP has been found to be a lab contaminant.Inorganic contaminants generally exceeded backgroundconcentrations, but are likely due to suspended particulates andare not representative of groundwater quality at that location.TSS for G3M-93-10X and -11X were 206 and 1,110 milligrams perliter (mg/1), respectively.

In Round 2 (September 1993), trace concentrations of toluene (2.6Mg/1 and 1.25 ng/l in G3M-93-10X and -11X, respectively) andtetrachloroethene (2.6 jug/1 in G3M-93-10X) were detected in thegroundwater. Concentrations for both these analytes are belowstate and federal MCLs for drinking water. The exact source ofthese compounds is unknown but they are not believed to be


derived from soils at the Maintenance Yards. Notetrachloroethene was detected in soil samples from boringsupgradient or in the vicinity of G3M-93-10X, or in any other soilsamples collected at the Maintenance Yards. Sludge samples fromthe excavated UST upgradient of G3M-93-10X were free of VOCcontaminants. Trace concentrations of toluene (0.05 ppm andlower) were detected in only three of 67 soil samples collectedin the Maintenance Yards during the SI and SSI. No toluene wasdetected in soil samples collected below 5 feet in depth. As inRound 1, inorganic contaminants in Round 2 unfiltered samplesgenerally exceeded background concentrations but are due tosuspended particulates and are not representative of groundwaterquality at that location. Only sodium exceeded backgroundconcentration in filtered samples (13,800 and 16,800 fJ.g/1 forG3M-93-10X and -11X respectively) and is likely due to use ofroad salt. Detected concentrations of sodium are below state andfederal guidelines for drinking water. Based on the samplingresults from these two wells and the sampling conducted in the SIfor the Group 3 area, there is no evidence that contaminantsassociated with the hot spot areas or those found in other areasof the Maintenance Yards have adversely affected groundwaterquality.

C. Cold Spring Brook Surface Water and Sediment

During the SI, surface water and sediment samples were collectedfrom Cold Spring Brook to assess potential contaminant migrationfrom the Group 3 SAs. No organic compounds were detected insurface water and few inorganic analytes were detected. Sedimentsamples exhibited some organic compound contamination. Theresults of sediment sampling support the conclusion thatcontaminant migration via storm and surface water runoff is apossible source of sediment contamination in Cold Spring Brook.However, it is not possible to conclude if the organic compoundsdetected in the downstream sediment sample are specificallyderived from the Maintenance Yards or some other locationserviced by the same stormwater collection system. Figure 3shows the stormwater drainage system layout for the MaintenanceYards. Cold Spring Brook sediments are outside the scope of thisoperable unit. The Army is addressing sediment issues under AreaRequiring Environmental Evaluation (AREE) 70 Storm WaterDischarge System.

A complete discussion of site characteristics can be found in theSI Report, April 1993, Section 4, Volume I and the FS Report,January 1994, Section 1.

RECORD OF DECISIONBarnvun Road Maintenance Yards/ AQCs 44 & 52 Paga 14

VI. SUMMARY OF SITE RISKS

A Quantitative Human Health Risk Evaluation and a PreliminaryEcological Risk Evaluation were performed to estimate theprobability and magnitude of potential adverse human health andenvironmental effects from exposure to contaminants associatedwith the Maintenance Yards. The results of the QuantitativeHuman Health Risk Evaluation and Preliminary Ecological RiskEvaluation for the site are discussed in the followingsubsections. Subsection A discusses the general approach andassumptions used in performing the baseline risk assessment.Subsection B discusses the results of the baseline riskassessment. Subsection C discusses the ecological riskevaluation.

A. Baseline Risk Assessment Approach and Assumptions

The human health risk assessment followed a four step process:1) contaminant identification, which identified those hazardoussubstances that, given the specifics of the site were ofsignificant concern; 2) exposure assessment, which identifiedactual or potential exposure pathways, characterized thepotentially exposed populations, and determined the extent ofpossible exposure; 3) toxicity assessment, which considered thetypes and magnitude of adverse health effects associated withexposure to hazardous substances, and 4) risk characterization,which integrated the three earlier steps to summarize thepotential and actual risks posed by hazardous substances at thesite, including carcinogenic and non-carcinogenic risks.

Thirty-seven contaminants of concern, listed in Table 7 and 8(for surface and subsurface soils, respectively) of this ROD wereselected for evaluation in the risk assessment. Thesecontaminants constitute a representative subset of the more than43 contaminants identified at the Maintenance Yards during theSI. The 37 contaminants of concern were selected to representpotential site-related hazards based on toxicity, concentration,frequency of detection, and mobility and persistence in theenvironment. A summary of the health effects of each of thecontaminants of concern can be found in the risk evaluationdetailed in the SI Report, Section 4, Volume I and the FS Report,Section 1.

Potential human health effects associated with exposure to thecontaminants of concern were estimated quantitatively through thedevelopment of the following hypothetical exposure pathways:

Exposure to soil associated with crankcase releases(across the Maintenance Yards) considering:

RECORD OF DECISIONBarnum Road Maintenance Yards/ AOCs 44 & 52 Page IS

• Ingestion/dermal contact/inhalation withsurface and subsurface soil by constructionworkers;

• Ingestion/dermal contact with surface soil bylong-term workers;

Exposure to soil associated with the mogas spill(localized in the Cannibalization Yard) consideringingestion/dermal contact with surface and subsurfacesoils by construction workers.

These pathways were developed to reflect the potential forexposure to hazardous substances based on the present uses,potential future uses, and location of the Maintenance Yards.The site has a long history of vehicle storage and repair andwill continue to be used for this purpose until the yards close.(During the development of the FS, the Army was projecting thatthe yards would be closed in the summer of 1996. However, due torecent redevelopment interests, this schedule may be acceleratedand the Army could vacate the yards by early 1995). Followingclosure of the Maintenance Yards, the site and surrounding areais expected to remain commercial/industrial property based onFort Devens Federal Land Disposition plans by the MassachusettsGovernment Land Bank. Reuse possibilities of the yard andadjacent Building 3713 being investigated include development ofa rail yard with railroad car refurbishing facility. The areadirectly south of Building 3713 (DOL vehicle maintenancebuilding) is anticipated to become part of the Devens Inland Portdue to proximity to the railway. The following is a briefsummary of the exposure pathways evaluated. For each pathwayevaluated, an average and a reasonable maximum exposure estimatewas generated corresponding to exposure to the average and themaximum concentration detected in that particular medium. A morethorough description can be found in the human health riskevaluation detailed in the SI Report, Section 4, Volume I and theFS Report, Section 1.

1. Crankcase Releases

Under current and future use, it is possible that a worker couldbe exposed to chemicals detected in soil if excavation were tooccur. This might occur for utility repair or new buildingconstruction. It is also possible that an employee of Building3713 could contact contaminants in surface soil during anactivity such as grounds maintenance.

For the construction worker exposure scenario, it was assumedthat a construction worker would be exposed to surface andsubsurface soils (to a depth of 10 feet) for a period of three

RECORD OF DECISIONBarnum Road Maintenance Yards, AOCs 44 & 52 Pag« 16

months (five workdays for 12 weeks). It was further assumed thatthe worker would be exposed through direct contact with thechemicals on his arms and hands and through the incidentalingestion of soil particles.

For the long-term worker exposure scenario, it was assumed thatan employee of Building 3713 could be exposed to chemicals in thesurface soil (to a depth of 2 feet) in the Maintenance Yards fora working lifetime of 25 years (250 days/year). As for theconstruction worker scenario, it was assumed that the workerwould be exposed through direct contact on his arms and hands andincidental ingestion.

To evaluate the impact of inhalation exposure, the constructionworker receptor was also evaluated for potential exposures tosurface and subsurface soil contaminants (to a depth of 10 feet)via the inhalation of particulates raised during constructionactivities. It was assumed that contaminant concentrations inairborne particulates would be equivalent to the concentrations(arithmetic average) of contaminants in surface and subsurfacesoil. A range of potential Exposure Point Concentrations (EPCs)in air was then calculated. First, it was assumed that therespirable particulate concentration (PM10) in the air was equalto the National Ambient Air Quality Standard (NAAQS) of 50 fj.g percubic meter (ng/m ) annual arithmetic mean concentration.Second, a reasonable air upper-bound EPC was calculated byassuming that the PM10 concentration was equal to 150 ng/m , theNAAQS maximum concentration for a 24-hour period not to beexceeded more than once per year. Using the calculated aircontaminant EPCs that construction workers were assumed exposedto for the entire exposure duration, and an inhalation rate of2.5 m per hour (or 20 m per day divided by an 8-hour workday),risks were evaluated for the particulate inhalation pathway.Toxicity constants (i.e., inhalation cancer slope factors, andinhalation reference concentrations) were obtained from the USEPAIntegration Risk Information System (IRIS) or USEPA's HealthEffects Assessment Summary Tables (HEAST). Inhalation toxicityconstants were used if available. Chemicals lacking inhalationslope factors or reference concentrations were evaluated usingoral slope factors or oral reference doses as surrogate values.As with the other exposure routes (direct contact and incidentalingestion), a construction worker was assumed to inhale particlesfive days per week for a three month-long construction project.

The site worker receptor was not evaluated for the particulateinhalation pathway. Normal site worker activities are unlikelyto raise dust in amounts or for periods of time which wouldresult in significant exposures. Therefore, risks from theparticulate inhalation pathway under exposure scenarios that donot include dust-producing activities can be expected to be


insignificant compared to risks from other soil exposurepathways, and have not been quantified.

2. Mogas Spill

Under current and future use, it is possible that a worker couldbe exposed to chemicals detected in soil if excavation were tooccur in the mogas spill area. This might occur for utilityrepair or new building construction. Because of the limitedextent of this spill (represented by sampling location 44B-92-06X), long-term, repeated exposure is considered to be unlikely.Therefore, worker exposure that would be chronic in duration wasnot evaluated.

It was assumed that a construction worker would be exposed tochemicals in the surface and subsurface soil in the area of themogas spill for a period of three months (5 workdays for 12weeks). This represents a conservative assumption becauserepeated exposure to soil in this particular area is unlikely.It was further assumed that the worker would be exposed throughdirect contact with the chemicals and through the incidentalingestion of soil particles. The maximum concentration detectedat any depth at sampling location 44B-92-06X was selected torepresent the EPC. Most of the residual contamination associatedwith the mogas release was detected and reported as TPHC. Thisis consistent with the composition of mogas, a high-octane leadedgasoline. Because no dose-response value exists with which toevaluate the toxicity of TPHC, a surrogate dose-response valuewas used, that of gasoline. Details of this evaluation arecovered in SI Report, Section 4, Volume I.

B. Baseline Risk Assessment Results

Excess lifetime cancer risks were determined for each exposurepathway by multiplying the exposure level with the chemical-specific cancer factor. Cancer potency factors have beendeveloped by USEPA from epidemiological or animal studies toreflect a conservative "upper bound" of the risk posed bypotentially carcinogenic compounds. That is, the true risk isunlikely to be greater than the risk predicted. The resultingrisk estimates are expressed in scientific notation as aprobability (e.g., 1 x 10" for 1/1,000,000) and indicate (usingthis example), that an average individual is not likely to havegreater that a one in a million chance of developing cancer over70 years as a result of site-related exposure as defined to thecompound at the stated concentration. Current USEPA practiceconsiders carcinogenic risks to be additive when assessingexposure to a mixture of hazardous substances. Two standardapproaches are commonly used for estimating cancer risks forcPAHs. The first and more conservative is the benzo(a)pyrene


[B(a)P] approach. Cancer risk estimates are made assuming thatall cPAHs are as potent as benzo(a)pyrene. This standardapproach was the method used by USEPA Region I at the time thatthe risk estimates for the Maintenance Yards were developed. Thesecond method is the toxic equivalency factor (TEF) approachwhich utilizes TEFs to convert each cPAH's concentration to anequivalent concentration of benzo(a)pyrene thereby establishing apotency relative to B(a)P, which is the method which has beenrecently adopted for use by USEPA Region I.

The hazard index was also calculated for each pathway as USEPA'smeasure of the potential for non-carcinogenic health effects. Ahazard quotient is calculated by dividing the exposure level bythe reference dose (RfD) or other suitable benchmark for non-carcinogenic health effects for an individual compound.Reference doses have been developed by USEPA to protect sensitiveindividuals over the course of a lifetime and they reflect adaily exposure level that is likely to be without an appreciablerisk of an adverse health effect. RfDs are derived fromepidemiological or animal studies and incorporate uncertaintyfactors to help ensure that adverse health effects will notoccur. The hazard quotient is often expressed as a single value(e.g., 0.3) indicating the ratio of the stated exposure asdefined to the RfD value (in this example, the exposure ascharacterized is approximately one-third of an acceptableexposure level for the given compound). The hazard quotient isonly considered additive for compounds that have the same orsimilar toxic endpoint and the sum is referred to as the hazardindex (HI). (For example: the hazard quotient for a compoundknown to produce liver damage should not be added to a secondwhose toxic endpoint is kidney damage).

Tables 9 through 16 depict the carcinogenic and non-carcinogenicrisk summary for the contaminants of concern for each exposurepathway previously described for the Maintenance Yards.

1. Crankcase Releases

Risk estimates made under a construction worker exposure scenariofor crankcase releases at the Maintenance Yards fell within theUSEPA Superfund target risk range of 1E-4 to 1E-6 excess cancerrisk for carcinogens and a target HI of 1. The cancer riskestimates ranged from 4E-6 to 5E-5, assuming exposure to AOCaverage and maximum concentrations (in soil to a depth of 10feet). Impacts from inhalation exposure were determined to benegligible. The carcinogenic risks from inhalation ranged from3E-8 to SE-8 at the ambient particulate limits of 50 and150 M9/ni / respectively. The hazard indices ranged from 0.04 to0.1. These risks are well within USEPA Superfund target risklimits.


Risk estimates made under a long-term worker exposure scenarioexceeded the USEPA Superfund target risk range of 1E-4 to 1E-6excess cancer risk for carcinogens. The cancer risk estimatesranged from 4E-3 to 7E-4, assuming exposure to AOC maximum andaverage concentrations (in soil to a depth of 2 feet).

The chemicals that contribute most significantly to carcinogenicrisk are cPAHs, arsenic, and beryllium. (Although the cancerrisk associated with long-term exposure to arsenic is 1.3 x 10" ,the average concentration of arsenic in surface soil across theMaintenance Yards [14 ppm] is below the base-wide calculatedbackground concentration of 21 ppm. As discussed in the SIReport, beryllium does not appear to be related to Army activityand is probably naturally occurring.) The hazard indices forboth exposure scenarios are below or approximate 1.

2. Mogas Spill

Risk estimates made under a construction worker exposure scenariofor the mogas spill in the Cannibalization Yard fell within theacceptable USEPA Superfund target risk range of 1E-4 to 1E-6excess cancer risk for carcinogens. The cancer risk estimate wascalculated to be 2E-6, assuming exposure to the maximumconcentration found at sampling location 44B-92-06X. The HI wasestimated at 1.9. The chemicals that contribute mostsignificantly to the HI are arsenic (HI = 0.8) and TPHC (HI =0.7). Following USEPA risk assessment guidance, when an HIexceeds 1.0, it is appropriate to consider the toxicologicalendpoints upon which the non-carcinogenic hazards are based andthe target organs for toxicological effects. Hazard indices forindividual compounds should properly be added together only ifthe toxicological endpoints or mechanisms of action of thecompounds are similar. In the case of arsenic and TPHC, theirtoxicological effects would be expected to differ. Thedose/response value for arsenic is based on effects to the skin(i.e., hyperpigmentation and keratosis) while the dose/responsevalue for TPHC (gasoline) is based on reduction in body weightgain. The toxicity of gasoline is attributed primarily toCentral Nervous System effects. Because the toxicologicalendpoints of concern for arsenic and TPHC are different, it isinappropriate to add their hazard indices together. Therefore,based on this consideration, the noncarcinogenic HI would be lessthan 1.0.

Actual or threatened releases of hazardous substances from thissite, if not addressed by implementing the response actionselected in this ROD, may present an imminent and substantialendangerment to public health and welfare. Specifically, currentor future exposure to the surface soils for a working lifetimeposes a threat to human health. Therefore, based on estimated


human health risk, the remedial method focuses on treatment of,and/or minimizing exposure to contaminants within the top twofeet such that the cancer risk estimates fall within USEPASuperfund target risk range. Contaminants which drive the riskin the top two feet of soil are predominantly cPAHs. Arsenic andberyllium also are carcinogenic compounds but only contributeapproximately 5 percent to the cancer risk estimate and arebelieved to be naturally occurring. Therefore, based onestimated risk, remedial methods will focus on the organiccontaminants present, primarily cPAHs.

C. Ecological Risk Evaluation

A preliminary ecological risk evaluation was performed for theMaintenance Yards. It was concluded that no significant habitatfor resident or migratory ecological receptors occur at the site,and no rare or endangered species are known to occur in thevicinity of the Maintenance Yards. The Maintenance Yards aretypically filled with parked heavy equipment vehicles and aresurrounded by fence. The sites are devoid of any woody orherbaceous vegetation. Based on the lack of ecological exposurepathways, no comparison of surface soil analytes to protectivecontaminant level (PCL) reference values was conducted.

In conclusion, based on this evaluation, it is not likely thatthe contaminants found within the Maintenance Yards will impactecological receptors at the site. Potential risks for exposureto surface water and sediments in the portion of Cold SpringBrook adjacent to this general area are being evaluated as partof the AREE 70 evaluation.

VII. DEVELOPMENT AND SCREENING OF ALTERNATIVES

A. Statutory Requirements/Response Objectives

Under its legal authorities, the Army's primary responsibility atSuperfund sites is to undertake remedial actions that areprotective of human health and the environment. In addition,Section 121 of CERCLA establishes several other statutoryrequirements and preferences, including: a requirement that theremedial action, when complete, must comply with all federal andmore stringent state environmental standards, requirements,criteria or limitations, unless a waiver is invoked; arequirement that a remedial action be cost-effective and utilizepermanent solutions and alternative treatment technologies orresource recovery technologies to the maximum extent practicable;and a preference for remedies in which treatment whichpermanently and significantly reduces the volume, toxicity or

RECORD OF DECISIONBarnum Road Maintenance Yards, AOC3 44 & 52 Page 21

mobility of the hazardous substances is a principal element overremedies not involving such treatment. Response alternativeswere developed to be consistent with these Congressionalmandates.

Based on preliminary information relating to types ofcontaminants, environmental media of concern, and potentialexposure pathways, remedial action objectives were developed toaid in the development and screening of alternatives. Theseremedial action objectives were developed to mitigate existingand future potential threats to public health and theenvironment. The response objectives are:

1. Minimize direct contact/ingestion and inhalation withsurface soils at the Maintenance Yards which areestimated to exceed the USEPA Superfund target range of1E-4 to 1E-6 excess cancer risk for carcinogens.

2. Reduce off-site run-off of contaminants that mightresult in concentrations in excess of ambient surfacewater quality standards and in backgroundconcentrations in sediments.

3. Reduce or contain the source of contamination tominimize potential migration of contaminants of concernwhich might result in groundwater concentrations inexcess of the MCLs.

B. Technology and Alternative Development and Screening

CERCLA and the National Contingency Plan (NCP) set forth theprocess by which remedial actions are evaluated and selected. Inaccordance with these requirements, a range of alternatives wasdeveloped for the site.

The FS developed a range of alternatives in which treatment thatreduces the toxicity, mobility, or volume of the hazardoussubstances is a principal element. This range included analternative that removes or destroys hazardous substances to themaximum extent feasible, eliminating or minimizing to the degreepossible the need for long-term management. This range alsoincluded alternatives that treat the principal threats posed bythe site but vary in the degree of treatment employed and thequantities and characteristics of the treatment residuals anduntreated waste that must be managed; alternatives that involvelittle or no treatment but provide protection through engineeringor institutional controls; and a no action alternative.


As discussed in Sections 3 and 4 of the FS, the FS identified,assessed and screened technologies and process options based onimplementability, effectiveness and cost. Over 20 technologieswere determined to be potentially applicable to meet the remedialresponse objectives. This assessment retained certaintechnologies and process options which led to the assembly of anumber of remedial alternatives. Section 5 of the FS identified,evaluated and screened 11 remedial alternatives based onimplementability, effectiveness and cost, as described in Section300.430(e)(4) of the NCP. From this screening process, sevenremedial alternatives were retained for detailed analysis.Table 17 identifies the seven alternatives that were retainedthrough the screening process, as well as those that wereeliminated from further consideration.

VIII. DESCRIPTION OF ALTERNATIVES

This Section provides a narrative summary of each alternative asevaluated in the FS. Eleven alternatives were initiallydeveloped in the FS Report. Of the 11 alternatives, seven wereretained in the FS screening step and were evaluated in detail.The seven alternatives are summarized below. Time and cost forcompletion of each Alternative as reported in the FS was based onthe Army occupying the Maintenance Yards until the summer of1996. A detailed tabular assessment of each alternative can befound in Table 7-1 of the FS Report.

A. Alternative 1: No-Action

• Groundwater and stormwater/sediment monitoring.

The No Action Alternative involves sampling of groundwatermonitoring wells and stormwater catch basins located within anddowngradient of the Maintenance Yards. There is no dataindicating that off-site migration of contaminants is a problemat the Maintenance Yards. However, as a conservative measure,sampling of groundwater from six existing wells andstormwater/sediment from the two catch basins located in theMaintenance Yards would be performed yearly for a five-yearperiod to monitor for any potential migration of contaminants,even though such migration is not likely. Analytes tested wouldbe those tested in the SI (ABB-ES, 1993) for the MaintenanceYards. The No Action Alternative does not involve remedialactions to control migration of contaminants or institutionalcontrols to prevent exposure to contaminated soils within theMaintenance Yards. As required by CERCLA, Alternative 1 isdeveloped to provide a baseline for comparison with the otherremedial alternatives.

RECORD OF DECISIONBarnum Road Maintenance Yards, AOCa 44 & 52 Page 23

Estimated Time for Restoration: not applicableEstimated Capital Costs: $0Estimated Operation and Maintenance Costs: $133,000

(net present worth)Estimated Total Costs: $133,000

(net present worth, assuming 10 percent discount rate)

B. Alternative 2: Fencing/Asphalt Batching Hot Spot Areas

• Excavate hot spot areas,• Asphalt batch hot spot area soils on site,• Maintain fencing around the Maintenance Yards and

implement deed and land use restrictions, and• Groundwater and stormwater/sediment monitoring.

This alternative includes preventing access by maintainingfencing around the site that would prevent access therebyminimizing potential exposure pathways. Deed restrictions wouldact as an institutional control to ensure that the fence remainedintact in the future. Excavation and cold mix asphalt batchingsoil from the hot spot areas in the would reduce the volume ofcontaminants present in the highest concentrations at theMaintenance Yards. Sampling and analysis of groundwater,stormwater and sediments as discussed in Alternative 1 would alsobe performed as a conservative measure to monitor for off-sitemigration.

The location-specific applicable or relevant and appropriaterequirement (ARAR) identified for this alternative regardingwetlands protection will not be met if contaminants from theMaintenance Yards are currently migrating off-site via thestormwater system. This alternative will not reduce potentialoff-site runoff of contaminants in surface water from theMaintenance Yards to the wetlands. Alternative 2 would notcomply with chemical-specific risk-based values because theremediation would not reduce contaminant concentrations to theselevels. Remediation would limit exposure to these chemicals.

Estimated Time for Restoration: Approximately three weeks fortreatment; restoration completed prior to closing of theMaintenance Yards

Estimated Capital Costs: $204,000Estimated Operation and Maintenance Costs: $152,000

(net present worth)Estimated Total Costs: $356,000


RECORD OF DECISIONBarnum Road Maintenance Yards/ ROC3 44 & 52 Page 24

C. Alternative 3: Capping Site/Asphalt Batching Hot SpotAreas

• Excavate hot spot areas,• Asphalt batch hot spot area soils on site,• Cap entire site with asphalt pavement and implement

deed and land use restrictions, and• Groundwater monitoring.

This alternative entails excavating and asphalt batching the hotspot area soils on site, capping the entire site with asphaltpavement, and groundwater monitoring. Excavation and asphaltbatching soil from the hot spot areas in the Cannibalization Yardwould reduce the volume of contaminants present in the highestconcentrations at the Maintenance Yards. Asphalt batchedmaterial from the hot spots can be used as paving base materialfor the cap. Capping the site with bituminous pavement wouldminimize potential exposure pathways, thus mitigate future riskto public health associated with the surface soil. Additionally,potential of contaminant migration off-site is minimized. Deedand land use restrictions would act as an institutional controlto ensure that the cap remained intact in the future. Samplingand analysis of groundwater within or downgradient of theMaintenance Yards would also be performed as detailed inAlternative 1.

The location-specific ARAR identified for this alternativeregarding wetlands protection would be met. This alternativecovers the site with pavement, thus reducing potential off-siterunoff of contaminants in surface water from the MaintenanceYards to the wetlands. The remedy will be designed andconstructed to manage the increased surface water flow (due topaved surfaces) in a manner that will minimize impact to theadjacent wetlands. Alternative 3 would not comply with chemical-specific risk-based values because the remediation would notreduce contaminant concentrations to these levels. However,remediation would limit exposure to these chemicals.

Estimated Time for Restoration: Approximately three months;restoration completed prior to closing of the MaintenanceYards.

Estimated Capital Costs: $1,017,000Estimated Operation and Maintenance Costs: $204,000

(net present worth)Estimated Total Costs: $1,221,000



D. Alternative 5: Asphalt Batching Site/Asphalt BatchingHot Spot Areas

• Excavate the top two feet across the site andcontaminated soils in the hot spot areas,

• Stockpile/sample/analyze soils and asphalt batch soilthat exceed cleanup levels,

• Backfill excavations with stockpiled soil not found tobe contaminated above site cleanup levels,

• Place asphalt batched material on the site surface, and• Groundwater monitoring.

This alternative involves excavating the top two feet of soilacross the Maintenance Yards and contaminated soils in the hotspot areas; placing excavated soils in piles at the site forsampling and analysis; asphalt batching soils which exceed sitecleanup levels; and performing groundwater monitoring at theMaintenance Yards. Soil with concentrations below the cleanupcriteria will be placed back in the excavation area. Asphaltbatching would immobilize the contaminants exceeding cleanuplevels present in the top two feet, thus minimizing directcontact/ingestion and inhalation of the soils having acarcinogenic risk. Excavation and asphalt batching soil from thehot spot areas in the Cannibalization Yard would reduce thevolume of contaminants present in the highest concentrations atthe Maintenance Yards. Additionally, potential of contaminantmigration off-site is minimized. Sampling and analysis ofgroundwater within or downgradient of the Maintenance Yards wouldalso be performed as detailed in Alternative 1.

As described in the May 1994 Final FS Addendum, a pavementwearing course placed over the batched material was not includedin the FS cost as it reportedly would not be required by theregulatory agencies. However, as detailed in the Proposed Plan,the Army has chosen to add a pavement wearing course for avehicle parking surface over the asphalt batched material as partof Alternative 5. Addition of the wearing course will ensure theintegrity of the asphalt batched material as a parking lot basefor current and future property use.

The location-specific ARAR identified for this alternativeregarding wetlands protection would be met. This alternativecovers the site with pavement, thus reduces potential off-siterunoff of contaminants in surface water from the MaintenanceYards to the wetlands. The remedy will be designed andconstructed to manage the increased surface water flow (due topaved surfaces) in a manner that will minimize impact to theadjacent wetlands. Alternative 5 would not comply with chemical-specific risk-based values, because remediation would not reducecontaminant concentrations to these levels. However, remediation


would limit exposure by immobilizing the contaminants. Asphaltbatching binds the contaminants within an asphalt matrix viachemical and physical processes. Cleanup levels are achieved byreducing the concentration of mobile contaminants.

Estimated Time for Restoration: Approximately four months fortreatment; restoration completed prior to closing of theMaintenance Yards.

Estimated Capital Costs w/ wearing course: $1,865,000Estimated Operation and Maintenance Costs: $72,000



E. Alternative 7: Bioventing Site and Hot Spot Areas

• Install and operate bioventing system to treat entiresite and the hot spot soils.

• Groundwater monitoring.

This alternative includes bioventing the entire site and the hotspot areas, and performing groundwater monitoring. Details ofthe bioventing technology are discussed in Section 4.3 of the FS.This alternative includes initial nutrient injection by tractor;and installation of vapor extraction and injection trenches andapproximately 20 bioventing wells, with associated piping,blowers, and humidifier. To prevent short circuiting of air, anasphalt pavement cap will be installed over the entire area ofthe Maintenance Yards. Bioventing will reduce the contaminantspresent in the top two feet thus minimize directcontact/ingestion and inhalation of the soils having acarcinogenic risk. Additionally, the concentrations of thecontaminants of concern are reduced towards background levels indepths below two feet over the site area as well as in the hotspot areas. Because the bioventing system requires a cap toprevent short circuiting of air, the potential of contaminantmigration off-site is immediately minimized upon construction ofthe cap. Sampling and analysis of groundwater within ordowngradient of the Maintenance Yards would be performed asdetailed in Alternative l. Duration of monitoring would be forthe treatment period (estimated to be 10 years).

The location-specific ARAR identified for this alternativeregarding wetlands protection would be met because the wetlandswould not be adversely affected by the remedial action. Thisalternative covers the site with pavement, thus reduces potentialoff-site runoff of contaminants in surface water from soils ofthe Maintenance Yards to the wetlands. The remedy will bedesigned and constructed to manage the increased surface water


flow (due to paved surfaces) in a manner that will minimizeimpact to the adjacent wetlands. Alternative 7 would comply withthe chemical-specific risk-based cleanup levels by promotingdestructive biodegradation of the carcinogenic organic compoundsin the top two feet of the soil and reducing the risk to withinthe USEPA Superfund target risk range of 1E-4 to 1E-6.

The initial injection of nutrients would need to be monitored soas to not impact either Grove Pond and its wetlands or the GrovePond water supply wells. This would minimize human health risksassociated with nitrate/nitrite in groundwater and ecologicalrisks associated with nitrate and phosphate migrating to surfacewater. The MADEP Central Regional Office Water Supply Sectionhas indicated that bioventing is not recommended within publicwater supply aquifer area. The concerns that they have include:high soil permeability, proximity to the Grove Pond Wells,mobilization of contaminants through nutrient addition, the timeto complete degradation, and the difficulty biodegrading cPAHs.However, nutrients would be scientifically applied and monitoredand are not expected to increase the solubility and migration ofcPAHs.

Treatability studies were conducted to determine theeffectiveness of bioventing in reducing cPAH and TPHCconcentrations within the soils of the Maintenance Yards. Basedon the 1993 Biological Treatability Study Report by ABBEnvironmental Services, Inc. (ABB-ES), bioventing does not appearto be nearly as effective as landfarming or composting and infact may not be an effective alternative. The estimatedtreatment period to achieve a total cPAH concentration reductionto 7 ppm is 10 years.

Estimated Time for Restoration: up to 10 years treatment; siterestored approximately eight years after closing of theMaintenance Yards.

Estimated Capital Costs: $1,070,000Estimated Operation and Maintenance Costs: $478,000



F. Alternative 8: Landfarming Site/Excavating andLandfarming Hot Spot Areas

• Mechanically screen surface soil to remove pavementpieces.

• Excavate hot spots.• Landfarm hot spot soils and site soils.• Groundwater monitoring.

RECORD OF DECISIONBarnum Road Maintenance Yards/ AOC3 44 & 52 Page 28

This alternative involves mechanically screening out the asphaltpavement piece's from surface soil, landfarming the entire area ofthe Maintenance Yards, excavating and landfarming the hot spotarea soils that exceed cleanup levels, and performing groundwatermonitoring. Landfarming will reduce the contaminants present inthe top two feet thus minimize direct contact/ingestion andinhalation of the soils. Additionally, the concentration of thecontaminants of concern could be reduced in depths below two feetover the site area by applying excess nutrients and water to thesoil surface. To enable the yards to be used in part duringremediation, design would be based on treating a portion of theyard while the; other portion remained functional as a maintenanceyard. After yard closure, the remaining portion would beremediated. Sampling and analysis of groundwater within ordowngradient of the Maintenance Yards would be performed asdetailed in Alternative 1. Duration of monitoring would be forthe treatment period (estimated to be seven years assuming yardclosure in the summer of 1996).

The location-specific ARAR identified for previous alternativesregarding wetlands protection is not applicable since as part ofthe landfarming operation, for Alternative 8, catch basins wouldbe removed thus eliminating any flow to the wetlands.Alternative 8 would comply with the chemical-specific risk-basedcleanup levels by promoting destructive biodegradation of thecarcinogenic organic compounds in the top two feet of the soiland reducing the risk to within the USEPA Superfund target riskrange of 1E-4 to 1E-6.

As described in Alternative 7, nutrients would need to bemonitored so as to not impact either Grove Pond and its wetlandsor the Grove Pond water supply wells. The MADEP Central RegionalOffice Water Supply Section has indicated that landfarming is notrecommended within a public water supply aquifer area for thesame concerns discussed in Alternative 7. Nutrients would bescientifically applied and monitored and are not expected toincrease the solubility and migration of cPAHs.

Treatability testing and literature studies indicate that theTPHC and cPAH contaminants in the Maintenance Yard soils arebiodegradable. Biodegradation of cPAHs in the soil is expectedto occur slowly, because it was not observable within thelaboratory treatment time of 69 days. However, bioremediationtreatment time data indicates that cPAHs (specificallybenzo(a) pyrenei, which is one of the more difficult cPAHs tobiodegrade) have a half-life of approximately 11.5 months.Treatability testing also indicated that approximately 50 percentof the TPHC biodegraded within the first month followed by slowerreduction of the more recalcitrant TPHC compounds.Bioremediation pilot-scale testing of the AOCs 44 and 52 soils is


recommended as a design activity. Bioremediation of the first 20percent of the Maintenance Yards will serve as this test.Results will be used to further refine the design for treatmentof the remaining 80 percent of the yards.

Estimated Time for Restoration: up to seven years treatment.Site restored approximately five years after closing of theMaintenance Yards.

Estimated Capital Costs: $621,000Estimated Operation and Maintenance Costs: $932,000



G. Alternative 9: Treatment of Site and Hot Spot AreaSoils at a Central Soil Treatment Facility

• Excavate the top two feet across the site andcontaminated soils in the hot spot areas. Mechanicallyscreen to remove pavement pieces.

• Stockpile/sample/analyze soils and remove soil thatexceeds cleanup levels off-site for treatment.

• Compost/asphalt batch soils at a central soil treatmentfacility or dispose/treat off-base if unsuitable fortreatment on-base.

• Groundwater monitoring.

Alternative 9 includes excavating the top two feet of soil acrossthe site and contaminated soils in the Cannibalization Yard hotspot areas; placing excavated soils in piles at the site forsampling and analysis; transporting soils which exceed sitecleanup levels to a central soil treatment facility on base; andperforming groundwater monitoring at the Maintenance Yards. As apre-treatment process, surface soil in areas of the sitecontaining bituminous pavement pieces would be mechanicallyscreened to remove large sized fragments. Screened debris andpavement will be transported to the central soil treatmentfacility for crushing and asphalt batching. As evaluated in theFS, the top two feet of soil from approximately 20 percent of theyard (west end of the yard) and the Cannibalization hot spotareas would be excavated first. This phase of the remediationwould serve as a pilot test for windrow composting treatment.The remaining 80 percent of the yard would continue to beutilized by the Army and would not be remediated as part ofAlternative 9 until yard closure.

RECORD OF DECISIONBarnum Road Maintenance Yards, AOC3 44 & 52 Page 30

The proposed facility is discussed in the FS Report and the FinalSiting Study Report (January 1994). The treatment methods to beused at the facility would be composting and cold mix asphaltbatching. These treatment methods would result in the reuse ofsoils on Fort Devens. Excavated soil which is unsuitable fortreatment (if any) at the central soil treatment facility will betreated and/or disposed of off-base at an approved facility.

Alternative 9 would reduce the contaminants present in the toptwo feet and hot spot areas excavated. Soils with contaminantsexceeding cleanup levels would be removed from the site upon yardclosure permitting immediate reuse of the site. This will meetthe remedial objectives of minimizing direct contact/ingestionand inhalation of the soils having a carcinogenic risk. Samplingand analysis of groundwater within or downgradient of theMaintenance Yards would also be performed as detailed inAlternative 1.

The location-specific ARAR identified for this alternativeregarding wetlands protection would be met. This alternativeremoves contaminated surface soils, thus reduces potential off-site runoff of contaminants in surface water from soils of theMaintenance Yards to the wetlands. This alternative also needsto be in compliance with the Massachusetts Hazardous Waste Rules,Location Standards for Facilities (310 CMR 30.700-30.707)regarding locating treatment facility operations on lands thatare not overlaying an actual, planned, or potential public orprivate drinking water supply. If a groundwater recharge areadoes underlie a selected site, the site has to be relocated or awaiver, if appropriate, would have to be obtained under the Stateregulations. Details of the siting evaluation for the proposedfacility are covered by the Siting Study Report. Alternative 9would comply with the chemical-specific risk-based cleanuplevels. Compliance is achieved by physically removing soilscontaining carcinogenic organic compounds exceeding the cleanupconcentration in the top two feet of the soil thereby mitigatingthe risk to within the USEPA Superfund target risk range of 1E-4to 1E-6. As described in Alternative 8, treatability testing andliterature studies were conducted. They indicate that the TPHCand cPAH contaminants in the Maintenance Yard soils arebiodegradable, however, biodegradation of cPAHs and recalcitrantTPHC in the soil are expected to occur slowly.

Estimated Time for Restoration: Site restoration completeapproximately two months after closing of the MaintenanceYards.

Estimated Capital Costs: $2,739,000(net present worth)

Estimated Operation and Maintenance Costs: $659,000(net present worth)

Estimated Total Costs: $3,398,000(net present worth, assuming 10 percent discount rate)


IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES

Section 121(b)(1) of CERCLA presents several factors that at aminimum the Army is required to consider in its assessment ofalternatives. Building upon these specific statutory mandates,the NCP articulates nine evaluation criteria to be used inassessing the individual remedial alternatives.

A detailed analysis was performed on the alternatives using thenine evaluation criteria in order to select a site remedy.Specific discussion regarding this analysis is provided inSection 6.0 of the FS Report. The nine criteria are summarizedas follows:

Threshold Criteria

The two threshold criteria described below must be met inorder for the alternatives to be eligible for selection inaccordance with the NCP.

1. Overall protection of human health and theenvironment addresses whether or not a remedyprovides adequate protection and describes howrisks posed through each pathway are eliminated,reduced or controlled through treatment,engineering controls, or institutional controls.

2. Compliance with ARARs addresses whether or not aremedy will meet all of the ARARs of other federaland state environmental laws and/or providegrounds for invoking a waiver.

Primary Balancing Criteria

The following five criteria are utilized to compare andevaluate the elements of one alternative to another thatmeet the threshold criteria.

3. Long-term effectiveness and permanence addressesthe criteria that are utilized to assessalternatives for the long-term effectiveness andpermanence they afford, along with the degree of

[ certainty that they will prove successful.4 1

4. Reduction of toxicity, mobility, or volume throughI treatment addresses the degree to which[ alternatives employ recycling or treatment that

reduces toxicity, mobility, or volume, including


how treatment is used to address the principalthreats posed by the site.

5. Short-term effectiveness addresses the period oftime needed to achieve protection and any adverseimpacts on human health and the environment thatmay be posed during the construction andimplementation period, until cleanup goals areachieved.

6. Implementability addresses the technical andadministrative feasibility of a remedy, includingthe availability of materials and services neededto implement a particular option.

7. Cost includes estimated capital and OperationMaintenance (O&M) costs, as well as present-worthcosts.

Modifying Criteria

The modifying criteria are used on the final evaluation ofremedial alternatives generally after the Army has receivedpublic comment on the FS and Proposed Plan.

8. State acceptance addresses the state's positionand key concerns related to the preferredalternative and other alternatives, and thestate's comments on ARARs or the proposed use ofwaivers.

9. Community acceptance addresses the public'sgeneral response to the alternatives described inthe Proposed Plan and FS report.

Following the detailed analysis of each individual alternative, acomparative analysis, focusing on the relative performance ofeach alternative against the nine criteria, was conducted. Thiscomparative analysis can be found in Table 7-1 of the FS Report.It should be noted that Section VIII of the ROD presents thealternatives as they appear in the FS Report. Upon the Army'sselection of the preferred alternative and development of theProposed Plan, two concerns were raised by the regulatoryagencies that subsequently resulted in applying deedrestrictions.

One concern was potential residential exposure to MaintenanceYard soils. The Maintenance Yards and adjacent Barnum Road areahave been targeted by the Massachusetts Government Land Bank for


future redevelopment as a rail/industrial area. The quantitativerisk evaluation and cleanup levels for the site assume this areawill remain zoned for commercial/industrial use. Since the riskevaluation was not performed considering residential exposure, aninstitutional control would need to be implemented to ensure thatthe proposed commercial/industrial use for the Maintenance Yardscould not be changed to residential use. Consequently, the Armyhas applied a deed restriction to Alternatives 5, 7, 8 and 9which would prohibit residential development within theMaintenance Yards.

The second concern was the lack of analytical data for soilbetween 2 feet and 5 feet bgs. Sampling and analyses wereperformed during the SI on soil depths of 0 to 2 feet, 5 to 7feet, and 10 to 12 feet bgs (Boring G3M-92-04X was sampled at 0-2, 12-14 and 26-28 foot intervals). Soil between 2 and 5 feetwas not sampled. However, contaminants were found to betypically higher in surface soil samples (0 to 2 feet) andgenerally absent or of lower concentration with depth which isconsistent with the reported release mechanisms (leaking orspilled vehicular fluids). Contaminant concentrations insubsurface soils are unlikely to be higher than or equal tocontaminant concentrations in surface soils. Risk estimates foronly one of three probable soil exposure scenarios evaluatedexceeded acceptable limits for carcinogens. The scenario forwhich risks exceeded acceptable limits assumes a working lifetimeexposure (250 days/year for 25 years) of a maintenance worker tosurface soil (top 2 feet). Risk estimates for constructionworker scenarios (exposure to surface and subsurface soils [0 to10 feet] for three months) were within acceptable limits.

Although risks associated with exposure to soils deeper than 2feet are within acceptable range, the possibility exists that theentire top two feet of soil could be removed for a future land-use scenario, and the 2- to 4-foot subsurface soil would become"surface" soil. The possibility also exists that contaminantsbelow 2 feet in depth could be at greater or similarconcentrations to the surface soils. There is no analyticalinformation available for this soil level to conclude, without adoubt, that there would be no carcinogenic risk should the toptwo feet of soil be removed.

Consequently, as a protective measure, the Army has appliedinstitutional controls in the form of deed restrictions toAlternatives 5, 8 and 9. (Alternative 7, which entails treatmentof subsurface soils would not require these institutionalcontrols). The deed restrictions will prohibit the removal ofthe top 2-foot cover or barrier from the site to prevent anypossible future long-term (working lifetime) surface soilexposure scenarios to what are presently classified as subsurface


soils. Additionally, the deed restrictions will institute soilmanagement procedures should future excavation below 2 feetoccur.

The section below presents the nine criteria and a briefnarrative summary of the alternatives and the strengths andweaknesses according to the detailed and comparative analysis.A detailed assessment of each alternative according to the ninecriteria can be found in Section 6.0 of the FS Report.

1. Overall Protection of Human Health and the Environment

This criterion is one that, according to CERCLA, must be met fora remedial alternative to be chosen as the final remedy for thesite. Overall Protection of Human Health and the Environmentaddresses how an alternative as a whole will protect human healthand the environment. This includes an assessment of how publichealth and environmental risks are properly eliminated, reduced,or controlled through treatment, engineering controls, orinstitutional controls.

Alternative 1, the No Action alternative is not protective inthat it provides no remedial action, and does not imposeinstitutional controls to prevent exposure to known contaminants.USEPA's target risk range would likely continue to be exceededindefinitely for a site worker without some type of remediation.Alternatives 2 and 3 would eliminate risks by minimizing exposurethrough institutional controls (preventing access to the site andcapping, respectively). Alternative 5, the PreferredAlternative, would achieve an irreversible reduction in mobilityof the contaminants. It is expected that remedial action timewould be approximately four months. Alternative 7, bioventing,would achieve risk reduction by contaminant destruction inapproximately 10 years. However, the risk also would beeliminated by minimizing exposure upon installation of the capprior to the start of bioremediation. (A cap is required for thebioventing technology.)

Alternative 8, landfarming, would achieve risk reduction bycontaminant destruction in approximately seven years, based onyard closure by the summer of 1996 as projected by the Armyduring the development of the FS Report, or five years, based onpotential accelerated yard closure by early 1995. Alternative 9,would be protective immediately following soil excavation,removal, and backfilling at the site, estimated to be within twomonths after operations in the Maintenance Yards cease. The soilwould then be remediated at a central Fort Devens soil treatmentfacility. Alternatives 5, 7,8 and 9 would have deedrestrictions as previously discussed in this Section.


2. Compliance with ARARs

CERCLA also requires that the selected alternative comply withARARs or a waiver be obtained if the alternative does not comply.(ARARs identified for Alternative 5 are provided in Table 19).The location-specific ARAR identified for the Maintenance Yardsalternatives entails regulations that protect wetlands.Alternatives 1 and 2 will not reduce potential off-site runoff ofcontaminants in surface water from the Maintenance Yards to thewetlands. Alternatives 3, 5, 7, 8, and 9 all minimize thepotential of off-site migration of contaminants via thestormwater system. Impacts to wetlands due to increasedstormwater runoff from paved surfaces (Alternatives 2, 3, 5, and7) would need to be considered during remediation and design ofthe stormwater collection system expansion. Additional location-specific ARARs for siting of hazardous waste treatment facilitieswould apply to the central soil treatment facility (Alternative9) •

Action-specific regulations for groundwater monitoring is an ARARfor all of the alternatives, including No Action, and would bemet for all alternatives by instituting a groundwater monitoringprogram for each alternative. The Massachusetts Hazardous WasteRegulations contain ARARs for all remedial alternatives becauseof the nature of contamination at the site. Each alternativewould comply with these regulations during the design andimplementation of the remedial activity.

Federal and state air quality regulations would be met by all thealternatives. In particular, dust suppression would be requiredfor alternatives involving excavation, tilling, or otheractivities that could generate dust.

Requirements specific to remedial actions such as soil recyclingby asphalt batching, biological treatment, and land treatmentwould be met by the alternatives to which they apply.

Although there are no chemical-specific ARARs for establishingcleanup levels for the soils at the Maintenance Yards, risk-basedcleanup criteria have been developed as a remediation goal.Alternatives 1, 2, 3, and 5 do not reduce contaminantconcentrations to meet these cleanup levels; however,Alternatives 2, 3, and 5 do reduce risks by minimizing thepotential for exposure to the contaminants. Alternatives 2 and 3rely on institutional controls to minimize the exposure tosurface soils. Alternatives 5, 7, 8, & 9 do not requireinstitutional controls to minimize exposure to surface soilsunder current and proposed industrial use scenarios. However,they do use institutional controls to prohibit redevelopment forresidential use. Alternative 5 utilizes a treatment process


(asphalt batching) to immobilize the contaminants in surfacesoils but requires restrictions on removal of the 2-foot cover orbarrier from the site to prevent any possible exposure tosubsurface soils (2-foot to 5-foot level where sampling was notperformed). Also soil management procedures are required shouldfuture excavation below 2 feet occur. Although there is nocurrent evidence that suggests contaminant levels at 2 to 5 feetbgs would create a risk if uncovered, precautions in the form ofdeed restrictions would be taken regarding subsurface soils.Alternatives 8 and 9 would meet surface soil cleanup objectivesby using either in-situ or ex-situ response actions but also havesimilar subsurface soil restrictions for the same reasons asAlternative 5. Alternative 7 would treat surface and subsurfacesoils and would not have these restrictions.

3. Long-Term Effectiveness and Permanence

This criterion evaluates the reliability of each alternative inprotecting human health and the environment after the responseobjectives have been met, in terms of the magnitude of residualrisk, the reliability of controls and the degree of certaintythat they will prove successful.

Alternative 1 provides no controls or treatment to protect humanhealth and the environment. Alternatives 2 and 3 rely mainly oninstitutional controls to prevent exposure to the surface soilsat the Maintenance Yards. Alternatives 5, 7, 8 and 9 utilizetreatment technologies (in-situ and ex-situ) for permanentlyimmobilizing or destroying the contaminants and only use deedrestrictions to prevent future conditions from developing thatmay result in risk to human health or the environment. Allalternatives utilize groundwater monitoring for five years or forthe duration of treatment at the site (whichever is longer) fromthe start of remediation. Groundwater monitoring is used as ameans of assessing contaminant migration to the groundwater. Interms of risk reduction over the entire site, Alternatives 8 and9 might be considered the most effective in that the targetcontaminants are destroyed or physically removed in lieu ofimmobilizing as in Alternative 5. However, biodegradation ofcPAHs in the soil is expected to occur slowly (Alternatives 7, 8and 9). Treatability testing detailed in the FS Report indicatesthat Alternative 7, bioventing, is not nearly as effective inreducing contaminants as landfarming (Alternative 8) orcomposting (component of Alternative 9) and, in fact, may not bean effective alternative.


4. Reduction of Toxicity, Mobility, or Volume throughTreatment

Reduction of toxicity, mobility, or volume through treatment arethree principal measures of the overall performance of analternative. The 1986 amendments to the Superfund statuteemphasize that, whenever possible, a remedy should be selectedthat uses a treatment process to reduce permanently the level oftoxicity of contaminants at the site, the spread of contaminantsaway from the source of contamination, and the volume or amountof contamination at the site.

All alternatives except Alternative 1 employ treatment as animportant element. Alternatives 2 and 3 will each reduce themobility of contaminants in the hot spot areas that will becomeasphalt batched material and be utilized as a pavement basecourse. Alternative 5 would reduce the mobility of contaminantsin the hot spot area soils and in the top two feet of soil acrossthe 8.8-acre site which exceed cleanup levels. Asphalt batchedmaterial will be the residual remaining after treatment, whichwill be placed in a layer on the surface of the site.Alternatives 7 and 8, which utilize biological treatmenttechnologies entirely, will reduce the toxicity, mobility, andvolume of soil contaminants and will produce no residuals aftertreatment. Alternative 7, which will entail bioventing theentire site, will treat the top two feet and hot spot areas withpotential of reducing contaminant concentrations with decreasingeffectiveness down to an approximate 10-foot depth across thesite.

Alternatives 8 and 9, which will entail landfarming and off-sitetreatment, respectively, would treat the hot spot areas and thetop two feet of soil. Alternative 8 would have the potential ofreducing contaminant concentrations with decreasing effectivenessat depths below 2 feet. Alternative 9 removes the hot spot areasoil and the top two feet of soil which exceed cleanup criteriafrom the site. The off-site treatment process entails biologicaltreatment which reduces the toxicity, mobility, and volume ofsoil contaminants and produces no residuals after treatment. Italso uses asphalt batching on some soil which would reduce themobility of contaminants in the soil. Asphalt batched materialwill be the residual after treatment which would be used asroadway material.

5. Short-Term Effectiveness

Short-term effectiveness refers to the likelihood of adverseimpacts on human health or the environment that may be posedduring the construction and implementation of an alternative


until cleanup goals are achieved. This criterion also considersthe duration of the remedial alternative.

Alternative 1 would have the least impact during implementationbecause it would not involve construction or operation.Alternative 7 would also have minimal impact on the community,workers, and environment because remediation would take place in-situ. However, increased stormwater runoff from the cap wouldneed to be controlled to minimize impacts on the wetland whichreceives drainage from this area. Runoff control would also bean issue for Alternatives 3, 5, and 2 (to a lesser extent) whichwould place the impermeable asphalt batched material over thesite. Alternatives 2, 3, 5, 8, and 9 involve excavation andhandling of contaminated soils. Adverse impacts from potentialworker exposure would be mitigated by protective clothing andequipment and safe work practices. Fugitive dust would becontrolled by application of water during remedial actions.

Completion of remedial actions would be essentially immediate forAlternatives 2, 3, and 5 because work on site could beaccomplished within a few weeks or months. As evaluated in theFS Report, on-site remedial actions associated with Alternative 9would be completed following closure of the Maintenance Yards.Soils exceeding cleanup levels would be taken off-site to an on-base treatment facility. During the development of the FS, theArmy was projecting that the yards would be closed in the summerof 1996. Based on this projection, excavation at the site wouldbe phased (excavation of hot spots and 20 percent of the site tobegin in 1994, and the remainder to begin in 1996) to accommodatethe Maintenance Yards closure schedule. However, due to recentredevelopment interests, this schedule may be accelerated and theArmy could vacate the yards by early 1995. It is likely thateven under the accelerated schedule, soils from the site wouldneed to be removed in phases to minimize the size requirement ofthe on-base treatment facility. Similarly, Alternative 8 wouldtake up to seven years to complete, based on phased remediation(remediation of hot spots and 20 percent of the site to begin in1994, and the remainder to begin in 1996) to accommodate theMaintenance Yards FS projected closure schedule, or five years ifthe yards close early in 1995. Although bioventing underAlternative 7 could begin in 1994 without major disruption tonormal operations, remediation is expected to take 10 years tocomplete, because this type of bioremediation is not asaggressive as landfarming or composting.

6. Implementability

This criterion evaluates each alternative's ease of constructionand operation; administrative feasibility; and availability ofservices, materials, equipment, and specialists that may required

RECORD OP DECISIONBarnum Road Maintenance Yards, AOCs 44 S 52 Page 39

to construct and operate the technology. This criterion alsoconsiders the ease or difficulty of implementing further remedialactions at a later date, and the effect the remedial alternativewould have on continued operations at the Maintenance Yards.

Alternative 1, which only includes groundwater monitoring, wouldbe the easiest alternative to implement at the site, and wouldhave the least impact on future remedial actions and MaintenanceYards activities. Similarly, Alternative 2 would be relativelyeasy to construct and would have minimal impact on activities atthe site. Alternatives 3 and 5 would be easy to constructbecause they involve asphalt batching/paving the site, whichutilize common construction practices. However, if the yards arestill functional upon commencement of remedial activities, thesealternatives would disrupt the yards for several weeks duringstormwater collection system modification, excavation and paving.Also, if further action is warranted at a later date, thepavement may need to be removed.

Alternative 9 involves excavating and transporting soil, whichare common technologies. Composting technology has been used fortreatment of sewage sludge and is also applicable tobiodegradable contaminants in soil. This alternative would haveminimal effect on future remedial actions. However, if the yardsare still functional upon commencement of remedial actions,implementation would impact Army activities by confining currentoperations to 80 percent of the yards until the Maintenance Yardsclose. An existing central soil treatment facility is notcurrently available; therefore, a facility will need to be sitedand constructed for soils from the Maintenance Yards.Construction of a facility with sufficient capacity to treat allof the soil at once would be difficult in terms of facilitysiting and other regulatory issues. Operation of the facilitywould be relatively simple and would not require skilledoperators, but may require bioremediation specialists to monitorperformance and troubleshoot on an as-needed basis.

Alternatives 7 and 8 would not be difficult to construct oroperate but pose aquifer protection concerns. Nutrients forAlternatives 7 and 8 would need to be monitored so as to notimpact either Grove Pond and its wetlands or the Grove Pond watersupply wells. Stormwater collection system expansion would alsobe an issue for Alternative 7, since this alternative entailscapping the entire site. Also, if further action is warranted ata later date, the paving may need to be removed. Alternative 8would have minimal impact on future actions. Alternative 7 willcreate similar disturbances within the yards as Alternative 3 dueto the installation of the bioventing system and stormwaterpiping and appurtenances, and the paving of the site.Alternative 8 will create similar disturbances within the yards


as Alternative 9 if the yards are still functioning uponcommencement of remedial activities.

7. Cost

A comparison of the estimated total present worth costs (based ona 10 percent discount) for each alternative is as follows:

Alternative

#1

#2

#3

#5

#7

#8

#9

Total Capital

$ 0

$ 204,000

$ 1,017,000

$ 1,865,000

$ 1,070,000

$ 621,000

$ 2,739,000

Total O&M (netpresent worth)

$ 133,000

$ 152,000

$ 204,000

$ 72,000

$ 478,000

$ 932,000

$ 659,000

Total Costs (netpresent worth

$ 133,000

$ 356,000

$ 1,221,000

$ 1,937,000

$ 1,548,000

$ 1,553,000

$ 3,398,000

Capital, O&M, and present worth costs for each alternative werecalculated within a range of accuracy of +50 percent to -30percent. The alternatives with the lowest capital costs arethose that include little remedial action, such as Alternatives1, 2, and 3, and those that utilize in-situ treatmenttechnologies (Alternatives 8 and 7). Alternatives 5 and 9, whichinvolve excavation and treatment of soil, require larger capital.O&M costs are computed on an annual basis, and are lowest forAlternative 5, which does not require long-term maintenance. O&Mcosts for Alternatives 1, 2, 3, and 5 include environmentalmonitoring for 5 years. Alternatives 7, 8, and 9 includeoperation of the treatment systems and groundwater monitoring forthe estimated duration of treatment.

Alternatives 1, 2 and 3 which have low capital costs, also havelower total present worth cost. Alternatives 7 and 8 have highpresent worth costs due to longer treatment durations;Alternative 5 has high costs due to treatment costs. Alternative9 is the most expensive due to treatment facility constructionand extended treatment duration.

8. State Acceptance

MADEP has been actively involved with the Maintenance Yardsduring the development of the SI, FS and this ROD.


MADEP provided comments on the Army's Preferred Alternativeduring the public hearing. In summary, MADEP believes thatAlternative 5 is the most protective of the proposedalternatives. MADEP expressed the desire that the Army excavateany grossly contaminated soil that is encountered, besides thetop two feet and the two hot spot areas. These would include anyareas where previous sampling has shown that soil below 2 feetwas contaminated above cleanup levels. MADEP also requested thatthe Army review their spill management plan for the MaintenanceYards to ensure that in the interim before remediation, there isa good management plan for spills and that the spill containmentpad is utilized to minimize the likelihood of furthercontaminating soils.

A summary of these and other MADEP comments, and the Army'sresponses, are included in the Responsiveness Summary attached asAppendix C to this ROD. The Commonwealth of Massachusetts hasindicated it's support for the remedy and the concurrence letteris located in Appendix D of this ROD.

9. Community Acceptance

The comments received by the community and local governments aresummarized and responded to in the Responsiveness Summaryattached to the ROD as Appendix C.

Comments were received from a merchant and two town officialsfrom the town of Ayer and representative of the Fort Devens ReuseCenter. Comments generally supported the Army's choice of theselected remedy.

X. THE SELECTED REMEDY

The remedy selected to address the contamination identified atthe Maintenance Yards is Alternative 5, Asphalt Batching theSite/Asphalt Batching the Hot Spot Areas. The remedy includesthe following components: excavating the top two feet of soilacross the site and the two hot spot areas; placing excavatedsoils in piles at the site for sampling and analysis; cold mixasphalt batching soils which exceed site cleanup levels;backfilling site excavations with stockpiled soil not found to becontaminated above cleanup levels and with the cold mix asphaltbatched material; expanding the existing stormwater collectionsystem including construction of detention pond(s); and applyinga pavement wearing course for a vehicle parking surface over theMaintenance Yards; performing groundwater monitoring; andinstituting deed restrictions to: prohibit residentialdevelopment/use of the Maintenance Yards, minimize thepossibility of long-term (working lifetime) exposure to


subsurface soils, and require management of soils resulting fromconstruction related activities.

The approximate cleanup timeframe for the selected remedy is fourmonths following commencement of remedial activities.

A. Soil Cleanup Levels

The FS investigated several methods for establishing a cleanuplevel to achieve a cancer risk that is within the USEPA Superfundtarget risk range. During a Draft FS Report review meeting withUSEPA and MADEP, a cleanup level of 7 ppm average total cPAHs wasselected for the FS Report from the computed target range. Thisvalue was arrived at assuming all cPAHs are as potent asbenzo(a)pyrene (the B[a]P approach), which was USEPA Region I'sstandard approach for computing risk estimates for cPAHs at thetime the quantitative risk evaluation was performed for theMaintenance Yards. This cleanup level for known and suspectcarcinogens (Classes A, B, and C compounds) achieves a 10excess cancer risk level considering exposures via dermal contactand incidental ingestion. (Although inhalation is a potentialexposure route, risk estimates indicate that it is aninsignificant contributor to the overall risk at the MaintenanceYards).

Since the development of the target level for cPAHs, USEPA viewstwo critical assumptions differently than at the time of the FS.The first assumption involves the use of the dermal exposureroute. Although benzo(a)pyrene has been known to cause skincancer, USEPA Region I no longer includes the dermal route ofexposure when developing target levels for cPAHs because ofinconclusive data. The second assumption involves assessing therelative toxicity of the cPAHs. The toxic equivalency factor(TEF) approach involves applying TEFs to cPAHs based on eachcompounds relative potency to that of benzo(a)pyrene.Toxicologists within USEPA Region I have reviewed the TEFapproach in light of USEPA provisional guidance and have recentlyaccepted the TEF method. To determine the effects of theseassumptions on the target levels presented in the FS, targetlevels were recalculated excluding the dermal route of exposureand applying the relative potency factors (TEF approach).Results are listed in the following table.


SOIL CLEANUP LEVELS FOR CPAHsVARIOUS COMPUTATION APPROACHES

Approach

USEPA B(a)P approach

USEPA TEF approach

Target Level (ppm) at 10"4 RiskAverage Total cPAH Concentrations

Ingestion/Dermal IngestionRoutes Route Only

6.4

23

78

1300

USEPA Region I has recently formally accepted the TEF approachfor new RI/FS sites where risk assessment is not substantiallyunderway or where the USEPA remedial project manager decides toreevaluate risk with the new approach. However, MADEP'sacceptance of the NCP risk assessment approach for the site iscontingent upon the dermal exposure pathway being utilized andthe TEF approach not being used, such that the cleanup level isconsistent with the Massachusetts Contingency Plan (MCP), 310 CMR40.0000 (November 19, 1994). Consequently, the cleanup level atthe Maintenance Yards will be 7 ppm average total cPAHs as wasselected in the FS Report.

It is noted that the CERCLA risk approach to risk assessmentsdoes not measure risk resulting from TPHC, which are acombination of a number of compounds often including cPAHcontaminants. Although not required to do so under CERCLA or theNCP, the Army has agreed, with MADEP approval, to establish TPHCcleanup levels for soils at the Maintenance Yards based onguidance from the MCP. The MCP establishes 500 ppm as thecleanup criteria for TPHC using MCP Method 1 and S-l Soil and GW-1 groundwater categories. As noted in the footnote to Table 2 inthe MCP regulations (310 CMR 40.0975(6) (a)), entitled "MCP Method1: Soil Category S-l Standards", the Method 1 S-l soil standardfor TPHC does not apply to benzene, toluene, ethylbenzene, andxylene (BTEX) compounds or specific PAH compounds. Therefore,the S-l soil standard for TPHC is used for AOC 44 and 52 soils inconjunction with the site-specific cleanup level for cPAHsidentified above. Benzene was not detected in AOC 44 and 52soil. As reported in Appendix A of the FS, the risks associatedwith toluene, ethylbenzene, and xylenes in AOC 44 and 52 soilsfall well outside the Superfund target HI of one; assuming workerexposure to the maximum detected concentrations of thesecompounds results in hazard quotients on the order of 3x10 orless. Use of the TPHC soil standard under the Method 1, S-l soiland GW-1 groundwater categories results in the most health-protective of the Method 1 standards. This is because S-l soil

RECORD OF DECISIONBarnum Road Maintenance Yards, AOCs 44 & 52 Pag« 44

is, by definition, the most accessible and therefore presents thegreatest potential for exposure, and GW-l groundwater is assumedto be potable.

Based on the Baseline Risk Evaluation in the FS Report, exposureto non-carcinogenic Classes D and E compounds are at anacceptable level to which the human population includingsensitive subgroups may be exposed without adverse affect duringa lifetime or part of a lifetime. Consequently no cleanup levelsfor these compounds were derived.

The cPAH and TPHC cleanup levels of 7 ppm average total cPAHs and500 ppm TPHC must be met at the completion of the remedial actionwithin the present fenced surface area of the Maintenance Yardsto a two-foot depth and in the two hot spot surface andsubsurface soil areas identified as the mogas spill area and theleaking UST area. The cleanup level for cPAHs attains USEPA'srisk management goal for remedial actions and has been determinedby USEPA to be protective of human health and the environment.The cleanup level for TPHC meets the requirement of the MADEP forthis contaminant.

B. Description of Remedial Components

The following is a description of the remedial components of theselected remedy for the Maintenance Yards:


levels,• Backfill excavations with uncontaminated stockpiled

soil and with the asphalt batched material,• Expand the existing stormwater collection system,• Apply a pavement wearing course,• Perform groundwater monitoring.• Institute deed restrictions to prohibit residential

development/use of the Maintenance Yards, minimize thepossibility of long-term (working lifetime) exposure tosubsurface soils, and require management of soilsresulting from construction related activities.

Excavate Surface Soils; Prior to commencement of the remedialdesign, predesign test pits will be excavated to better predictthe typical soil characteristics (color, texture, and presence ofpavement) and layers containing cPAHs that may be encounteredwhen the top 2 feet of soil is removed during remediation. Thispreview will enable planned optimization of soil excavation andhandling activities during remedial action; improve estimates on


the volume of soils that will require treatment; and provide soilgradation data for the asphalt batching design. Details of thesetest pitting activities will be provided in a predesign workplan.

It is proposed that the Maintenance Yards surface soils beexcavated in 6-inch layers down to a 2-foot depth, and stockpiledand sampled in 100-cy batches. Layers of other thickness may beexcavated depending on the observed thickness of layers in thetest pits. It is believed that layers with pavement will containthe highest concentration of cPAHs. If proven to be true fromtest pit results, this soil will be stockpiled separately. Soilswill be initially screened for visible and olfactory evidence ofwaste material or overtly contaminated soils. Soils observed tocontain broken pieces of pavement will be segregated as cPAH-contaminated soil in maximum 100 cy piles and kept in separatepiles for analytical screening. Soils with fuel odor or evidenceof petroleum contamination will also be separated from soil withno evidence of contamination.

All soil to a 2-foot depth will be excavated, stockpiled andsampled regardless of physical evidence of contamination. Thisamounts to a total unexcavated soil volume of approximately28,400 cy of soil. A topographic survey, to be performed as apredesign activity, will more accurately quantify the soil volumeto be excavated. Excavation sequence of surface soils andinstallation of utilities will be detailed in the design and/orContractors work plan.

An air monitoring program will be established to assess airquality during all excavation and soil handling activities. Airmonitoring will ensure that total suspended particulates (TSPs)do not exceed predetermined action levels. Details of thisprogram will be provided in the remedial design.

Excavate Hot Spot Areas; Trench exploration will first beperformed to include or exclude the boring 44B-93-10X area as thepotential mogas spill area. To initially identify the potentialhot spot area, trenches will be excavated over 44B-93-10X.Headspace screening by photoionization detector (PID) or NDIRModified Method 418.1 screening on the trench sidewalls. Thisarea will be excluded from further investigation and excavationif there is no detection of volatiles or if TPHC is not over 500ppm.

Trenches will also be excavated over boring 44B-92-06X toinitially define the extent of the hot spot area detected in thisarea. Headspace and NDIR screening will be performed onsidewalls and/or bottom of trench if staining is not evident.


The hot spot will then be fully excavated to the approximatedimensions as determined by the trench screening and excavationwill continue until laboratory analysis reveals concentrationsless than 500 ppm.

The hot spot area around the waste oil UST will also beexcavated. This area has been previously over-excavated andbackfilled with clean soil. The clean backfill soil in the over-excavated area will be excavated, segregated and sampled toensure clean backfill and native soil are clearly distinguished.Upon reaching native soil, excavation and sampling for TPHC willbe continue until laboratory analysis reveals concentrations lessthan 500 ppm.

Any other "hot spot areas" observed during the excavation of thesurface soils will be excavated, segregated, stockpiled andsampled in a similar manner as described in this ROD.

Depth of contamination is unknown in the hot spot areas. Forplanning purposes, contamination was assumed to extend to anaverage 17-foot depth. Details of the trenching, excavation andsampling for excavating the hot spot areas will be provided inthe remedial design.

Stockpiling and Sampling and Analysis; Soils excavated from hotspot areas will be placed on, and covered with, a minimum 8-milpolyethylene tarp to prevent mixing of TPHC contaminated soilswith clean soils. Surface soils will also be placed onpolyethylene tarpaulins if there is potential for soil tocontaminate clean soil. All stockpiling of soils will berestricted to the areas at the Maintenance Yards to be detailedin the design. Excavation work sequence in relation tostockpiling methods will be detailed in the Contractor's workplan. Stockpiling and analytical work will be done concurrentlyto minimize the duration that soils are left on-site. Jerseybarriers or concrete blocks may be used to separate piles ifrequired.

Sampling and analysis to classify stockpiled soils from hot spotand surface soil excavations as acceptable for reuse at the sitewithout treatment, will require collecting five soil subsamplesand field compositing to yield one sample for every 100 cy ofstockpiled soil or for every segregated stockpile, whicheversmaller in volume. Samples from hot spot stockpiled soils willbe analyzed in the field laboratory for TPHC using the ModifiedMethod 418.1 (NDIR). Samples from surface soil stockpiled soilswill be analyzed in the field laboratory for TPHC using theModified Method 418.1 (NDIR) and for the following seven cPAHsusing Modified Method 8270 (GC/MS) by a field laboratory:


Benzo(a)anthraceneBenzo(b)fluorantheneBenzo(k)fluorantheneBenzo(a)pyreneChryseneDibenzo(a,h)anthraceneIndeno(1,2,3-cd)pyrene

All analytical samples will be screened through a No. 20 sieve atthe laboratory to remove any pavement particles down to the sizeof coarse sand prior to performing the analysis.

Asphalt Batch Soils Exceeding Site Cleanup Levels: Stockpiledsoils with contaminants exceeding an average total cPAHconcentration of 7 ppm and 500 ppm TPHC, will be cold mix asphaltbatched on-site. Asphalt batching has been accepted by theregulators as a technology that is successful at immobilizingcompounds common in petroleum releases. As detailed in the FSReport, leaching of contaminants from asphalt batched soils hasbeen evaluated (with favorable results) by sampling groundwaterwells near stockpiled treated soils and by performing laboratoryleaching tests. Coupled with the formation of a relativelyimpermeable barrier, the chemical and physical fixation ofcontaminants by asphalt batching is considered to be protectiveof human health and effective in minimizing contaminant migrationto the groundwater. Asphalt batching site soils will immobilizethe contaminants exceeding cleanup levels present in the top twofeet, thus minimizing direct contact/ingestion of the soilshaving a carcinogenic risk. Asphalt batching the hot spot areasin the Cannibalization Yard will reduce the mobility of organiccontaminants present in the highest concentrations at the site.

The cold mix asphalt batching technology is performed at ambienttemperatures and entails recycling petroleum contaminated soilinto a bituminous paving or road base product. Excavated soilsmay be processed through a crusher or screen to produce aphysically uniform soil material. The soil may then be blendedwith other aggregate (if required due to existing soilconditions) and asphalt emulsion in a pugmill. Soil gradationresults and the pavement design will dictate soil preparationneeds. The finished product will be used as the base or subbasematerial for parking lot construction over the Maintenance Yards.For costing purposes the FS Report assumed that approximately17,000 cu yds (excavated volume) of surface and hot spot soilswill require asphalt batching. This estimate may be refined uponcompletion of the predesign test pit field work.

Backfill Excavations: Excavations will be backfilled with"clean" stockpiled soil and with the soils which have beenasphalt batched. Site soil will be classified as "clean" if it

RECORD OF DECISIONBarnum Road Maintenance Yards/ AOCs 44 & 52 Paga 48

meets the cleanup criteria of 500 ppm for TPHC and the risk-basedcleanup criteria of 7 ppm (average) for total cPAHs. This soilwill be used to refill a portion of the excavated areas at theMaintenance Yards. Preferably, upon receipt of analyticalresults, the soil will be immediately backfilled into designatedareas. If backfill areas are not available, the soil will bestored in designated piles separate from other soil for later useas on-site backfill. The asphalt batched material will then bespread and rolled to the thickness and contours to be detailed inthe final design and will serve as the subbase or base course forthe paved parking lot.

As an additional benefit, the asphalt batched material serves asa low-permeable barrier minimizing surface water infiltrationthrough site soils, thereby providing greater aquifer protection.The quantity of off-site aggregate and pavement required for theparking lot construction will be estimated in the remedial designbased on pavement design loads, soil gradation test results, arefined estimate of the soil requiring asphalt batching, sitegrading, and other design details. Contingencies will also beconsidered for pavement design should soils requiring asphaltbatching be more and less than anticipated.

Expand the Existing Stormwater Collection System; Constructionof the paved parking lot at the Maintenance Yards will increasethe amount of stormwater runoff during rain events. Therefore,the selected remedy will include expansion of the existingstormwater collection system including installation of additionalcatch basins, additional stormwater piping, and oil and greasetraps as required. Additionally, potential impacts to wetlandsat stormwater outfalls will be investigated and, as needed,minimized by construction of detention basins and flow reducers.

Prior to the design of this system, a predesign investigation ofthe existing stormwater system will be performed. To enabledeveloping a representative model of the system, informationrelating to the existing storm drainage system will be reviewedand field inspections will be made as necessary. The model willbe used to compute the current stormwater runoff flow and predictfuture stormwater flow after construction of the parking lot. Itwill also be used as a design tool by predicting the impact ofdetention pond(s) and other flow restriction devices on systemflows, enabling design criteria to be met. Details of thepredesign investigation work and the stormwater system expansionwill be provided in a predesign work plan and the remedial designrespectively.

Apply a Pavement Wearing Course: A paving wearing course is atop coat of pavement that is placed over a pavement base courseto provide a smooth, durable surface in high traffic areas. A


pavement wearing course placed over the batched material is not arequired remedial component for selected remedy. However, theArmy has chosen to add a pavement wearing course for a vehicleparking surface over the asphalt batched material as an ancillarycomponent. Addition of the wearing course will ensure theintegrity of the asphalt batched material as a parking lot basefor current and future property use.

Perform Groundwater Monitoring; The objective of groundwatermonitoring is to provide assurance to the public and theregulatory agencies that the groundwater in the aquiferunderlying the facility remains unaffected by past MaintenanceYard activities and that it has not been impacted by the remedialactivities. Sampling and analysis of groundwater from existingwells at the Maintenance Yards will be performed yearly for aperiod of five years upon commencement of remedial activities.Sampling will be for the same analytes tested for during the SI.Details of this program will be provided in the remedial design.

Institute Deed Restrictions: Institutional controls in the formof deed restrictions will be implemented to prevent potentialcircumstances which may result in risk of harm to health, safety,public welfare or the environment. These restrictions willinclude:

1. No residential development/use of the Maintenance Yards willbe permitted. The quantitative risk evaluation and establishedcleanup level assume the property will remain zoned forcommercial/industrial use.

2. Removal of the 2-foot cover or an asphaltic barrier from theMaintenance Yards will be prohibited to prevent surface soilexposure to existing subsurface soils (2-foot to 5-foot level).This deed restriction will be implemented as a precautionarymeasure to minimize the possibility of long-term (workinglifetime) exposure to subsurface soils. This restriction willnot apply to excavations undertaken in connection withconstruction of buildings or other structures, utilities,infrastructures or any other construction related purpose wherethe cover is penetrated and/or temporarily removed and protectionfrom long-term exposure to subsurface soil is not jeopardized.To comply with this deed restriction, the 2-foot layer of covermaterial (which may consist of one or combination of "clean" sitesoil used as backfill, asphalt batched material, off-sitesoils/aggregate and bituminous pavement) will remain over thesubsurface soil (existing 2- to 5-foot soil level) to minimizedirect contact/ingestion to the present subsurface soils. Thecontinuity of the paved surface need not be maintained providingthe cover thickness of 2 feet is provided. As an alternative, acontinuous and maintained paved surface which would prevent

RECORD OF DECISIONBarnum Road Maintenance Yards, AOCa 44 & 52 Page 50

exposure to subsurface soils could be substituted for the 2-footthick cover.

This restriction also would not apply to excavation and use thatis within the scope of any authorized response action. The deedrestriction may be nullified, as approved by the regulatoryagencies, should there be future evidence showing thatcontaminant levels within the 2- to 5-foot soil zone are belowsite surface soil cleanup levels.

3. Excavation below 2 feet at the Maintenance Yards, subsequentto completion of the remedial action established in this ROD,will require:

a. Development and implementation of a Health and SafetyPlan for the work area; and

b. Development and implementation of a Sampling andAnalysis Plan for management of the excavated soils inaccordance with the following:

Where reuse of soil within the Maintenance Yards isintended, sampling and analysis of stockpiled soilsexcavated below 2 feet will follow criteria detailed in thisROD for hot spot area soils. Soils with contaminantsexceeding the 500 ppm cleanup level for TPHC will be treatedin a manner consistent with this ROD. Soils withcontaminants below the established cleanup level may bereturned to the excavation. Soil excavated below 2 feet butreturned to the top 2 feet (as surface soil) must also besampled, analyzed and, if required, treated for cPAHcontaminants as detailed in this ROD.

Where reuse of soil outside the Maintenance Yards isintended, sampling/analysis and action levels for stockpiledsoils excavated below 2 feet will follow criteria governedby the regulations or policies in effect for the finaldisposal area.

C. Other Components of the Selected Remedy

To assure that the remedial action continues to protect humanhealth and the environment, and to the extent required by law,USEPA will review the operable unit at least once every fiveyears after the initiation of remedial action if any hazardoussubstances, pollutants or contaminants remain at the site. USEPAwill also review the operable unit before Fort Devens is proposedfor deletion from the NPL.


XI. STATUTORY DETERMINATIONS

The remedial action selected for implementation at theMaintenance Yards is consistent with CERCLA and, to the extentpracticable, the NCP. The selected remedy is protective of humanhealth and the environment, attains ARARs and is cost-effective.The selected remedy also satisfies the statutory preference fortreatment which permanently and significantly reduces themobility, toxicity or volume of hazardous substances as aprincipal element. Additionally, the selected remedy utilizesalternative treatment technologies or resource recoverytechnologies to the maximum extent practicable.

A. The Selected Remedy is Protective of Human Health andthe Environment

The remedy at the Maintenance Yards will permanently reduce therisks posed to human health and the environment by eliminating,reducing or controlling exposures to human and environmentalreceptors through treatment, engineering controls, andinstitutional controls. Specifically, the risk presented by theMaintenance Yards is from long-term (working lifetime) directcontact/ingestion of the surface soil containing cPAHs.Therefore, the selected remedy uses asphalt batching toimmobilize these carcinogenic contaminants, minimizing the toxiceffects on human health and the environment and the potential foroff-site run-off of contaminants. Additionally, asphalt batchingsoils from the hot spot areas will reduce the mobility of TPHCcontaminants present in the highest concentrations at the site.The stormwater system expansion and stormwater flow controls willbe used as engineering controls to manage increased stormwaterrunoff, resulting from the application of the low-impermeable(pavement) surface. Institutional controls are not needed tominimize human health risk, but will be utilized as aprecautionary measure to prohibit residential development,minimize the possibility of long-term (working lifetime) exposureto subsurface soils, and to require management of soils resultingfrom construction related activities.

Moreover, the selected remedy will achieve potential human healthrisk levels that attain the 10 to 10 incremental cancer riskrange for cPAHs.

B. The Selected Remedy Attains ARARs

This remedy will attain all applicable or relevant andappropriate federal and state requirements that apply to theSite. No waivers are required. ARARs for the Site wereidentified and discussed in the FS (Sections 1.7 and 6). Table19, in Appendix B of this ROD, presents a tabular summary of the

RECORD OF DECISIONBarn tun Road Maintenance Yards, AOCs 44 & 52 Page 52

ARARs for the selected remedy, including the regulatory citation,a brief summary of the requirement, and how it will be attained.The following is a summary of the key ARARs and how they pertainto the selected remedy:

Location Specific

Federal Standards:

National Environmental Policy Act; [40 CFR Part 6]. ThisARAR is applicable and pertains to the protection ofwetlands. It requires that Federal agencies minimize thedegradation, loss, or destruction of wetlands, and preserveand enhance natural and beneficial values of wetlands underExecutive Orders 11990 and 11988. The wetlands adjacent tothe Maintenance Yards may currently be impacted by surfacewater runoff via the storm water system. The selectedalternative covers the site with pavement, thus reducingpotential off-site runoff of contaminants in surface waterfrom soils at the Maintenance Yards to the wetlands. Theremedy will also be designed and constructed to manage theincreased flow from the paved surface in a manner that willminimize impact to adjacent wetlands.

Action Specific

State Standards;

Massachusetts Air Pollution Control Regulations; F310 CMR6.00 - 7.001. This ARAR is applicable and pertains toparticulate matter standards (Section 6.0) and applicationof toxic air pollutant control program requirements.Specifically, Section 6.04 provides ambient air qualitycriteria such as particulate matter standards which ispertinent to the Maintenance Yards remedial activity. As aminimum, respirable particulate matter (PM10) for treatmentand excavation activities must be maintained at an annualmean arithmetic concentration of 50 nq/m and a maximum 24-hour concentration of 150 Mg/n» . Section 7.02 providesemissions limitations from facilities and operations andrequires BACT. The emissions limits for particulate matterand fugitive emissions at the Maintenance Yards will bemanaged through engineering controls during excavation andtreatment activities.

Massachusetts Hazardous Waste Management Rules fMHWMR)Identification and Listing of Hazardous Wastes [310 CMR30.1001. This ARAR is applicable. The wastes found atthis site were determined not to be characteristic hazardous


wastes; however, waste oil is a listed hazardous waste underthis rule.

Massachusetts Hazardous Waste Management Rules (MHWMR^Provisions for Recyclable Material and for Waste Oil; [310CMR 30.2001 This ARAR is applicable and containsprocedural and substantive requirements for handlingregulated recyclable materials. The substantiverequirements include preventing and reporting releases tothe environment, proper maintenance of treatment and controlsystems, and handling of regulated recyclable materials.Asphalt batching of soil on site will comply with thesubstantive requirements of this regulation.

Massachusetts Hazardous Waste Management Rules (MHWMR) WastePiles; [310 CMR 30.640 - 30.6491. This ARAR is applicableand pertains to waste pile facilities. A waste pilefacility must install a liner, provide a leachate collectionsystem, provide a run-on/run-off control system, comply withthe groundwater monitoring requirements, performinspections, and close the facility properly. Theserequirements will be addressed in the design of an area forstockpiling of wastes for on-site treatment.

Massachusetts Hazardous Waste Management Rules (MHWMR)Groundwater Protection; P310 CMR 30.660 - 30.6791. ThisARAR is Relevant and Appropriate and pertains to groundwatermonitoring that is conducted during and following remedialactions. Concentration limits for the hazardous con-stituents are specified in 310 CMR 30.667. There is nocurrent evidence that contaminants associated with theMaintenance Yards have adversely affected the groundwaterquality. However, groundwater monitoring will be conductedas a component of the remedy specifically to provideassurance to the public and the regulatory agencies that thegroundwater in the aquifer underlying the facility remainsunaffected by past Maintenance Yard activities and that ithas not been impacted by the remedial activities.

The following guidance will also be considered (TBCs) duringimplementation of the remedial action:

Standards for Analytical Data for Remedial Response Action[WSC-300-891 This "To Be Considered" policy describes the

i minimum standards for analytical data submitted to thet* MADEP. All sampling plans will be designed with

consideration of the analytical methods provided in thisr non-promulgated advisory.

RECORD OF DECISIONBarnvun Road Maintenance Yards, AOCs 44 & 52 Page 54

C. The Selected Remedial Action is Cost-Effective

In the Army's judgment, the selected remedy is cost effective,i.e., the remedy affords overall effectiveness proportional toits costs. In selecting this remedy, once the Army identifiedalternatives that are protective of human health and theenvironment and that attain, or, as appropriate, waive ARARs, theArmy evaluated the overall effectiveness of each alternative byassessing the relevant three criteria -- long- term effectivenessand permanence; reduction in toxicity, mobility, and volumethrough treatment; and short-term effectiveness, in combination.The relationship of the overall effectiveness of this remedialalternative was determined to be proportional to its costs. Thecosts of this remedial alternative are specified in Table 18.

The Army, based upon USEPA guidance, evaluates cost-effectivenessonly in selecting a remedy from among protective alternatives.Alternatives 1, 2, and 3 in the FS are all less costly than theselected remedy. However, each of those alternatives allows thesurface soils to continue to pose an unacceptable risk for anexcessive time period. This is because each of thesealternatives relies solely on institutional controls in the areawhere risk is demonstrated to be outside USEPA1s acceptable riskrange. Since these alternatives are not sufficiently protective,their cost-effectiveness cannot be analyzed.

Alternative 9 in the FS is the most expensive alternative andalso the least cost-effective, assuming for comparison that soilstreated at the facility would be limited to Maintenance Yardssoils. Any enhanced protectiveness at the Maintenance Yardsprovided by Alternative 9 is not proportional to its additionalcosts. Institutional controls would still be required as aprecautionary measure to prevent future conditions fromdeveloping that may result in risk to human health or theenvironment. Additionally, Alternative 9 would not have thebenefit of providing greater aquifer protection as does theselected remedy through construction of the low-permeable(asphalt batched soil) layer.

Alternatives 7 and 8 are less expensive than the selected remedy,but may actually be less cost effective than the selected remedy.Alternative 7, bioventing, would require an estimated treatmenttime of 10 years, and based on FS treatability testing may not beeffective at cPAH reduction. Alternative 8, Landfarming, wouldrequire 5 to 7 years (depending upon the timing of the closure ofthe Maintenance Yards). It would present a greater short-termexposure to contaminants, and would not have the benefit ofproviding greater aquifer protection as does the selected remedy.

RECORD OF DECISIONBarnum Road Maintenance Yards, AQCs 44 & 52 Page 55

D. The Selected Remedy Utilizes Permanent Solutions andAlternative Treatment or Resource Recovery Technologiesto the Maximum Extent Practicable

Once the Army identified those alternatives that attain or, asappropriate, waive ARARs and that are protective of human healthand the environment, the Army identified which alternativeutilizes permanent solutions and alternative treatmenttechnologies or resource recovery technologies to the maximumextent practicable. This determination was made by decidingwhich one of the identified alternatives provides the bestbalance of trade-offs among alternatives in terms of: 1) long-term effectiveness and permanence; 2) reduction of toxicity,mobility or volume through treatment; 3) short-termeffectiveness; 4) implementability; and 5) cost. The balancingtest emphasizes long-term effectiveness and permanence and thereduction of toxicity, mobility and volume through treatment; andconsiders the preference for treatment as a principal element,the bias against off-site land disposal of untreated waste, andcommunity and state acceptance. The selected remedy provides thebest balance of trade-offs among the alternatives.

The Army believes that the selected remedy and Alternatives 7, 8,and 9 compare similarly in terms of long-term effectiveness andpermanence, and reduction of toxicity, mobility, or volumethrough treatment. The selected remedy and Alternatives 7, 8,and 9 all use treatment technologies to permanently andirreversibly immobilize or destroy cPAHs in the surface soils.The selected remedy does not reduce risk by destroying orremoving organic contaminants as do the other three alternatives.However, the selected remedy does immobilize the contaminants inthe asphalt batching process and the resultant material is usedon-site as pavement. As a side benefit, this low-permeablepavement layer provides greater long-term protection ofgroundwater. Alternative 7 also involves construction of apavement surface (low-permeable layer) but requires applicationof nutrients to the soil which is a potential threat to theaquifer below the site.

The selected remedy requires the shortest period of time (fourmonths) for remediation, thereby potentially impacting thesurrounding community, workers and the environment for the leastduration. Alternative 7 would also have minimal impact on thecommunity, workers and environment because remediation would takeplace in-situ. However, remediation would take approximately 10years and would require application of nutrients to the soilwhich would be a potential threat to the aquifer during thisentire period. Alternative 8 requires five to seven years ofremediation at the site depending upon the timing of theMaintenance Yard closure. Alternative 9 requires approximately


three months on-site activity and up to four years forbiodegradation of contaminants at a central soil treatmentfacility.

The selected remedy is the easiest to implement, involving commonconstruction practices. Alternative 9 requires siting andconstruction of an off-site soil treatment facility which couldbe difficult in terms of facility siting and other regulatoryissues including reuse of treated soils in a manner compliantwith current regulations. Alternatives 7 and 8 would not bedifficult to construct or operate, but pose difficultiesadministratively due to aquifer protection concerns. Theselected remedy is less expensive than Alternative 9 but moreexpensive than Alternatives 7 and 8. As previously discussed inParagraph C, any enhanced protectiveness at the Maintenance Yardsprovided by Alternative 9 is not proportional to the requiredadditional $1,461,000 expenditures.

As described in more detail in the Responsiveness Summary, stateand community comments generally support the Army's choice of theselected remedy. Considering such support, and based on theabove analysis of statutory criteria, the Army believes that theselected remedy utilizes permanent solutions and alternativetreatment or resource recovery technologies to the maximum extentpracticable.

E. The Selected Remedy Satisfies the Preference forTreatment which Permanently and Significantly reducesthe Toxicity, Mobility or Volume of the HazardousSubstances as a Principal Element

The principal element of the selected remedy is source control.This element addresses the primary threat at the MaintenanceYards, which is the threat of ingestion or contact withcontaminated surface soils. The selected remedy satisfies thestatutory preference for treatment as a principal element bytreating the contaminants in the surface soils and hot spotareas, thereby providing significant reduction in the toxicityand mobility cf the contaminants. Therefore, the selected remedysatisfies the statutory preference for treatment as a principalelement.

XII. DOCUMENTATION OF NO SIGNIFICANT CHANGES

The Army presented a proposed plan (preferred alternative) forremediation of the site on May 16, 1994. The components of thepreferred alternative included:


• Excavating surface soil (top two feet across the site),• Excavating the two hot spot areas,• Stockpiling soils for sampling and analysis,• Cold mix asphalt batching soils exceeding site cleanup

levels,• Backfilling excavations with stockpiled soil not found

to be contaminated above cleanup levels and with theasphalt batched material,

• Expanding the existing stormwater collection system,• Applying a pavement wearing course,• Performing groundwater monitoring.• Instituting deed restrictions to either prohibit

removal of the top 2-foot cover or requiring a physicalbarrier over the present subsurface soils (existing 2-to 5-foot soil level).

The selected remedy contains no significant changes from thatproposed in the Proposed Plan. It is noted however, thatadditional deed restrictions have been added. The additionaldeed restrictions prohibit residential use and require sampling,analysis and management of soils resulting from constructionrelated excavations.

An additional change concerns the computed acreage of theMaintenance Yards. The Proposed Plan states that the area of theMaintenance Yards is approximately 8.8 acres. A topographicsurvey of the yards performed in July 1994 revealed that thetotal area is 8.1 acres (7.8 acres excluding the spillcontainment basin area).

It is also noted that the U.S. Army Center for Health Promotionand Preventative Medicine (USACHPPM) conducted a survey in thefall of 1994 to establish the history of radioactive sources atFort Devens. The locations and activities of sources, and theuses or accidents that may have contaminated areas at Fort Devenswere presented by USACHPPM in a November 7, 1994 report entitled"Industrial Radiation Historical Data Review No. 27-43-E3QX-95Fort Devens Massachusetts." This report identified theCannibalization Yard and the TDA Maintenance Yard as areas withpotential radioactive contamination. Vehicles and equipment withradium dials, depleted uranium armor, and radioluminescent paintwere once stored in the TDA Maintenance and Cannibalization Yardsbefore being dismantled in the Cannibalization Yard for usableparts. To determine if any release of radioactive materialoccurred, a scanning survey and soil sampling program wereconducted from December 11 to 15, 1994. Scanning and sampling ofsurface soils were performed in accordance with the "FinalRadiological Work Plan, AOCs 44 & 52, Barnum Road MaintenanceYards, Fort Devens, Massachusetts", dated December 14, 1994.Investigation results are detailed in the "Final Radiological

RECORD OF DECISIONBarnum Road Maintenance Yards/ ROCs 44 & 52 Page 58

Status Report For Cannibalization Yard & TDA Maintenance Yard,Fort Devens, Massachusetts" dated March 1995. Results show thatthe Cannibalization Yard and TDA Maintenance Yard were well belowthe levels which pose a risk, and therefore meet the requirementsfor unrestricted use in accordance with U.S. Nuclear RegulatoryCommission guidelines. The USACHPPM data review report, theradiological work plan and the final radiological status reportcan be found in the Administrative Record.

XIII. STATE ROLE

The Commonwealth of Massachusetts has reviewed the variousalternatives and has concurred with the selected remedy for theMaintenance Yards. The state has also reviewed the SI, RiskEvaluation and FS to determine if the selected remedy is incompliance with applicable or relevant and appropriate stateenvironmental laws and regulations. A copy of the declaration ofconcurrence is attached as Appendix D.

zDX

BARNUM ROAD MAINTENANCE YARDSAOCS 44 & 52ROD SUMMARY

APPENDIX A

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SOIL CONTAMINANT RELEASE ANALYSIS - FUGITIVE DUST

BASED ON NATIONAL AMBIENT AJR QUALITY STANDARD (NAAQS)

FOR RESPIRABLE PARTICLES (PM10) (1)

AOCs 44 AND 52 - AVERAGE SOIL CONCENTRATIONS

FORT DEVENS. MA

CONTAMINANT

1

Carcinogens

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Benzo(a)pyrene

Bcnzo(b)fluoranthene

Benzo(k)fluoranthene

Carbazole

Chrysene

Dibenz(a.h)anthracene

Indeno( 1 .23 - cd)pyrene

Arsenic

Beryllium

Lead

Cadmium

Chromium VI (3)

Nickel

' Noncarcinogeni

| Ethylbenzene

Toluene

Xylenes

2-Methylnaphthalene

Acenaphthene

Acenaphlhylene

Anthracene

Benzo(gJu)perylene

Dibenzofuran

Fluoranthene

Fluorene

Naphthalene

Phenanthrene

Pyrene

Barium

Copper

Chromium III (3)

Iron

SOIL FUGITIVE DUST FUGITIVE DUST

CONCENTRATION NAAQS CONCENTRATION (2)

(mg/kg) (ug/nr3) (mg/m3)

1.941

2.078

2.241

2.318

1.658

0.621

2.581

0.782

2.001

12.36

0.514

10.188

0.635

1.719

15.299

0.000936

0.000441

0.00129

0.267

0.235

0.297

0.742

1.839

0.327

5.044

0.564

0.554

3.658

3.405

24.907

8.885

15.473

8547.391

50

50

50

50

50

50

50

50

50

50

50

50

50

50

50

50

50

50

50

50

50

50

50

50

50

50

50

50

50

50

50

50

50

971E-08

104E-0-

1 12E-fT

1 16E-0"

S29E-08

3 HE-OS129E-07

3.91E-08

100E-07

61SE-07

2.57E-08

509E-0"

3 18E-08

860E-08

7.65E-07

4.68E-H

2.21E-11

6.45E-11

1 34E-08

1.18E-08

1.49E-08

3.71E-OS

920E-08

1.64E-08

2.52E-07

2.82E-08

2.77E-08

1.83E-07

1.70E-07 '

1.25E-06

4.44E-071

!7.74E-07

4.27E-04-

DUST-NAQ.WK1

0 0 0 0 4 8

TABLE 13. continued


BASED ON NATIONAL AMBIENT AIR QUALITY STANDARD (NAAQS)

FOR RESPIRABLE PARTICLES (PM10)(1)


FORT DEVENS. MA

CONTAMINANT

Magnesium

Manganese

Potassium

Sodium

Vanadium

Zinc

SOIL

CONCENTRATION

(mg/kg)

2504.574

154.293

1008.659

155.042

10.942

26.532

FUGITIVE DUST

NAAQS

(ug/m3)

50

50

50

50

50

50

FUGITIVE DUST

CONCENTRATION (2)

(mg/m )

1.25E-04

7.71E-06

5.04E-05

7.75E-06

5.47E-fP

1.33E-06

(1) The National Ambient Air Quality Standard for respirable particulars

(PM10) is 50 ug/m3 (annual arithmetic mean concentration)

(2) Fugitive Dust Concentration (mg/m ) = (Soil Concentration (mg/kg) x

NAAQS for Fugitive Dust (mg/m3)]/! * 109 ug/Vg

(3) The total chromium concentration (17.192 mg/kg) was divided into 90% chromium III and

10% chromium VI (a carcinogen via inhalation).

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TABLE 15



FOR TOTAL RESPIRABLE PARTICLES - 24 HOUR MAXIMUM/ONCE PER YEAR (I)


FORT DEVENS. MA

j CONTAMINANT

Carcinogens

Bis(2 - ethylhexyl)phthalate

Be azo( a (anthracene

Benzo(a)pyrene

Benzo(b)fluoranthene

; Benzo(k)fluoranthene

'. Carbazole

Chrysene

Dibenz(a.h)anthracene

Indeno( 1 .2 3 -cd)pyrene

Arsenic

Beryllium

Lead

Cadmium

Chromium VI (3)

Nickel

Noncarcinogens

Ethylbenzene

; Toluene

Xylenes

2- Methylnaphthalene

Acenaphthene

Acenaphlhylene

Anthracene

Benzo(gjia)perylene

Dibenzofuran

Fluoranthene

Fluorene

Naphthalene

Phenanthrene

Pyrene

Barium

Copper

Chromium III (3)

Iron

SOIL

CONCENTRATION

(mgftg)

1.941

2.078

2.241

2.318

1.658

0.621

2.581

0.782

2.001

12.36

0.514

10.188

0.635

1.719

15.299

0.000936

0.000441

0.00129

0.267

0.235

0.297

0.742

1.839

0.327

5.044

0.564

0.554

3.658

3.405

24.907

8.885

15.473

8547.391

FUGITIVE DUST FUGITIVE DUST

NAAQS CONCENTRATION (2)

(ug/m3) (mg/m3)

150

150

150

150

150

150

150

150

150

150

150

150

150

150

150

150

150

150

150

150

150

150

150

150

150

150

150

150

150

150

150

150

150

2.91E-07

3.12E-07

3.36E-07

3.48E-0"

2.49E-07

9.32E-08

3.87E-07

1.17E-07

3.00E-07

I.S5E-06

7.71E-08

1.53E-06

9.53E-08

2.58E-07

2.29E-06

1.40E-10

6.62E-11

1.94E-10

4.01E-08

3.53E-08

4.46E-08

1.11E-07

2.76E-07

4.91E-08

7.57E-07

8.46E-08 i8.31E-08'

5.49E-07

5.11E-07,

3.74E-06 !

1.33E-06

2.32E-06

1.28E-03

DST-NAQT.WK1

0 0 0 0 5 4

TABLE 15, continued



FOR TOTAL RESPIRABLE PARTICLES - 24 HOUR MAXIMUM/ONCE PER YEAR (1)


FORTDEVENS MA

CONTAMINANT

Magnesium

Manganese

Potassium

Sodium

Vanadium

Zinc

SOIL

CONCENTRATION

(mg/kg)2504 574

154 293

1008 659

155042

10942

26532

FUGITIVE DUST

NAAQS

(ugfo3)

150

150

150

150

150

150

FUGITIVE DUST

CONCENTRATION (2)

(mg/nr)

3'6E-04

231E-0<

1 ME-04

2^3E-0-;

1 64E-06

398E-06

(1) The National Ambient Air Quality Standard for the concentration of total respirable particulates (PM10)

in a 24-hour period not to be exceeded more than once per year is 150 ug'm

(2) Fugitive Dust Concentration (mg/m-'') = [Soil Concentration (mg/kg) x

NAAQS for Fugitive Dust (mgAn3)]/! T 109 ugVg

(3) The total chromium concentration (17 192 mg.'kg) was divided into 90% chromium III and

10% chromium VI (a carcinogen via inhalation)

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TABLE 18SELECTED REMEDY

COST ESTIMATEALTERNATIVE 5: ASPHALT BATCH SITE/ASPHALT BATCH HOT SPOT AREAS

AOCS 44 & 52 - MAINTENANCE YARDSFORT DEVENS, MASSACHUSETTS

ITEM COST PRESENT WORTH

Capital Costs

Asphalt Batch Site and Hot Spot AreasExcavationAsphalt BatchingAnalyticalSite Restoration (includes pavementwearing course)

Expansion of Stormwater Collection System(see Table 6-7)

Air Monitoring

Total Capital Costs

S 134,00051,072,000S 116,000S 327.00051,649,000

5145,000

571,000

51,865,000

51,649,000

5145,000

571,000

51,865,000

Annual Operation and Maintenance Costs

Groundwater Monitoring (See Table 6-3)

Total Operation and Maintenance Cost

TOTAL PRESENT WORTH COST

519,000

519,000

572,000"

572,000

51,937,000

NOTE:Costs include 25% contingency. Costs rounded1 Present worth based on 10% interest rate and

to nearest $1,000.duration of 5 years.

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APPENDIX C

RESPONSIVENESS SUMMARY

f00064

United States Department of the Army

S U P E R P U N D

Responsiveness SummaryBarnum Road Maintenance Yards Site - AOCs 44 & 52

March 1995

0 0 0 0 6 5

RESPONSIVENESS SUMMARY Page 1Barnum Road Maintenance Yards - AOCs 44 & 52

INTRODUCTION

The United States Department of the Army (Army) held a 30-daycomment period from May 25 to June 24, 1994. This comment periodprovided an opportunity for interested parties to comment on theProposed Plan, the Feasibility Study (FS) and other documents(included in the Administrative Record), which have beendeveloped to address the cleanup of the unsaturated soils at theBarnum Road Maintenance Yards - Areas of Contamination (AOCs) 44& 52 at Fort Devens, Massachusetts. The Proposed Planspecifically addresses cleanup of the surface soils and twosubsurface "hot spot" areas. The FS examined and evaluatedvarious options (referred to as remedial alternatives), whichaddress human health risk from exposure to these soils andpotential migration of substances present in the soil at AOCs 44& 52. The Army identified its preferred alternative for AOCs 44& 52 in the Proposed Plan issued on May 16, 1994. All supportingdocumentation for the decision regarding AOCs 44 & 52 is placedin the Administrative Record for review. The AdministrativeRecord is a collection of all the documents considered by theArmy in choosing the remedy for AOCs 44 & 52. It was madeavailable at the Fort Devens Base Realignment and Closure (BRAC)Environmental Office, Building P12, Fort Devens, and at the AyerTown Hall, Main Street, Ayer. An index to the AdministrativeRecord was made available at the United States EnvironmentalProtection Agency (USEPA) Records Center, 90 Canal Street, BostonMA and is provided as Appendix E to the Record of Decision.

The purpose of this Responsiveness Summary is to document Armyresponses to the questions and comments raised during the publiccomment period on the FS, Proposed Plan, and other documents inthe Administrative Record. The Army and USEPA reviewed andconsidered the comments prior to selecting the remedy for AOCs 44& 52 which is documented in this Record of Decision.

The comments received by the community and local governments aresummarized and responded to in this Responsiveness Summary.Comments from the public were received from a merchant and twotown officials from the town of Ayer and a representative of theFort Devens Reuse Center. Comments were also received from theMassachusetts Department of Environmental Protection (MADEP).Comments generally supported the Army's choice of the selectedremedy. Concern was also expressed over the proximity of AOCs 44& 52 to the Grove Pond drinking water wells.

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This Responsiveness Summary is organized into the followingsections:

I. Overview of Remedial Alternatives Considered in the FSIncluding the Selected Remedy - This section brieflyoutlines the remedial alternatives evaluated in detail inthe FS and the Proposed Plan, including the Army's selectedremedy.

II. Background on Community Involvement - This section providesa brief history of community involvement and Armyinitiatives in apprising the community of Site activities.

III. Summary of Comments Received During the Public CommentPeriod and Army Responses - This section provides Armyresponses to the verbal and written comments received fromthe public and not formally responded to during the publicmeeting. A transcript of the public meeting consisting ofall comments received during this meeting and the Army'sresponses to these comments are provided in Attachment A ofthis Responsiveness Summary.

*********

I. Overview of Remedial Alternatives Considered in theFeasibility Study Including the Selected Remedy

Eleven alternatives were initially developed in the FS Report.Of the eleven alternatives, seven were retained in the FSscreening step and were evaluated in detail. The sevenalternatives are:

• Alternative 1: No Action (as required by the NationalContingency Plan)The No Action Alternative includes sampling ofgroundwater monitoring wells and stormwater catchbasins located within and downgradient of theMaintenance Yards for up to five years. The No ActionAlternative does not involve remedial actions tocontrol migration of substances or institutionalcontrols to prevent exposure to affected soils withinthe Maintenance Yards.

• Alternative 2; Fencing/Asphalt Batching Hot Spot AreasThis alternative includes preventing access bymaintaining fencing around the site that would limitpotential exposure pathways. Deed and land userestrictions would be implemented to ensure that the

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fence remained intact in the future. Excavating andasphalt batching the hot spot area soils using an on-site cold-mix process would reduce the volume ofcompounds present in the highest concentrations at theAOCs. Asphalt batched material from the hot spotswould be used as paving base material at the site.Sampling and analysis of groundwater, stormwater andsediments within or downgradient of the MaintenanceYards would also be performed to monitor for off-sitemigration of compounds.

• Alternative 3; Capping Site/Asphalt Batching Hot SpotAreasThis alternative entails excavating and asphaltbatching the hot spot area soils, expanding theexisting stormwater collection system includingconstruction of detention pond(s), capping the entiresite with asphalt pavement, and groundwater monitoring.Deed and land use restrictions would be implemented toensure that the cap remained intact in the future tominimize exposure to surface soils. Excavating andasphalt batching hot spot area soils in theCannibalization Yard would reduce the volume ofcompounds present in the highest concentrations at theAOCs. Asphalt batched material from the hot spotswould be used as paving base material at the site.Sampling and analysis of groundwater within ordowngradient of the Maintenance Yards would also beperformed to monitor for migration of compounds to thegroundwater.

The Army's Selected Remedy is Alternative 5.

• Alternative 5: Asphalt Batching Site/Asphalt BatchingHot Spot AreasAlternative 5 involves excavating the top two feet ofsoil across the site and the two hot spot areas;placing excavated soils in piles at the site forsampling and analysis; cold mix asphalt batching thesesoils which exceed (do not meet) site cleanup levels;backfilling site excavations with stockpiled soilhaving compound concentrations below cleanup levels,followed by placement of the cold mix asphalt batchedmaterial; expanding the existing stormwater collectionsystem including construction of detention pond(s);applying a pavement wearing course for a vehicleparking surface over the Maintenance Yards; andperforming groundwater monitoring. Alternative 5 will

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immobilize the petroleum substances in the top two feetof soil which exceed (do not meet) cleanup levels, thusminimizing direct contact/ingestion and inhalation ofthe soils. Excavating and asphalt batching hot spotareas in the Cannibalization Yard will reduce themobility of organic compounds present in the highestconcentrations at the site. Additionally,Alternative 5 minimizes the potential of petroleumsubstances migrating off-site.

The proposed pavement wearing course is not a requiredcomponent of the Alternative 5 that is evaluated in theFS Report. The Army has chosen to add this componentto Alternative 5 as part of the preferred alternativeto ensure the integrity of the asphalt batched materialas a parking lot base for current and future propertyuse.

Also, as discussed in the ROD, deed restrictions willbe instituted to prohibit residential development,minimize the possibility of long-term (workinglifetime) exposure to subsurface soils, and requiremanagement of soils resulting from construction relatedactivities.

Alternative 7; Bioventinq Site and Hot Spot AreasThis alternative involves bioventing the entire siteand the hot spot areas, and performing groundwatermonitoring. This alternative includes initial nutrientinjection in the areas by tractor and installation ofapproximately 20 bioventing wells, with associatedpiping, blower, and humidifier. An asphalt pavementcap would be installed over the entire area of the AOCsto prevent short circuiting of air. Bioventing wouldreduce the compounds present in the top two feet, thusminimizing direct contact/ingestion and inhalation ofthe surface soils. Additionally, the concentration ofthe compounds would be reduced in depths down toapproximately 10 feet over the site area. Sampling andanalysis of groundwater within or downgradient of theMaintenance Yards would also be performed to monitorfor any migration of substances to the groundwater. Asdetailed in the ROD, a deed restriction would beinstituted to prohibit residential development withinthe Maintenance Yards.

OOQ069


• Alternative 8; Landfarming Site/Excavating andLandfarminq Hot Spot AreasThis alternative includes mechanically screening outthe asphalt pavement pieces from surface soil,landfarming the entire area of the AOCs, excavating andlandfarming the hot spot area soils that exceed (do notmeet) cleanup levels, and performing groundwatermonitoring. The landfarming process involves applyingnutrients and moisture to the soil. The soil is tilledusing disk plows or rototillers to mix and aerate thesoil which encourages naturally occurring soil bacteriato degrade and stabilize the petroleum compounds.Landfarming will reduce the compounds present in thetop two feet of soil, thus minimizing directcontact/ingestion and inhalation of the soils.Additionally, the concentration of compounds could bereduced in depths below 2 feet over the site area byapplying excess nutrients and water to the soilsurface. Deed restrictions would also be applied asdescribed in Alternative 5.

• Alternative 9; Treatment of Site and Hot Spot AreaSoils at a Central Soil Treatment FacilityAlternative 9 entails excavating the top two feet ofsoil across the site and the two hot spot areas;placing excavated soils in piles at the site forsampling and analysis; transporting soils which exceed(do not meet) site cleanup levels to a central soiltreatment facility on base; and performing groundwatermonitoring at the Maintenance Yards. As a pre-treatment process, surface soil in areas of the sitecontaining bituminous pavement pieces would be screenedmechanically to remove large sized fragments. Thetreatment methods to be used at the central soiltreatment facility would be windrow composting and coldmix asphalt batching. Alternative 9 would reduce thecompounds present in the top two feet of soil and hotspot areas excavated. Deed restrictions would also beapplied as described in Alternative 5.

It will take approximately four months to clean-up the site onceconstruction activities on-site have started.

II. Background on Community Involvement

Throughout the Site's history, community concern and involvementhas generally centered around the fact that the Maintenance Yardsare located in close proximity to the town of Ayer Grove Pond

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wells. The Army has kept the community and other interestedparties apprised of site activities through regular and frequentinformational meetings, fact sheets, press releases and publicmeetings.

The Army released a community relations plan in February 1992,that had been submitted earlier for public review, outlining aprogram to address community concerns, and to keep citizensinformed about and involved in activities during remedialactivities. As part of this plan, the Army established aTechnical Review Committee (TRC) in early 1992. The TRC, asrequired by SARA Section 211 and Army Regulation 200-1, includesrepresentatives from USEPA, USAEC, Fort Devens, MADEP, localofficials and the community. The committee generally metquarterly (until January 1994, when it was replaced by theRestoration Advisory Board [RAB]) to review and provide technicalcomments on work products, schedules, work plans and proposedactivities for the SAs at Fort Devens. The SI and FS Reports,Proposed Plan and other related support documents were allsubmitted to the TRC for their review and comment. Additionally,AOCs 44 & 52 activity was specifically discussed at TRC meetingsheld March 24, 1992, January 5, 1993, August 2, 1993 and January26, 1994.

As part of the Army's commitment to involving the affectedcommunities, a. RAB is formed when an installation closureinvolves transfer of property to the community. The RAB wasformed in February 1994 to add members of the Citizen's AdvisoryCommittee (CAC) with current TRC members. The CAC was previouslyestablished to address Massachusetts Environmental Policy Act(MEPA)/Environmental Assessment issues concerning the reuse ofproperty at Fort Devens. The RAB consists of 28 members (15original TRC members plus 13 new members) who are representativesfrom the Army, USEPA Region I, MADEP, local governments andcitizens of the local communities. It meets monthly and providesadvice to the installation and regulatory agencies on Fort Devenscleanup programs. Specific responsibilities include: addressingcleanup issues such as land use and cleanup goals; reviewingplans and documents; identifying proposed requirements andpriorities; arid conducting regular meetings which are open to thepublic. The proposed plan for AOCs 44 & 52 was presented at theJune 2, 1994 RAB meeting.

On May 16, 1994, the Army issued a fact sheet to more than 100citizens and organizations, providing the public with a briefexplanation of the preferred alternative for cleanup of theMaintenance Yards. It described the opportunities for publicparticipation, and provided details on the public comment period

00007 1


and public meetings to be held.

On May 16, the Army issued a press release concerning theproposed cleanup at the Maintenance Yards, to the Lowell Sun,Worcester Telegram, Fitchburg-Leominster Sentinel & Enterprise,Harvard Post, Public Spirit (Ayer) and Fort Devens Dispatch.During the week of June 6, 1994, the Army published a publicnotice concerning the Proposed Plan and public hearing in thePublic Spirit, the Fitchburg-Leominster Sentinel & Enterprise,the Lowell Sun, and the Fort Devens Dispatch. The Army also madethe plan available to the public at the information repositorieslocated at the libraries in Ayer, Shirley, Lancaster, Harvard andat Fort Devens.

On May 24, 1994, the Army held an informal informational meetingat Fort Devens to discuss the results of the field investigationand the cleanup alternatives presented in the FS and to presentthe Army's Proposed Plan. This meeting also provided theopportunity for open discussion concerning the proposed cleanup.From May 25 to June 24, 1994, the Army held a 30-day publiccomment period to accept public comments on the alternativespresented in the FS and the Proposed Plan and on other documentsreleased to the public. On June 15, 1994 the Army held a formalpublic meeting at Fort Devens to discuss the Proposed Plan and toaccept any verbal comments from the public. A transcript of thismeeting and the comments and the Army's response to comments areincluded in this responsiveness summary.

All supporting documentation for the decision regarding theMaintenance Yards is placed in the Administrative Record forreview. The Administrative Record is a collection of all thedocuments considered by the Army in choosing the remedy for theMaintenance Yards. On May 27, 1994 the Army made theAdministrative Record available for public review at the FortDevens BRAG Environmental Office, and at the Ayer Town Hall,Ayer, Massachusetts. An index to the Administrative Record wasavailable at the USEPA Records Center, 90 Canal Street, Boston,Massachusetts and is provided as Appendix E.

III. Summary of Comments Received During the Public CommentPeriod and Army Responses

Comments la through Id: The current chairman of the Ayer Boardof Selectmen expressed her belief that proper notification wasnot received by the town of Ayer regarding the Proposed Plan forremediation of the Barnum Road Maintenance Yards. Also, she hadheard that to save money there was a change in plans for cleanupof the site from what was proposed many months ago, or maybe a

000072


year ago. The chairman specifically stressed the importance ofthe town's involvement due to the recent vote by the people ofAyer to reconstruct a well at Grove Pond downgradient of theMaintenance Yards. Specific questions relating to the abovegeneral concerns were:

• Comment la: How many feet from the Grove Pond well isthis hot spot that you're talking about?

Army Response: During the public hearing the Armyresponded that it was over 2,000 feet but an exactfigure was not available. A more precise distancebetween the Grove Pond wells and the Maintenance Yardsis approximately 2,200 feet. The proposed cleanup ofthe Maintenance Yards, as detailed in the FS andProposed Plan, focuses on surface soils (0 to 2 feetbelow ground surface) which have been affected byreleases of gasoline, motor oil, and other automotivefluids and includes two "hot spots": 1) surface andsubsurface (below 2 feet) soils associated with areported release of "mogas" (motor vehicle gasoline) in1985, and 2) subsurface soils associated with leakagefrom a 1,000-gallon underground waste oil storage tankwhich was removed in May 1992.

• Comment Ib: Were you aware when you [selected theremedy] that the Grove Pond wells were going to bereused?

Army Response: The Army was aware that the town ofAyer was considering returning its potable water supplywells on Grove Pond to regular service. Protection ofthis aquifer was a major consideration in developingremedial alternatives, proposing a preferredalternative for public comment, and selecting theremedy. The FS and Proposed Plan discuss the potentialredevelopment of these wells and delineate the Zone IIarea of influence (zone of contribution to the wellsunder the most severe pumping and recharge conditionsthat can be anticipated realistically). AOCs 44 & 52are located within this Zone II area as defined in areport prepared for the town of Ayer entitled "Town ofAyer, Massachusetts Grove Pond Wells HydrogeologicInvestigation and Zone II Aquifer Mapping" by the townof Ayer's consultant, Camp, Dresser & McKee, Inc.(1993) .

000073


r • Comment Ic: How much conversation has there been with, the town of Ayer about what you have contemplated

doing, and who have you been talking to in Ayer?

Army Response: Section II of this ResponsivenessSummary describes the Army's actions taken to informthe public about the environmental restoration of theMaintenance Yards. The SI and FS Reports, ProposedPlan and other related support documents were allsubmitted to the TRC for review and comment. TRCmembers from the town of Ayer have included the formerand current Superintendent of Public Works, and NashobaAssociated Boards of Health, Environmental HealthDivision representative. The Fact Sheet (issued to thepublic to describe the preferred alternative andopportunities for public participation in the cleanupplan) was mailed to more than 100 citizens andorganizations. Included in this mailing were thefollowing officials and/or affiliations for the town ofAyer: the above TRC members, the Executive Director ofthe Ayer Chamber of Commerce, the Ayer Board of Health,the Chairman of the Board of Selectmen, the ExecutiveSecretary, the Conservation Commission, the Water BylawCommission Chairperson, the Joint Boards of Selectmen,and six other citizens/merchants of the town of Ayer.

• Comment Id: The town needs an explanation of why therehas been a change [in plans for cleanup of the sitefrom what was proposed many months ago or maybe a yearago] .

• Army Response: At least two other remedialalternatives detailed in the FS Report were evaluatedas a possible preferred alternative and then changed oreliminated in favor of another alternative, prior toofficially issuing the final Proposed Plan to thepublic. At one time in the evaluation process,Alternative 8 - Landfarming the Site and Excavating andLandfarming Hot Spot Areas, was considered a possiblepreferred alternative. This alternative was eliminatedprincipally due to the proximity of the Grove Pondwater supply wells and recommendation by the MADEPCentral Regional Office Water Supply Section.Landfarming requires applying nutrients to the soil andthere was concern of nitrate/nitrites and phosphatesmigrating to the groundwater. Later in the evaluationand review process, Alternative 9 - Treatment of Siteand Hot Spot Area Soils at a Central Soil Treatment

000074


Facility was considered a possible preferredalternative. This alternative was also eventuallyeliminated because of the difficulty in reusingcompost-treated soils at AOCs 44 & 52 or elsewhere atFort Devens in a manner that would be consideredadequately regulated in accordance with theMassachusetts Contingency Plan (MCP). Alternative 5 -Asphalt Batching the Site and Asphalt Batching the HotSpot Areas was eventually selected as the preferredalternative in the final Proposed Plan which was issuedto the public in May 1994. Alternative 5 wasconsidered to be more protective by forming a low-permeable (asphalt batched) layer, thus furtherprotecting the groundwater from the potential migrationof compounds and further preventing any possibleexposure to affected subsurface soil (if any).Alternative 5 is less expensive than Alternative 9, butmore expensive than Alternative 8.

Comment 2: The MADEP Central Regional Office Fort Devens SectionChief expressed that the MADEP believes that Alternative 5 is themost protective of the proposed alternatives. She added that theMADEP would like to state that it is their understanding that theArmy will excavate any "grossly contaminated" soil encountered,besides the top two feet and the two hot spot areas. They wouldlike to make sure that these include areas where previoussampling has shown that soil below 2 feet contained compoundsabove the cleanup levels, especially in the spill containment padarea.

Army Response: The Army proposes to excavate any highly affectedsoil encountered in addition to the top two feet of soil and thetwo hot spot areas as the MADEP has requested. This was statedin the Final Excavated Soils Management Plan (ESMP) dated May1994 (Page 2-4). Except for the two hot spot areas, previoussampling below 2 feet has not shown soil to be affected aboveestablished cleanup levels.

SI samples collected from 15 borings at depths of 5 to 7 feet and10 to 12 feet revealed total petroleum hydrocarbon compound(TPHC) concentrations that meet the cleanup level (500 ppm). Thecleanup level for carcinogenic polynuclear aromatic hydrocarbons(cPAHs) (an average total cPAH concentration of 7 ppm) wasderived based on a surface soil exposure scenario and is notapplicable to subsurface soils. Risk evaluation for subsurfacesoils indicate that human health risks are within the acceptableUSEPA target risk range. However, even if the cPAH cleanupconcentration for surface soil was applied to the subsurface

00007 5


soil, only one of 31 subsurface soil samples exceeds (does notmeet) the cleanup level of 7 ppm (16.4 ppm from boring 44B-92-01Xat the 5- to 7-foot depth). The average concentration of totalcPAHs is below 7 ppm.

Exploratory test pits were excavated for construction of aconcrete spill-containment basin in the southeast corner of theTDA Maintenance Yard, in July 1991. These initial test pitsrevealed zones of contaminated soil below the surface (TPHC wasfound at 420 to 700 pg/g concentrations in surface soil samples).However, following removal of approximately 1,200 tons of soilfor construction of the basin, confirmation samples collectedfrom the proposed basin's subgrade at the bottom of theexcavation contained TPHC concentrations ranging from nondetectto only 7 ppm.

Comment 3: The MADEP also requested that the Army review theirspill management plan with the DOL to ensure, that prior toremediation, there is a good management plan for spills and thatthe spill containment pad is utilized to minimize the likelihoodof further impacting soils. This concern is raised due to theMADEP's interpretation that there were new spills detected duringthe supplemental site investigations last year.

Army Response: The Army will review the spill management plan toensure that approved procedures are being followed. However, theMADEP's comment warrants clarification. The "spills" referred toin the MADEP's comment was actually one drip spot, of the sizecommonly found in public parking areas or residence driveways andfar less than the MADEP reportable quantity of 10 gallons.

Comment 4: The Environmental Outreach Coordinator for the FortDevens Reuse Center asked what the general depth of groundwateris at the site and generally how far have the contaminantsmigrated through the soil in the yard?

Army Response: The approximate depth of the water table is 26 to28 feet. Groundwater sampling conducted in July 1992, October1992, June 1993, and September 1993 in the area, shows noevidence that substances found in the soils of the MaintenanceYards have migrated to the groundwater table and are affectinggroundwater quality.

Based on the SI soil sampling results, the average TPHCconcentrations across the site at the 0- to 2-foot, 5- to 7-footand 10- to 12-foot ranges are 315 ppm, 52 ppm and 33 ppmrespectively. Maximum TPHC concentrations are 1210 ppm, 170 ppmand 119 ppm respectively. These values exclude the TPHC

000076


concentrations at boring 44B-92-06X (that may be associated withthe mogas spill) and TPHC concentrations associated with thewaste oil underground storage tank (UST). Excluding these twoareas, TPHC concentrations that exceed (do not meet) the 500 ppmtarget level are found only in the top 2-foot sampling level.Average cPAH concentrations across the site at the 0- to 2-foot,5- to 7-foot and 10-to 12-foot ranges are 31 ppm, 2 ppm, and 0.2ppm. Maximum cPAH concentrations are 220 ppm, 16.4 ppm and 1.5ppm respectively. Risk evaluations indicate that human healthrisks exceed the acceptable USEPA Superfund target risk rangeonly from exposure to cPAHs in the top 2 feet of soil.

TPHC concentrations exceed (do not meet) the 500 ppm cleanuplevel below 2 feet in the hot spot areas. TPHC concentrationswere detected at 1560 ppm down to the 10- to 12-foot range inboring 44B-92-06X (mogas spill hot spot area). Soil samplescollected from the sidewalls (9 feet below ground surface [bgs])of overexcavated soils surrounding the removed waste oil UST,revealed TPHC concentrations ranging from 1,110 to 2,740 ppm.However TPHC was detected in only two of 16 additional samplescollected from supplemental SI borings in the UST area.Concentrations were 121 ppm (10 feet bgs) and 38 ppm (5 feet bgs)which meet the cleanup level. Subsurface soils in both hot spotareas will be excavated to remove TPHC contaminated soils thatexceed (do not meet) the cleanup level.

Comment 5: The current chairman of the Ayer Board of Selectmenasked if the groundwater monitoring wells sampled included thetown of Ayer Grove Pond well. She also asked if it is importantthat the Grove Pond well also be sampled.

Army Response: During the public hearing the Army responded thatthe Grove Pond wells have been sampled by USEPA but notconcurrently with the Army's sampling efforts at AOCs 44 & 52.(The specifics of these sampling events were not recalled duringthe meeting). Specifically, both Grove Pond wells were sampledbetween 7/3/90 and 8/21/91. Tetrachloroethene, a cleaningsolvent, was detected in one sample from Well #2 in 1991 at aconcentration of 1.2 M9/1 which is below (better than) state andfederal Maximum Contaminant Levels (MCLs) for drinking water. Notetrachloroethene has been detected in AOCs 44 & 52 soils.Sampling of the Grove Pond wells was also performed by the townof Ayer's consultant in 1992. Sampling was conducted inconjunction with the extended pumping tests to examine thequality of water produced by the wells in accordance withMassachusetts Drinking Water Regulations. There were no volatileorganics, pesticides or semivolatile organics detected duringthis sampling event. As with any drinking water supply, the

000077


MADEP will require the town of Ayer to sample the Grove Pondwells if they are to be used as a potable water source.

Comment 6: The current Superintendent of the town of AyerDepartment of Public Works also expressed his concern about thecleanup, since AOCs 44 & 52 are located within the Zone II forthe Grove Pond drinking water wells. He stated that wells havehistorically served the town of Ayer as the main source ofdrinking water but over the last few years have not been usedexcept for emergency situations because of high iron andmanganese content in the water. The Superintendent stated thatthis situation is about to change due to plans for constructionof a new filter plant. Once this plant is constructed, Ayerproposes to pump 1 million gallons per day (mgd) from the GrovePond well source. He stated that the proposed cleanup of theBarnum Road Maintenance Yards sounds adequate, provided a strongmonitoring program is in place and that if a problem develops,quick remedial action will be taken.

Army Response: The Proposed Plan includes sampling groundwaterfor a period of five years following remediation of the soils atthe Barnum Road Maintenance Yards. Details of this monitoringprogram will be specified in the forthcoming remedial design.The Army does not expect that the groundwater will ever beimpacted by the past Maintenance Yards activities, after soilremediation. In addition to soil treatment by asphalt batching,the Proposed Plan provides greater aquifer protection through theconstruction of the low-permeable pavement barrier at the site.However, should groundwater become affected, Alternative 5 doesnot impede the ability to quickly conduct further remedialactions.

Comment 7: A merchant in the town of Ayer stated that the Armyneeds to start addressing contamination in Plow Shop Pond. Hehas not heard much lately on this issue and would like to keepinformed.

Army Response: The Army has made Plow Shop Pond a separateoperable unit from the remediation being performed at the BarnumRoad Maintenance Yards. Sites are broken into separate operableunits so that the substances present at each site can be morecomprehensively addressed. Additional analytical sampling inPlow Shop Pond is proposed this summer. The sampling is beingperformed to investigate water quality of the pond and toevaluate potential remedial alternatives. Current and proposedactivities at Plow Shop Pond will follow the remedialinvestigation and feasibility study (RI/FS) process establishedby the USEPA Superfund program which encourages public

000078


involvement. The Army will be keeping the community and otherinterested parties apprised of Plow Shop Pond activities throughTRC meetings, public informational meetings, fact sheets, pressreleases and public hearings as was done for the Barnum RoadMaintenance Yards.

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ATTACHMENT A

PUBLIC HEARING TRANSCRIPT

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FORMAL PUBLIC HEARING

FINAL PROPOSED PLAN

BARNUM ROAD MAINTENANCE YARDSAOCs 44 & 52

FORT DEVENS, MASSACHUSETTS

Held at:Fort Devens, MassachusettsWednesday, June 15, 1994

!Robin Gross, Registered Professional Reporter

* * * *

DORIS 0. WONG ASSOCIATES

i) 0 0 0 » i

1 P R O C E E D I N G S

2 MR. CHAMBERS: It's now about 7:30, I'd

3 like to commence the formal public comment period.

4 My name is James Chambers, I'm the BRAC

5 Environmental Coordinator here at Fort Devens. As I

6 say, the public comment period began May 25, 1994,

7 and ends June 24, 1994. Comments may be either made

8 this evening or submitted in writing to the

9 following address, and I'll announce that right

10 now: Send that to AFZD-BEC, Post Office Box 1, Fort

11 Devens, Massachusetts, 01433. And you may call me

12 also at. area code 508-796-3114.

13 Comments received during this period will

14 be responded to in a document known as a

15 Responsiveness Summary that we anticipate will issue

16 on or before August 9, depending on the number of

17 comments we receive. We anticipate a draft Record

18 of Decision being made at that time, with a final

19 Record of Decision being made on September 12.

20 And with that, I'd like to invite public

21 comment. If you submit on cards, I will read

22 those. Once again, if you submit it on cards,

23 please write your name and your affiliation; and if

24 you elect to stand and make your announcement,


O U ^ U 3*

1 please announce your name and your affiliation.

2 MS. HAMEL: Do you want me to start? I'm

3 Pauline Hamel. I'm chairman of the Ayer Board of

4 Selectmen. My problem with this is I don't believe

5 proper notification was received by the town of the

6 work that's going to be done in that yard, and our

7 concern is that last night at town meeting the

8 people of the Town of Ayer voted to I guess you

9 might say reconstruct a well that's at the bottom of

10 this site. This is going to be our major water

11 supply for the Town of Ayer. It was our major water

12 supply several years ago; then we went to wells at

13 Spectacle Pond, which is on the other side of town,

14 but found they're not sufficient to our needs.

15 After considerable consultation with other

16 people by our DPW superintendent it was decided that

17 we would go back to the Grove Pond wells, to

18 reconstruct and put a considerable amount of money

19 with the future construction, even after the initial

20 work on the wells to clear the magnesium and

21 whatever else is in there; that there will be

22 additional capacity later on, and it will be built

23 so that we can use it for many, many years because

24 of the aquifer that runs under that.


0 0 \j o' '-j <$

1 My problem is this: Many months ago, when

2 Mr. Doney was head of the Reuse Center, he

3 informed me that there was an extensive cleanup

4 proposed for this particular area. It was not the

5 cleanup, as he described it to me, it was not the

6 cleanup that has recently been described to me.

7 Only accidentally did I find out about this

8 cleanup. We were interviewing, strangely enough,

9 for Mr. Doney's position at the Reuse Center about

10 three weeks ago when a gentleman made a remark about

11 a change that the government had in the cleanup of

12 this particular area. And when Eric Knapp, who

13 represents Massachusetts Land Bank, said to him,

14 "Where did you get that information? That's not

15 public knowledge," I just listened; he would not

16 state.

17 The next day I tried to find out more

18 information, and all I was told was that I didn't

19 have to worry about it; it was and had changed, but

20 I didn't have to worry, that it was a procedure,

21 process for cleaning that was acceptable to the

22 Massachusetts Land Bank. We are naturally not the

23 Massachusetts Land Bank, we are the town, and we

24 have to look for many years to that for a water


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1 source.

2 I would like to ask one question here

3 before I go further, perhaps you can tell me: How

4 many feet from the Grove Pond well is this hot spot

5 that you're talking about?

6 CAPTAIN PEASE: It's over 2,000 feet. I'm

7 not sure of the exact figure.

8 MS. HAMEL: Were you aware when you did

9 that that the Grove Pond wells were going to be

10 reused? How much conversation has there been with

11 the Town of Ayer about what you have contemplated

12 doing, and who have you been talking to in Ayer?

13 MR. CHAMBERS: We'll respond to that in the

14 responsiveness summary.

15 MS. HAMEL: All right. These are my

16 questions. My concern, naturally, is that all of a

17 sudden there's a change in the plans for the cleanup

18 of that area. I know nothing about -- it certainly

19 isn't within my knowledge to know whether this is a

20 good or a bad plan. I was told of a meeting that

21 was to take place in Sudbury which I attended last

22 Friday at which some of these people were present,

23 and they explained to me that they thought it was

24 probably a better plan than the initial one, but I'm


o e o o .s .•

1 certainly not convinced that it is.

2 And due to the fact that millions of

3 dollars were voted on last night to build this well

4 at Grove Pond, I think the Town of Ayer and the

5 people there need some explanation as to why the

6 extensive cleanup that was proposed many months ago,

7 maybe a year ago, is no longer planned. I was told

8 it was to save money. Whether that's true or not, I

9 don't know. But I certainly feel the town needs an

10 explanation as to why there has been a change.

11 And also I'd like to know who here has been

12 talking to people in the Town of Ayer, and who those

13 people are, and why we didn't receive -- I certainly

14 didn't know anything about a March 25 meeting, and

15 only by accident did I learn about it, because these

16 people who I saw on Friday told me about this

17 meeting tonight. And then I had to call around

18 today to find out -- I'm sorry that I didn't write

19 down the time and the place, and I had to call

20 around today several places to find out about the

21 time and the place. So I think that's a disservice

22 to the town, really.

23 As an individual who's elected to watch out

24 for the welfare of the people in the town, I feel


0 0 0 f S $

1 that the military certainly has not fulfilled its

2 obligation to the Town of Ayer in advising it what

3 is being done down there or above our contemplated

4 wells. That's all I have to say.

5 MS. WELSH: My name is Lynne Welsh, I'm

6 from the Massachusetts Department of Environmental

7 Protection, and I will be submitting written

8 comments during the comment period but I wanted to

9 take this opportunity to state that we have viewed

10 the plan which recommends Alternative 5, with

11 cleanup levels of 7 parts per million of

12 carcinogenic PAHs and 500 parts per million TPH, and

13 believe that this is the most protective of the

14 proposed alternatives.

15 As we have stated to you and a group of

16 other people last Friday, we do have two concerns

17 which we have talked to the Army about and just

18 wanted to state that our understanding is that

19 besides the excavation of the top two feet and the

20 hot spots there also be excavation of grossly

21 contaminated soil. And we'd like to make sure that

22 these include the areas where previous sampling has

23 shown that soil was contaminated above the cleanup

24 levels in areas below two feet, especially the


0 0 rt 0 r; 7

1 cleanup levels in the spill containment pad; that if

2 these are grossly contaminated, they should be

3 excavated also.

4 During the investigation which the Army was

5 doing last year, the supplemental investigation,

6 sampling by ABB showed new spills in the yards, and

7 we'd like the Army to review their spill management

8 plan with the DOL, Division of Labor -- whoever runs

9 the TDA yards -- to make sure that during the time

10 when study and when the design is going on that

11 there's a good management plan out there for the

12 spills and that the spill containment pad is

13 utilized so there's less likelihood of more grossly

14 contaminated soils that need to be remediated.

15 Thank you.

16 MR. CHAMBERS: More comments?

17 MS. KOHN: My name is Judith Kohn, K - o - h - n ,

18 and I am the Environmental Outreach Coordinator for

19 the Fort Devens Reuse Center. I just have a general

20 question: What's the general depth of groundwater

21 in this site, 44, 52?

22 CAPTAIN PEASE: 26 feet.

23 MS. KOHN: I guess a follow-up question to

24 that, how far generally have the contaminants


C •: 0 0 v- *,

1 migrated through the soil in the yard?



4 MS. KOHN: Thank you. That's all I have.

5 MR. CHAMBERS: More comments?

6 MS. HAMEL: I have one additional one that

7 I'd like to ask. You mentioned that there were

8 eight wells checked. Was one of them the Grove Pond

9 well?

10 CAPTAIN PEASE: That was sampled but not

11 concurrently. That was sampled at another time by

12 -- I'm going to have use the EPA for help. The EPA

13 sampled that well.

14 MS. HAMEL: It's not important that well be

15 checked or that area? By someone?



18 (Pause)

19 MS. HAMEL: Can I ask one other question?

20 Does the Army still use their well which is right

21 besides Ayer's Grove Pond well? There's a well that

22 sits right beside the Grove Pond well or, you know,

23 it's relatively close, it's just down, I don't know,

24 I have no idea 2,000 feet or 200 feet, but it's


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right adjacent to the Grove Pond well, and does the

Army still use that well?

CAPTAIN PEASE: Yes, the Army uses that

wel 1 .

MS. HAMEL: Has that well been tested?

CAPTAIN PEASE: Yes, it has.

MR. CHAMBERS: Okay. I'd like to ask once

again if there are more comments. Okay. With that,

we'd like to close this public comment meeting.

Thank you.

(Whereupon, the proceedings were

closed at 7:46 p.m.)


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C E R T I F I C A T E

I, Robin Gross, Registered Professional

Reporter, do hereby certify that the foregoing

transcript, Volume I, is a true and accurate

transcription of my stenographic notes taken on

Wednesday, June 15, 1994.

Robin Gross

Registered Professional Reporter


zDX

BARNUM ROAD MAINTENANCE YARDSAOCs 44 & 52ROD SUMMARY

APPENDIX D

DECLARATION OF STATE CONCURRENCE

D 0 0 0 9 2

Commonwearn of MassachusettsExecutive Office of environmental ATalrsDepartment ofinvirenmental ProtectionCentral Regional Office

March 7, 1595

Mr. John De VillarsRegional Administrator*J.S. Environmental Protection AgencyRegicr. IJFK Federal BuildingBoston, MA 02203

RS: aarr.um Road Maintenance Yards (3RMY) , AOCa 44 and 52, FortDavans, MA, ROD Concurrence

Dear Mr. De Villars:

The Massachusetts Department cf environmental Protection(MADE?' has reviewed the preferred remedial alternativerecommended by the Army and the SPA fcr the final cleanup cf theSarr.-m Road Maintenance Yards, the core provisions of which aresummarized below. The MADE? has worked closely with the Army andEPA ;~ the development of the preferred alternative and ispleased tc concur with the Army's choice cf the remedialalternative.

The MADE? has evaluated the preferred alternative forconsistency with M.G.L. c. 21E {212; and the MassachusettsCcr.cir.ger.cy Plan 'MC?/ . The remedial alternative addresses theer.cire 3RMY as one ocarabla unit and includes the followingcctr.pcr.ents :

• Excavate the top two feat of surface soil across thesite;

• Excavate the two hot spot areas;

• Stockpile soils for sampling and analysis;

• Ccli nix asphalt batch soils exceeding site cleanuplevels;

• Sackfill excavations with uncontaminated stockpiled soiland with aaphalt batched material;

• Apply a pavement wearing course;

0 0 0 0 9 37S Qrov* StfMt t WoroMMr, Miu«chuM«n01«M • FAX (60«) 7*»>7«21 • TatophwM («») 7t2>7M3

• Expand the existir.g stormwater collection system;

ROD Ccr.currer.eeFort Cever.3, MAMarch *», 1995Page 2

• Perform grcundwater monitoring;

• As a precautionary measure, institute deed restrictions topreclude receptor contact with subsurface soils. Thesedeed restrictions include:

1) prohibit residential development/use,

2) minimize the possibility of long term (workinglifetime) exposure to subsurface soils,

3) raoûire management of soils resulting from futureconstruction related activities that may temporarilydisturb the cap.

The MADE?'a concurrence with the preferred remedialalternative is based upon the expectation that it will result ina p«rwar.«nt solution as defined in 212 and the MCP and thatcontaminant concentrations achieved during the implementation ofthe remedial alternative will meet the MC? standards.

The MAEEF would like to thank 2?A, in particular the Fort~ev«ns Remedial Project Manager, Jim 3yrr.e, fcr their efforts toensure that the requirements of the MADS? were met in theselection of the remedial alternative. We lock forward tocontinuing co work with £?A in the implementation of the remedialalternative. If vou have any questions, please contact lynr.eWalsh at i508> 792-7653, ext. 3351.

JL3-Liar0' L«ary

fgional DirectorJEP, CERO

cc: Fort T*v«ns Mailing List (Cover Letter Only)Edward Kunce, MATE?Jay Naparstek, MADE?Informational RepositoriesJim Byrne, EPACharles G«orge, ASCMark Applebee, ACOEJudy Kohn, Mass land 3ank

00009^

mZgxm

BARNUM ROAD MAINTENANCE YARDSAOCs 44 & 52ROD SUMMARY

APPENDIX E

ADMINISTRATIVE RECORD INDEX

000095

Fort Devens

Group 3, 5, & 6 Sites

Administrative Record File for

Fort Devens Barnum Road Maintenance Yard

Areas of Concern 44/52

Index

Prepared forNew England Division

Corps of Engineers

byABB ENVIRONMENTAL SERVICES, INC.

107 AudubonRoad, Wakefield, Massachusetts 01880 (617) 245-6606

P..00096

Introduction

This document is the Index to the Administrative Record File for the FortDevens Barnum Road Maintenance Yard - Areas of Concern (AOCs) 44/52.Section I of the Index cites site-specific documents and Section 0 cites guidancedocuments used by U.S. Army staff in selecting a response action at the site.Some documents in this Administrative Record File Index have been cited but notphysically included. If a document has been cross-referenced to anotherAdministrative Record File Index, the available corresponding comments andresponses have been cross-referenced as well.

The Administrative Record File is available for public review at EPARegion I's Office in Boston, Massachusetts, at the Fort Devens EnvironmentalManagement Office, Fort Devens, Massachusetts, and at the Aver Town Hall,1 Main Street, Ayer, Massachusetts. Supplemental/Addendum volumes may beadded to this Administrative Record File. Questions concerning theAdministrative Record should be addressed to the Fort Devens Base Realignmentand Closure Office (BRAC).

The Administrative Record is required by the ComprehensiveEnvironmental Response, Compensation, and Liability Act (CERCLA), asamended by the Superfund Amendments and Reauthorization Act (SARA).

GRP35&6\AOC44&52.IND ^ 03/06/95

Section I

Site-Specific Documents

0 0 0 0 9 3

ADMINISTRATIVE RECORD FILE INDEX

for

Fort Devens Barnum Road Maintenance YardAreas of Concern 44/52Compiled: March 1995

1.0 Pre-Remedial

Cross Reference: The following Reports, Comments, and Responses toComments (entries 1 through 6) are filed and cited as entries 1 through 6in minor break 1.2 Preliminary Assessment of the Fort Devens Group 1AAdministrative Record File Index.

Reports

1. "Final Master Environmental Plan for Fort Devens," ArgonneNational Laboratory (April 1992).

2. "Preliminary Zone II Analysis for the Production Wells at FortDevens, MA, Draft Report", ETA Inc. (January 1994).

Comments

3. Comments Dated May 1, 1992 from Walter Rolf, MontachusettRegional Planning Commission on the April 1992 "Final MasterEnvironmental Plan for Fort Devens," Argonne National Laboratory.

4. Comments Dated May 7, 1992 from James P. Byrne, EPA Region Ion the April 1992 "Final Master Environmental Plan for FortDevens," Argonne National Laboratory.

5. Comments Dated May 23, 1994 from D. Lynne Welsh,Commonwealth of Massachusetts Department of EnvironmentalProtection on the January 1994 "Preliminary Zone n Analysis forthe Production Wells at Fort Devens, MA, Draft Report", ETA Inc.

Responses to Comments

6. Response Dated June 29, 1992 from Carrol J. Howard, Fort Devensto the May 7, 1992 Comments from James P. Byrne, EPA Region I.Reports

GRP35&6\AOC44&52.IND fk A O 0 Q 9 03/06/95

1.3 Site Inspection

Cross-Reference: The following Reports, Comments, Responses toComments, Responses to Responses to Comments, and Meeting Notes(entries 1 through 25) are filed and cited as entry numbers 1 through 25 inminor break 1.3 Site Inspection Reports of the Fort Devens Groups 3, 5, &6 Sites Administrative Record Index.

Reports

1. "Final Task Order (Site Investigation) Work Plan," ABBEnvironmental Services, Inc. (September 1992).

2. "SI Data Packages," ABB Environmental Services, Inc. (December1992).

3. "Final Site Investigation Report - Groups 3, 5, & 6, Fort Devens,Massachusetts," ABB Environmental Services, Inc. (April 1993).

4. "Supplemental Site Investigation - Groups 3, 5, and 6, Fort Devens,Massachusetts, Task Order Work Plan," ABB EnvironmentalServices, Inc. (rev. July 1993).

5. "Supplemental Site Investigation - Data Package," ABBEnvironmental Services, Inc. (September 1993).

Comments

6. Comments Dated April 15, 1992 from D. Lynne Chappell,Commonwealth of Massachusetts Department of EnvironmentalProtection on the March 1992 "Draft SI Work Plan for Groups 3, 5,& 6," ABB Environmental Services, Inc.

7. Comments Dated May 1, 1992 from James P. Byrne, EPA Region Ion the "Draft SI Work Plan for Groups 3, 5, & 6, and ProjectOperations Plan" ABB Environmental Services, Inc.

8. Comments Dated July 21, 1992 from D. Lynne Chappell,Commonwealth of Massachusetts Department of EnvironmentalProtection on the June 1992 "Draft Final Work Plan for Groups 3,5, & 6," ABB Environmental Services, Inc.

9. Comments Dated July 28, 1992 from James P. Byrne, EPA Region Ion the June 1992 "Draft Final Work Plan for Groups 3, 5, & 6,"ABB Environmental Services, Inc.

10. Comments Dated October 26, 1992 from D. Lynne Chappell,Commonwealth of Massachusetts Department of EnvironmentalProtection on the September 1992 "Final Task Order (SiteInvestigation) Work Plan," ABB Environmental Services, Inc.

GRP35&6\AOC44&52.IND /\ 03/06/950.0 01 0 u

11. Comments Dated October 29, 1992 from James P. Byrne, EPARegion I on the September 1992 "Final Task Order (SiteInvestigation) Work Plan," ABB Environmental Services, Inc.

12. Comments Dated January 19, 1993 from James P. Byrne, EPARegion I on the December 1992 "SI Data Packages," ABBEnvironmental Services, Inc.

13. Comments Dated February 3, 1993 from D. Lynne Chappell,Commonwealth of Massachusetts Department of EnvironmentalProtection on the December 1992 "SI Data Packages," ABBEnvironmental Services, Inc.

14. Comments Dated May 6, 1993 from James P. Byrne, EPA Region Ion the April 1993 "Final SI Report, Fort Devens Site Investigation,Groups 3, 5, and 6," ABB Environmental Services, Inc.

15. Comments Dated May 20, 1993 from D. Lynne Chappell,Commonwealth of Massachusetts Department of EnvironmentalProtection on the April 1993 "Final SI Report, Fort Devens SiteInvestigation, Groups 3, 5, and 6," ABB Environmental Services, Inc.

16. Comments Dated August 26, 1993 from D. Lynne Chappell,Commonwealth of Massachusetts Department of EnvironmentalProtection on the July 1993 "Final Work Plan for the SupplementalSite Investigation, Groups 3, 5, & 6," ABB Environmental Services,Inc.

17. Comments Dated October 25, 1993 from D. Lynne Welsh,Commonwealth of Massachusetts Department of EnvironmentalProtection on the September 1993 "Supplemental SI Data Packagefor Fort Devens SI Groups 3, 5, & 6," ABB Environmental Services,Inc.

18. Comments Dated November 8, 1993 from James P. Byrne, EPARegion I on the September 1993 "Supplemental SI Data Package forFort Devens SI Groups 3, 5, & 6," ABB Environmental Services,Inc.


19. Responses Dated June 4, 1992 from U.S. Army Toxic andHazardous Materials Agency on the April 15, 1992 Comments fromD. Lynne Chappell, Commonwealth of Massachusetts Departmentof Environmental Protection and the May 1, 1992 Comments fromJames P. Byrne, EPA Region I.

20. Responses Dated September 24, 1992 from U.S. Army Toxic andHazardous Materials Agency on the July 21, 1992 Comments fromD. Lynne Chappell, Commonwealth of Massachusetts Departmentof Environmental Protection and the July 28, 1992 Comments fromJames P. Byrne, EPA Region I.

21. Responses Dated July 7, 1993 from U.S. Army EnvironmentalCenter on the May 6, 1993 Comments from James P. Byrne, EPA

GRP35&6\AOC44&52.IND -. A 1 03/06/95o o o i o i

Region I and the May 20, 1993 Comments from D. Lynne Chappell,Commonwealth of Massachusetts Department of EnvironmentalProtection.

Responses to Responses to Comments

22. Responses Dated July 28, 1992 from James P. Byrne, EPA Region Ion the June 4, 1992 Comments from U.S. Army Toxic andHazardous Materials Agency.

23. Responses Dated August 26, 1993 from D. Lynne Chappell-Welsh,Commonwealth of Massachusetts Department of EnvironmentalProtection on the July 7, 1993 Comments from U.S. ArmyEnvironmental Center.

Meeting Notes

24. Meeting Notes, ABB Environmental Services, Inc., EPA Region I,Commonwealth of Massachusetts Department of EnvironmentalProtection, Fort Devens Environmental Management Office, U.S.Army Environmental Center, and CDM Federal Programs Corp.(January 20, 1993). Concerning SI Data Package.

25. Meeting Notes, ABB Environmental Services, Inc., EPA Region I,Commonwealth of Massachusetts Department of EnvironmentalProtection, Fort Devens Environmental Management Office, U.S.Army Environmental Center, and CDM Federal Programs Corp.(September 27, 1993). Concerning Supplemental SI Data Package.

2.0 Removal Response

2.2 Removal Response Reports

1. "Post-Removal Report Underground Storage Tank Closure, 1,000Gallon Waste Oil UST No. 0058, Building 3713, Fort Devens,Massachusetts," ATEC Environmental Consultants (October 1993).

2.3 Sampling and Analysis Data

1. 'Technical Report Related to the Field Screening of Soil Samples atthe Site of the Proposed Spill Containment Basin, Project No. EQ-1902109P, Fort Devens, Massachusetts," Lincoln Environmental, Inc.(February 1992).

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0 0 0 1 0 2

2.4 Pollution Reports (POLREPs)

1. Memorandum from R. Spelfogel, U.S. Dept. of the Army to File(May 1, 1985). Concerning inspection of Cannibalization Point -TDA Maintenance Yard, Fort Devens.

3.0 Remedial Investigation (RI)

3.2 Sampling and Analysis Data

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

3.4 Interim Deliverables

Reports

1. Cross Reference: "Final Ground Water Flow Model at FortDevens," Engineering Technologies Associates, Inc. (May 24, 1993)[Filed and cited as entry number 1 in minor break 3.4 InterimDeliverables of the Fort Devens Group 1A Sites AdministrativeRecord Index].

2. Cross Reference: "Final Projects Operations Plan - Volume I ofIII," ABB Environmental Services, Inc. (December 1992). [Filedand cited as entry number 2 in minor break 3.4 Interim Deliverablesof the Fort Devens Group 2 & 1 Administrative Record File Index].

3. Cross Reference: "Final Projects Operations Plan - Volume n of III- Appendix A: Health and Safety Plan," ABB EnvironmentalServices, Inc. (December 1992). [Filed and cited as entry number 3in minor break 3.4 Interim Deliverables of the Fort Devens Group 2& 7 Administrative Record File Index].

4. Cross Reference: "Final Projects Operations Plan - Volume HI ofIII - Appendix B: Laboratory QA Plan; Appendix C:USATHAMA-Certified Analytical Methods," ABB EnvironmentalServices, Inc. (December 1992). [Filed and cited as entry number 4in minor break 3.4 Interim Deliverables of the Fort Devens Group 2& 7 Administrative Record File Index].

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Comments

5. Cross Reference: Comments Dated January 12, 1993 from James P.Byrne, EPA Region I on the December 1992 "Final ProjectsOperations Plan," ABB Environmental Services, Inc. [Filed andcited as entry number 5 in minor break 3.4 Interim Deliverables ofthe Fort Devens Group 2 & 7 Administrative Record File Index].

6. Cross Reference: Comments Dated February 1, 1993 from James P.Byrne, USEPA Region I and D. Lynne Chappell, Commonwealth ofMassachusetts Department of Environmental Protection on theOctober 30, 1992 "Draft Final Ground Water Flow Model at FortDevens," Engineering Technologies Associates, Inc. [Filed and citedas entry number 2 in minor break 3.4 Interim Deliverables of theFort Devens Group 1A Sites Administrative Record File Index].

7. Cross Reference: Comments Dated February 17, 1993 from D.Lynne Chappell, Commonwealth of Massachusetts Department ofEnvironmental Protection on the December 1992 "Final ProjectOperations Plan," ABB Environmental Services, Inc. [Filed andcited as entry number 7 in minor break 3.4 Interim Deliverables ofthe Fort Devens Group 2 & 7 Administrative Record File Index].

3.5 Applicable or Relevant and Appropriate Requirements (ARARs)

Cross-Reference: The following reports (entries 1 and 2) are filed andcited as entries 1 and 2 in minor break 3.5 Applicable or Relevant andAppropriate Requirements of the Fort Devens Groups 3, 5, & 6 SitesAdministrative Record Index.

Reports

1. "Draft Applicable or Relevant and Appropriate Requirements(ARARs) for CERCLA Remedial Actions," U.S. Army Toxic andHazardous Materials Agency (June 1992).

2. "Draft Assessment of Location-Specific Applicable or Relevant andAppropriate Requirements (ARARs) for Fort Devens,Massachusetts," U.S. Army Toxic and Hazardous Materials Agency(September 1992).

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4.0 Feasibility Study (FS)

4.4 Interim Deliverables

Reports

1. "Feasibility Evaluation Bioremediation of Maintenance Yard Soils,Biological Treatability Study Report," ABB Environmental Services,Inc. (September 1993).

2. "Final Siting Study Report for Central Soil Treatment Facility," ABBEnvironmental Services, Inc. (January 1994).

Comments

3. Comments Dated November 5, 1993 from D. Lynne Welsh,Commonwealth of Massachusetts Department of EnvironmentalProtection on the September 1993 "Feasibility EvaluationBioremediation of Maintenance Yard Soils, Biological TreatabilityStudy Report," ABB Environmental Services, Inc.

4. Comments Dated December 27, 1993 from James P. Byrne, EPARegion I on the November 1993 "Draft General ManagementProcedures, Excavated Waste Site Soils, Draft Siting Study Reportfor Central Soil Treatment Facility and the Feasibility Study Reportfor Unsarurated Soils at the Maintenance Yards (New Alternative9)" ABB Environmental Services, Inc.

5. Comments Dated January 13, 1994 from Molly Elder,Commonwealth of Massachusetts Department of EnvironmentalProtection on the November 1993 "Draft Siting Study Report forCentral Soil Treatment Facility," ABB Environmental Services, Inc.

6. Comments Dated March 11, 1994 from D. Lynne Welsh,Commonwealth of Massachusetts Department of EnvironmentalProtection on the September 1993 "Feasibility EvaluationBioremediation of Maintenance Yard Soils, Biological TreatabilityStudy Report," ABB Environmental Services, Inc.


7. U.S. Army Environmental Center Responses to Comments on thefollowing documents: Feasibility Study Report, BiologicalTreatabUity Study Report, Feasibility Study Report - NewAlternative 9, Draft General Management Procedures ExcavatedWaste Site Soils, and Draft Siting Study Report, dated January 25,1994.

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8. U.S. Army Environmental Center Responses to Comments on thefollowing documents: Final Feasibility Study Report, Draft ProposedPlan, Revised Draft Proposed Plan, Draft Excavated SoilsManagement Plan, Final General Management ProceduresExcavated Waste Site Soils, and Biological Treatability StudyReport, dated May 1994.

4.6 Feasibility Study (FS) Reports

Reports

1. "Final Feasibility Study Report for Unsaturated Soils at theMaintenance Yards (Areas of Contamination 44 and 52) FortDevens," ABB Environmental Services, Inc. (January 1994).

2. "Final Feasibility Study Addendum for Unsaturated Soils atMaintenance Yards AOCs 44/52, Fort Devens, Massachusetts," ABBEnvironmental Services, Inc. (May 1994).

Comments

3. Comments Dated July 9 and July 15, 1993 from James P. Byrne,EPA Region I on the June 1993 "Draft Focused Feasibility StudyReport AOCs 44 & 52," ABB Environmental Services, Inc.

4. Comments Dated July 29, 1993 from D. Lynne Chappell,Commonwealth of Massachusetts Department of EnvironmentalProtection on the June 1993 "Draft Focused Feasibility Study ReportAOCs 44 & 52," ABB Environmental Services, Inc.

5. Comments Dated October 13, 1993 from D. Lynne Welsh,Commonwealth of Massachusetts Department of EnvironmentalProtection on the August 1993 "Feasibility Study Report forUnsaturated Soils at Maintenance Yards AOCs 44/52, Fort Devens,Massachusetts," ABB Environmental Services, Inc.

6. Comments Dated December 16, 1993 from Molly J. Elder,Commonwealth of Massachusetts Department of EnvironmentalProtection on the November 1993 "Feasibility Study Report forUnsaturated Soils at Maintenance Yards AOCs 44/52, Fort Devens,Massachusetts," ABB Environmental Services, Inc.

7. Cross-Reference: Comments Dated December 27, 1993 from JamesP. Byrne, EPA Region I on the November 1993 "Draft GeneralManagement Procedures, Excavated Waste Site Soils, Draft SitingStudy Report for Central Soil Treatment Facility and FeasibilityStudy Report for Unsaturated Soils at Maintenance Yards - NewAlternative 9," ABB Environmental Services, Inc. [These commentsare filed and cited as a part of entry number 4 in the commentssection 4.4 Interim Deliverables of this minor break.

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8. Comments Dated February 28, 1994 from James P. Byrne, EPARegion I on the "Draft Proposed Plan and Final Feasibility Studyfor AOCs 44 & 52 (TDA Yard)," ABB Environmental Services, Inc.

9. Comments Dated March 11, 1994 from D. Lynne Welsh,Commonwealth of Massachusetts Department of EnvironmentalProtection on the January 1994 "Final Feasibility Study Report, FortDevens Feasibility Study AOCs 44 & 52," ABB EnvironmentalServices, Inc.


10. U. S. Army Environmental Center Responses to Comments on thefollowing documents: Fort Devens Focused Feasibility Study (FFS)for AOCs 44 and 52; Draft Feasibility Study Work Plan, FFS InitialScreening Document; and Supplemental Field Investigations andData Gathering Maintenance Yard Soils Work Plan, dated June 25,1993.

11. U. S. Army Environmental Center Responses to Comments on thefollowing document: Draft Feasibility Study Report AOCs 44 and 52Fort Devens, dated August 27, 1993.

12. Cross-Reference: U. S. Army Environmental Center Responses toComments on the following documents: Feasibility Study Report;Biological Treatability Study Report; Feasibility Study Report - NewAlternative 9; Draft General Management Procedures ExcavatedWaste Site Soils; and Draft Siting Study Report, dated January 25,1994. [These Responses to Comments are filed and cited as a partof entry number 7 in the Responses to Comments section 4.4 in thisminor break].

13. U. S. Army Environmental Center Responses to Comments on thefollowing documents: Final Feasibility Study Report, Draft ProposedPlan, Revised Draft Proposed Plan, Draft Excavated SoilsManagement Plan, Final General Management ProceduresExcavated Waste Site Soils, and Biological Treatability StudyReport, dated May 1994.

4.7 Work Plans and Progress Reports

Reports

1. "Final Focused Feasibility Study Work Plan," ABB EnvironmentalServices, Inc. (June 1993).

2. "Final Excavated Soils Management Plan for AOCs 44 & 52," ABBEnvironmental Services, Inc. (May 1994).

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Comments

3. Comments Dated June 8, 1993 from James P. Byrne, EPA Region Ion the June 1993 "Fort Devens Supplemental Field Investigationsand Data Gathering Maintenance Yard Soils; Fort Devens FocusedFeasibility Study Work Plan; Fort Devens Focused Feasibility StudyInitial Screening Document," ABB Environmental Services, Inc.

4. Comments Dated June 9, 1993 from D. Lynne Chappell,Commonwealth of Massachusetts Department of EnvironmentalProtection on the "Draft Feasibility Study Work Plan," ABBEnvironmental Services, Inc.

5. Comments Dated June 10, 1993 from D. Lynne Chappell,Commonwealth of Massachusetts Department of EnvironmentalProtection on the "Supplemental Field Investigations and DataGathering, Maintenance Yards Soils, AOCs 44 & 52," ABBEnvironmental Services, Inc.

6. Comments Dated June 15, 1993 from James P. Byrne, EPARegion I on the June 1993 "Treatability Study Work Plan,Supplemental Field Investigations and Data Gathering MaintenanceYard Soils, Fort Devens," ABB Environmental Services, Inc.

7. Comments Dated March 11, 1994 from D. Lynne Chappell,Commonwealth of Massachusetts Department of EnvironmentalProtection on the January 1994 "Draft Excavated Soils ManagementPlan, AOCs 44 and 52," ABB Environmental Services, Inc.


8. Cr oss-Reference: U. S. Army Environmental Center Responses toComments on the following documents: Fort Devens FocusedFeasibility Study (FFS) for AOCs 44 and 52; Draft Feasibility StudyWork Plan, FFS Initial Screening Document; Supplemental FieldInvestigations and Data Gathering Maintenance Yard Soils WorkPlan, dated June 25, 1993.[These Responses to Comments are filedand cited as a part of entry # 10 in section 4.6].

9. Cross-Reference: U. S. Army Environmental Center Responses toComments on the following documents: Final Feasibility StudyReport; Draft Proposed Plan; Revised Draft Proposed Plan; DraftExcavated Soils Management Plan; Final General ManagementProcedures Excavated Waste Site Soils and Biological TreatabilityStudy Report, dated May 1994. [These Responses to Comments arefiled and cited as a part of entry number 8 in minor break 4.4Interim Deliverables of the Fort Devens AOC 44/52 AdministrativeRecord File Index].

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4.9 Proposed Plans for Selected Remedial Action

1. Cover letter from James C. Chambers, BRAC EnvironmentalCoordinator to James P. Byrne, EPA Region I (April 11, 1994).Concerning transmittal of a new draft Proposed Plan, and includingrationale for change in the Army's preferred alternative.

2. "Final Proposed Plan, Fort Devens Barnum Road MaintenanceYards, AOCs 44 & 52," ABB Environmental Services, Inc. (May1994).

Comments

3. Cross-Reference: Comments Dated February 28, 1994 from JamesP. Byrne, EPA Region I on the January 1994 "Draft Proposed Plan,Fort Devens Barnum Road Maintenance Yards, AOCs 44 & 52,"ABB Environmental Services, Inc. [These Comments are filed andcited as a part of entry number 8 in the Comments section 4.6 ofthis minor break].

4. Comments Dated March 11, 1994 from D. Lynne Welsh,Commonwealth of Massachusetts Department of EnvironmentalProtection on the January 1994 "Draft Proposed Plan, Fort DevensBarnum Road Maintenance Yards, AOCs 44 & 52," ABBEnvironmental Services, Inc.

5. Comments Dated March 18, 1994 from D. Lynne Welsh,Commonwealth of Massachusetts Department of EnvironmentalProtection on the January 1994 "Draft Proposed Plan, Fort DevensBarnum Road Maintenance Yards, AOCs 44 & 52," ABBEnvironmental Services, Inc.

6. Comments Dated May 5, 1994 from D. Lynne Welsh,Commonwealth of Massachusetts Department of EnvironmentalProtection on the April 1994 "Revised Draft Proposed Plan forBarnum Road Maintenance Yards, AOCs 44 & 52," ABBEnvironmental Services, Inc.

7. Comments Dated May 9, 1994 from James P. Byrne, EPA Region Ion the April 1994 "Revised Draft Proposed Plan for Barnum RoadMaintenance Yards, AOCs 44 & 52," ABB Environmental Services,Inc.


8. Cross-Reference: U. S. Army Environmental Center Responses toComments on the following documents: Final Feasibility StudyReport; Draft Proposed Plan; Revised Draft Proposed Plan; DraftExcavated Soils Management Plan; Final General ManagementProcedures Excavated Waste Site Soils; and Biological Treatability

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Study Report, dated May 1994 [These Responses to Comments arefiled and cited as a part of entry number 8 in the Responses toComments section 4.4 of this minor break].

9. Cross-Reference: U. S. Army Environmental Center Responses toComments on the following documents: Fort Devens FocusedFeasibility Study (FFS) for AOCs 44 and 52; Draft Feasibility StudyWork Plan, FFS Initial Screening Document; Supplemental FieldInvestigations and Data Gathering Maintenance Yard Soils WorkPlan, dated June 25, 1993. [These Responses to Comments are filedand cited as a part of entry number 10 in the Responses toComments section 4.6 of this minor break].

5.0 Record of Decision (ROD)

5.4 Record of Decision

Reports

1. "Revised Draft Record of Decision Barnum Road MaintenanceYards, Fort Devens, Massachusetts", ABB Environmental Services,Inc. (September 7, 1994).

2. "Record of Decision Barnum Road Maintenance Yards, FortDevens, Massachusetts", ABB Environmental Services, Inc.(September 13, 1994).

3. "Record of Decision Barnum Road Maintenance Yards, FortDevens, Massachusetts (Final)," ABB Environmental Services, Inc.(March 1995).

Comments

4. Comments Dated August 19, 1994 from James P. Byrne, USEPARegion I on the August 1994 " Draft Record of Decision BarnumRoad Maintenance Yards, Fort Devens, Massachusetts," ABBEnvironmental Services, Inc.

5. Comments Dated August 25, 1994 from D. Lynne Welsh,Commonwealth of Massachusetts Department of EnvironmentalProtection on the August 1994 "Draft Record of Decision BarnumRoad Maintenance Yards, Fort Devens, Massachusetts," ABBEnvironmental Services, Inc.

6. Comments Dated September 16, 1994 from John Regan,Commonwealth of Massachusetts Department of EnvironmentalProtection on the review of the activity and use limitation (AUL).

7. Comments Dated September 16, 1994 from Cornelius O'Leary,Commonwealth of Massachusetts Department of EnvironmentalProtection on the Barnum Road Maintenance Yards (AOCs 44 &52), Fort Devens, Massachusetts, ROD Concurrence.

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8. Comments Dated February 17, 1995 from James P. Byrne, USEPA,on the Draft Radiological Report for the Cannibalization Yard andTDA Maintenance Yard and the Proposed Section XII(Documentation of No Significant Changes) Revisions to theBarnum Road Maintenance Yards Record of Decision.


9. Responses Dated September 7, 1994 from U.S. Army EnvironmentalCenter on the following document: Draft Record of Decision,Barnum Road Maintenance Yards, Fort Devens, Massachusetts.

5.5 Work Plans and Progress Reports

Reports

1. "Draft Radiological Survey Work Plan, Area of Contamination(AOCs) 44 & 52, Barnum Road Maintenance Yards, Fort Devens,Massachusetts," ABB Environmental Services, Inc. (October 1994).

2. "Final Radiological Survey Work Plan, Area of Contamination(AOCs) 44 & 52, Barnum Road Maintenance Yards, Fort Devens,Massachusetts," ABB Environmental Services, Inc. (December 1994).

3. "Draft Radiological Status Report for Cannibalization Yard andTDA Maintenance Yard, Area of Contamination 44 & 52, FortDevens, Massachusetts," ABB Environmental Services, Inc.(February 1995).

4. "Final Radiological Status Report for Cannibalization Yard andTDA Maintenance Yard, Area of Contamination 44 & 52, FortDevens, Massachusetts," ABB Environmental Services, Inc. (March1995).

Comments

5. Comments Dated November 15, 1994 from James P. Byrne,USEPA, on the "Draft Radiological Survey Work Plan for theBarnum Road Maintenance Yard," ABB Environmental Services,Inc.

6. Comments Dated November 16, 1994 from D. Lynne Welsh,Commonwealth of Massachusetts Department of EnvironmentalServices on the October 1994 "Draft Radiological Survey Work Plan,Areas of Contamination (AOCs) 44 & 52, Barnum RoadMaintenance Yards, Fort Devens, MA," ABB EnvironmentalServices, Inc.

7. Comments Dated November 29, 1994 from D. Lynne Welsh,Commonwealth of Massachusetts Department of EnvironmentalProtection on the October 1994 "Draft Radiological Survey Work

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Plan, Areas of Contamination (AOCs) 44 & 52, Barnum RoadMaintenance Yards, Fort Devens, Massachusetts," ABBEnvironmental Services, Inc.

8. Comments Dated December 16, 1994 from James P. Byrne, USEPA,on the Final Radiological Survey Work Plan and Response toComments for the Barnum Road Maintenance Yards, (ABBEnvironmental Services, Inc.).

9. Comments Dated December 27, 1994 from D. Lynne Welsh,Commonwealth of Massachusetts Department of EnvironmentalProtection on the Draft Radiological Survey Work Plan, Areas ofContamination (AOC) 44 & 52, and Final Radiological Work Plan,Areas of Contamination (AOCs) 44 & 52, Fort Devens,Massachusetts.

10. Cross Reference: Comments Dated February 17, 1995 from JamesP. Byrne, USEPA, on the Draft Radiological Report for theCannibalization Yard and TDA Maintenance Yard and theProposed Section XII (Documentation of No Significant Changes)Revisions to the Barnum Road Maintenance Yards Record ofDecision. [Filed and cited as entry number 8 in minor break 5.4Record of Decision in this index.]

11. Comments Dated March 3, 1995 from D. Lynne Welsh,Commonwealth of Massachusetts Department of EnvironmentalProtection the February 1995 "Draft Radiological Status Report forCannibalization Yard and TDA Maintenance Yard, Areas ofContamination 44 & 52, Fort Devens, Massachusetts," (ABBEnvironmental Services, Inc.).


12. Responses Dated December 13, 1994 from U.S. ArmyEnvironmental Center on the following document: DraftRadiological Survey Work Plan, Areas of Contamination (AOCs) 44& 52, Fort Devens, Massachusetts.

13. Responses Dated March 1995 from U.S. Army EnvironmentalCenter on the following document: Draft Radiological StatusReport for Cannibalization Yard and TDA Maintenance Yard,Areas of Contamination 44 & 52, Fort Devens, Massachusetts.

Responses to Responses to Comments

14. Cross Reference: Comments Dated December 16, 1994 from JamesP. Byrne, USEPA, on the Final Radiological Survey Work Plan andResponse to Comments for the Barnum Road Maintenance Yards,(ABB Environmental Services, Inc.). [Filed and cited as entrynumber 8 in minor break 5.5 Work Plans and Progress Reports inthis index.]

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10.0 Enforcement

10.16 Federal Facility Agreements

1. Cross-Reference: "Final Federal Facility Agreement UnderCERCLA Section 120," EPA Region I and U.S. Department ofthe Army (November 15. 1991) with attached map [Filed andcited as entry number 1 in minor break 10.16 Federal FacilityAgreements of the Fort Devens Group 1A Sites AdministrativeRecord Index].

13.0 Community Relations

13.2 Community Relations Plans

1. Cross-Reference: "Final Community Relations Plan," Ecologyand Environment, Inc. (February 1992) [Filed and cited as entrynumber 1 in minor break 13.2 Community Relations Plans of theFort Devens Group 1A Sites Administrative Record Index].

13.5 Fact Sheets

1. Barnum Road Maintenance Yards Fact Sheet, Fort Devens,Massachusetts," ABB Environmental Services, Inc. (May 1994).

13.11 Technical Review Committee Documents

Cross-Reference: The following documents cited below as entriesnumber 1 through 8 are filed and cited as entries number 1 through 8 inminor break 13.11 Technical Review Committee Documents of the FortDevens Group 1A Sites Administrative Record Index.

1. Technical Review Committee Meeting Agenda and Summary(March 21, 1991).

2. Technical Review Committee Meeting Agenda and Summary(June 27,1991).

3. Technical Review Committee Meeting Agenda and Summary(September 17, 1991).

4. Technical Review Committee Meeting Agenda and Summary(December 11, 1991).

5. Technical Review Committee Meeting Agenda and Summary(March 24, 1992).

6. Technical Review Committee Meeting Agenda and Summary(June 23, 1992).

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7. Technical Review Committee Meeting Agenda and Summary(September 29, 1992).

8. Technical Review Committee Meeting Agenda and Summary(January 5, 1993).

17.0 Site Management Records

17.6 Site Management Plans

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

Reports

1. "Final Quality Assurance Project Plan," Ecology andEnvironment, Inc. (November 1991).

2. "General Management Procedures, Excavated Waste Site Soils,Fort Devens, Massachusetts," ABB Environmental Services, Inc.(January 1994).

Comments

3. Cross Reference: Comments from James P. Byrne, EPA RegionI on the November 1991 "Final Quality Assurance Project Plan,"Ecology and Environment, Inc. [These Comments are filed andcited as a part of entry number 8 in the Responses to Commentssection of this minor break].

4. Comments Dated December 16, 1993 from Molly J. Elder,Commonwealth of Massachusetts Department of EnvironmentalProtection on the November 1993 "Draft General ManagementProcedures, Excavated Waste Site Soils, Fort Devens,Massachusetts," ABB Environmental Services, Inc.

5. Comments Dated December 27, 1993 from James P. Byrne, EPARegion I on the November 1993 "Draft General ManagementProcedures, Excavated Waste Site Soils, Fort Devens,Massachusetts," ABB Environmental Services, Inc. [Filed andcited as entry number 4 in minor break 4.4 Interim Deliverablesof the AOCs 44/52 Administrative Record Index.]

6. Comments Dated March 11, 1994 from D. Lynne Welsh,Commonwealth of Massachusetts Department of EnvironmentalProtection on the January 1994 "General ManagementProcedures, Excavated Waste Site Soils, Fort Devens,Massachusetts," ABB Environmental Services, Inc.

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7. Cross-Reference: U. S. Army Environmental Center Responses toComments on the following documents: Feasibility Study Report;Biological Treatability Study Report; Feasibility Study Report -New Alternative 9; Draft General Management ProceduresExcavated Waste Site Soils; and Draft Siting Study Report, datedJanuary 25, 1994. [These Responses to Comments are filed andcited as a part of entry number 7 in the Responses to Commentssection of minor break 4.4 Interim Deliverables of the AOCs44/52 Administrative Record Index.]

8. Response from Fort Devens to Comments from James P. Byrne,EPA Region I on the November 1991 "Final Quality AssuranceProject Plan," Ecology and Environment, Inc.

9. Cross-Reference: U.S. Army Environmental Center Responses toComments for the following documents: Final Feasibility StudyReport; Draft Proposed Plan; Revised Draft Proposed Plan;Draft Excavated Soils Management Plan; Final GeneralManagement Procedures Excavated Waste Site Soils; andBiological Treatability Study Report, dated May 1994. [TheseResponses to Comments are filed and cited as entry number 8 inthe Responses to Comments section of minor break 4.4 InterimDeliverables of the AOCs 44/52 Administrative Record Index.]

17.9 Site Safety Plans

Cross Reference: The following documents (entries 1 through 3) are filedand cited in minor break 17.9 Site Safety Plans of the Fort Devens Group1A Administrative Record File Index unless otherwise noted below.

Reports

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

Comments

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

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3. Response from Fort Devens to Comments from James P. Byrne,EPA Region I on the November 1991 "Final Health and SafetyPlan," Ecology and Environment, Inc.

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Section II

Guidance Documents

I

L

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GUIDANCE DOCUMENTS

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

1. Occupational Safety and Health Administration (OSHA). HazardousWaste Operation and Emergency Response (Final Rule, 29 CFR Part1910, Federal Register. Volume 54, Number 42) March 6, 1989.

2. USATHAMA. Geotechnical Requirements for Drilling Monitoring Well.Data Acquisition, and Reports. March 1987.

3. USATHAMA IRDMIS User's Manual. Version 4.2, April 1991.4. USATHAMA. USATHAMA Quality Assurance Program: PAM-41.

January 1990.5. USATHAMA. Draft Underground Storage Tank Removal Protocol -

Fort Devens. Massachusetts. December 4, 1992.6. U.S. Environmental Protection Agency. Guidance for Preparation of

Combined Work/Quality Assurance Project Plans for EnvironmentalMonitoring: OWRS OA-1. May 1984.

7. U.S. Environmental Protection Agency. Office of Research andDevelopment Interim Guidelines and Specifications for Preparing QualityAssurance Project Plans: QAMS-005/80. 1983.

8. U.S. Environmental Protection Agency. Office of Emergency andRemedial Response. Interim Final Guidance for Conducting RemedialInvestigations and Feasibility Studies Under CERCLA. (OSWERDirective 9355.3-01, EPA/540/3-89/004, 1986.

9. U.S. Environmental Protection Agency. Test Methods for EvaluatingSolid Waste: EPA SW-846 Third Edition. September 1986.

10. U.S. Environmental Protection Agency. Office of Emergency andRemedial Response. Risk Assessment Guidance for Superfund.Volume I. Human Health Evaluation Manual (Part A\ (EPA/540/1-89/002), 1989.

11. U.S. Environmental Protection Agency. Hazardous Waste ManagementSystem: Identification and Listing of Hazardous Waste: ToxicityCharacteristic Revisions. (Final Rule, 40 CFR Part 261 et al., FederalRegister Part V), June 29, 1990.

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APPENDIX F

GLOSSARY OF ACRONYMS AND ABBREVIATIONS

0001 19

GLOSSARY OP ACRONYMS AND ABBREVIATIONS

(.

ABB-ESAOCSARAR

AREE

B2EHPB(a)PbgsBRAGBTEX

CACCERCLA

CMRcPAHscy

DoD

EPCs

FS

GC/FID

HEASTHI

IAGIRISIRP

mMADEP

MCLMCPMEPAMEPmg/1MHWMR

NAAQSNPLNCPNDIR

ABB Environmental Services, Inc.Areas of ContaminationApplicable or Relevant and AppropriateRequirementsArea Requiring Environmental Evaluation

bis(2-ethylhexyl)phthalatebenzo(a)pyrenebelow ground surfaceBase Realignment and Closure Actbenzene, toluene, ethylbenzene, and xylene

Citizen's Advisory CommitteeComprehensive Environmental Response,Compensation, andLiability ActCode of Massachusetts Regulationscarcinogenic polynuclear aromatic hydrocarbonscubic yard

Department of Defense

Exposure Point Concentrations

Feasibility Study

gas chromatograph/flame ionization detector

Health Effects Assessment Summary TablesHazard Index

Federal Facilities Interagency AgreementIntegration Risk Information SystemInstallation Restoration Program

cubic meterMassachusetts Department of EnvironmentalProtectionMaximum Contaminant LevelMassachusetts Contingency PlanMassachusetts Environmental Policy ActMaster Environmental Planmilligrams per literMassachusetts Hazardous Waste Management Rules

National Ambient Air Quality StandardNational Priority ListNational Contingency PlanNon-dispersive Infrared

000120

GLOSSARY OF ACRONYMS AND ABBREVIATIONS

O&M

PAPAHPALPCSPCLPIDppm

RABRfDRODRTS

SASARA

SISSISVOC

TCLPTDATEFTPHCTRCTSPTSS

USAECUSAEHAUS EPAUST

VOC

Operation and Maintenance

Preliminary Assessmentpolynuclear aromatic hydrocarbonProject Analyte Listpolychlorinated biphenylprotective contaminant levelPhotoionization Detectorparts per million

Restoration Advisory BoardReference DoseRecord of DecisionRegional Training Site

Study AreaSuperfund Amendments and Reauthorization Act of1986Site InvestigationsSupplemental Site Investigationsemivolatile organic compound

Toxicity Characteristic Leachate ProcedureTable of Distribution and AllowancesToxic Equivalency Factortotal petroleum hydrocarbon compoundTechnical Review Committeetotal suspended particulatetotal suspended solids

micrograms per literUnited States Army Environmental CenterUnited States Army Environmental Hygiene AgencyUnited States Environmental Protection Agencyunderground storage tank

volatile organic compound

Q.O 01

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