HLA_1999_Record_of_Decision_Devens_Consolidation_Landfill.pdf

FINAL

RECORD OF DECISION

LANDFILL REMEDIATION

STUDY AREAS 6, 12, AND 13

AND AREAS OF CONTAMINATION (AOC) 9, 11, 40, AND 41

U.S. ARMY RESERVE FORCES TRAINING AREA

DEVENS, MASSACHUSETTS

CONTRACT DACA31-94-D-0061

DELIVERY ORDER 0002

Prepared for:

U. S Army Corps of Engineers New England District

Concord, Massachusetts

Prepared by:

Harding Lawson Associates Portland, Maine

JULY 1999

Section

STUDY AREAS 6, 12, AND 13

AND AREAS OF CONTAMINATION 9, 11, 40, AND 41

U.S. ARMY RESERVE FORCES TRAINING AREA

DEVENS, MASSACHUSETTS

TABLE OF CONTENTS

Title Page No.

DECLARATION FOR THE RECORD OF DECISION ...... .......................... ................................. l

DECISION SUMMARY

I. SITE NAME, LOCATION, AND DESCRIPTION

A. SA 6

B. AOC 9

C. AOC 11

D. SA 12

E. SA 13

F. AOC 40

G. AOC41

II. SITE HISTORY AND ENFORCEMENT ACTIVITIES

A. Land Use and Response History B. Enforcement History

III. COMMUNITY PARTICIPATION

IV. SCOPE AND ROLE OF THE RESPONSE ACTION

V. SUMMARY OF SITE CHARACTERISTICS

A. AOC9

B. AOC 11

C. SA 12

D. SA 13

E. AOC 40

F. AOC 41

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TABLE OF CONTENTS

(continued)

Title Page No.

VI. SUMMARY OF SITE RISKS

A. Human Health Risks

B. ENVIRONMENTAL RISKS

VII. DEVELOPMENT AND SCREENING OF ALTERNATIVES

A. Statutory Requirements/Responses Objectives B. Technology and Alternative Development and Screening

VIII. DESCRIPTION OF ALTERNATIVES

A. Alternative 1: No CERCLA action at all seven landfills B. Alternative 2: No CERCLA action at SAs 6, 12, and 13, and AOC 41 ; limited debris removal at AOC 11 (disposal at AOC 9); and cap-in-place debris at AOCs 9 and 40 .. 53 C. Alternative 3: No CERCLA action at SAs 6, 12, and 13, and AOC 41 ; cap-in-place debris at AOCs 9, 11 , and 40 D. Alternative 4: No CERCLA action at SAs 6, 12, and 13, and AOC 41; limited debris removal at AOC 11; excavation and consolidation of debris at AOCs 9 and 40 E. Alternative 4a: No Further Action at SA 6; limited removal at AOC 11, SA 12, and AOC 41 (disposal in Consolidation Landfill); and excavation and consolidation of AOCs 9 and 40 and SA 13 F. Alternative 4b: No Further Action at SA 6; limited removal at AOC 11. SA 12, and AOC 41; and excavation of AOCs 9 and 40 and SA 13, with onsite consolidation or offsite disposal G. Alternative 4c: No Further Action at SA 6; limited removal at SA 12 and AOC 41;

and excavation of AOCs 9, 11 , and 40, and SA 13, with onsite consolidation or offsite disposal H. Alternative 5: Limited debris removal at AOC 11 ; cap-in-place debris at SAs 6, 12, and 13, and AOC 41; excavation and consolidation of debris at AOCs 9 and 40 g:\projects\esps\reports\002\dr6 12 J 3rodwored.doc

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STUDY AREAS 6, 12, AND 13

AND AREAS OF CONTAMINATION 9, 11, 40, AND 41

U.S. ARMY RESERVE FORCES TRAINING AREA

DEVENS, MASSACHUSETTS

TABLE OF CONTENTS

(continued)

Title Page No.

I. Alternative 6: Cap-in-place debris at SAs 6, 12, and 13, and AOC 41; excavation and consolidation of debris at AOCs 9, 11, and 40 ................. :

J. Alternative 7: Cap-in-place all seven landfills K. Alternative 8: Limited debris removal at AOC 11 ; excavation and consolidation of debris from SAs 6, 12, and 13, and AOCs 9, 40, and 41 L. Alternative 9: Excavation and consolidation of debris from all seven landfills

IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES

A. Overall Protection of Human Health and the Environment B. Compliance with ARARs C. Long-term Effectiveness and Permanence D. Reduction of Toxicity, Mobility, and Volume through Treatment E. Short-term Effectiveness F. Implementability ...................................... .. ........................................... .... ... ........ .......... 7 5 G. Cost H. State Acceptance I. Community Acceptance

X. THE SELECTED REMEDY

A. Remediation Goals B. Description of Remedial Components

XI. STATUTORY DETERMINATIONS

A. Threshold Criteria

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STUDY AREAS 6, 12, AND 13

AND AREAS OF CONTAMINATION 9, 11, 40, AND 41

U.S. ARMY RESERVE FORCES TRAINING AREA

DEVENS, MASSACHUSETTS

TABLE OF CONTENTS

(continued)

Section Title Page No.

XII DOCUMENTATION OF SIGNIFICANT CHANGES

XIII.STATE ROLE

APPENDICES

APPENDIX A - FIGURES

APPENDIX B - SYNOPSIS OF FEDERAL AND STATE ARARS FOR

ALTERNATIVE 4C

APPENDIX C - RESPONSIVENESS SUMMARY

C. l Summary Of Comments Received During The First Public Comment Period December 8, 1997 Through March 9, 1998

C.2 Summary of Comments received During The Second Public Comment Period November 25, 1998 Through January 11 , 1999

C.3 Public Meeting Transcripts C.4 Written Public Comments

APPENDIX D -ADMINISTRATIVE RECORD INDEX

APPENDIX E - DECLARATION OF STATE CONCURRENCE

APPENDIX F- SUMMARY OF HUMAN HEALTH AND ECOLOGICAL RISK

INFORMATION

F.l RISK SUMMARY INFORMATION TABLES (AOC 9, AOC 11 , SA 12, SA 13, AOC 40, AOC 41)

F.2 RISK ASSESSMENT SUMMARY TABLES (AOC 11 AND AOC 40)

F.3 PRELIMINARY RISK EVALUATION SUMMARY TABLES (AOC 9, SA 12, SA

13, AND AOC 41)

APPENDIX G - GLOSSARY OF ACRONYMS AND ABBREVIATIONS

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LIST OF FIGURES

Figure No. Title

1 Location of SAs 6, 12, and 13, and AOCs 9, 11, 40 and 41 2 SA 6 Site Map 3 AOC 9 Site Map 4 AOC 11 Site Map 5 SA 12 Site Map 6 SA 13 Site Map 7 AOC 40 Site Map 8 AOC 41 Site Map 9 Golf Course Driving Range Site Map 10 Conceptual Debris Screening Flow Chart 11 Consolidation Landfill Cover and Liner Components g:\projects\esps\reports\002\dr6 l 213rodwored.doc

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Table No.

STUDY AREAS 6, 12, AND 13

AND AREAS OF CONTAMINATION 9, 11, 40, AND 41

U.S. ARMY RESERVE FORCES TRAINING AREA

DEVENS, MASSACHUSETTS

LIST OF TABLES

Title Page No.

1 Summary Of Reports 2 Alternative Description Summary 3 Alternative Cost Estimate Summary g:\projects\esps\reports\002\dr61213rodwored.doc

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DECLARATION FOR THE RECORD OF DECISION

Study Areas 6, 12, and 13

And Areas of Contamination 9, 11, 40, and 41 U.S. Army RFTA, Devens, Massachusetts

DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

Study Areas 6, 12, and 13 and Areas of Contamination 9, 11, 40, and 41 U.S. Army Reserve Forces Training Area Devens, Massachusetts

STATEMENT OF PURPOSE AND BASIS

This decision document presents the U.S. Army's selected remedial action for Study Areas (SAs) 6, 12, and 13 and Areas of Contamination (AOCs) 9, 11, 40, and 41 at the U.S. Army, Devens Reserve Forces Training Area (RFTA), Devens, Massachusetts. It was developed in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980 as amended, 42 USC §§ 9601 et seq. and to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) as amended, 40 Code of Federal Regulations (CFR) Part 300. The following have been delegated the authority to approve this Record of Decision (ROD): The Assistant Chief of Staff for Installation Management, Department of the Army, and the Director for the Office of Site Remediation and Restoration, U.S. Environmental Protection Agency.

This decision document is based on the Administrative Record developed in accordance with Section l 13(k) of CERCLA. The Administrative Record is available for public review at the Devens BRAC Environmental Office, 30 Quebec Street, Devens, Massachusetts, and at the Ayer Town Hall, Main Street, Ayer, Massachusetts. The Administrative Record Index (Appendix D of this ROD) identifies each of the items considered during selection of the remedial action.

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And Areas of Contamination 9, 11, 40, and 41 U.S. Army RFTA, Devens, Massachusetts

ASSESSMENT OF THE SITE

Actual or potential releases of substances from the debris disposal sites, if not addressed by the preferred alternative or one of the other active measures considered, may present a potential threat to human health or the environment.

DESCRIPTION OF THE SELECTED REMEDY

The major components of the Army's selected remedy are described below. Remedy descriptions are preceded by a discussion of how the remedy addresses: (1) current and/or future risks presented by the landfill sites, (2) restoration and protection of natural resources, or (3) support for redevelopment. The sites are grouped together according to the remedial action component to be implemented.

No formal risk evaluations have been performed for SA 6. 19th-century household debris at the site are not expected to pose unacceptable risk to human health or the environment. The selected remedy component for SA 6 is No Further Action under CERCLA. The site is being managed in conformance with Massachusetts Solid Waste Regulations.

SA 12,AOC 41

Currently, there are no risks to human health at SA 12 and AOC 41. Chemicals present at the two sites exceed screening standards established for residential land use. Were the sites to be occupied by year-round residents, potential health risks may be present. There are no plans for residential use of the sites. Potential, future risks to human health at both sites are, and will continue to be, addressed by restricting site access; access to both sites is controlled by the Army, who will retain the areas for military training use.

Contaminant concentrations in sediment adjacent to the Nashua River present risk to ecological receptors at SA 12. However, contaminant concentrations in sediment adjacent to the river were

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And Areas of Contamination 9, 11, 40, and 41 U.S. Army RFTA, Devens, Massachusetts higher than those in sediment at the foot of the landfill, suggesting that the river itself is a contributor to floodplain sediment contamination. Potential wildlife risks exist at AOC 41, due primarily to exposure to contaminants in surface soil. Surface soil removal will address the potential risks.

The selected remedy components for SA 12 and for AOC 41 include: (1) removal of visible man made surface debris to remove potential physical hazards, (2) removal of known surface soil concentrated contaminant areas, or "hot spots", that are a source of potential ecological risk, and

(3) future site monitoring to evaluate potential impacts from remaining debris. MADEP will be responsible for future monitoring at SA 12. As part of the activities documented in the 1996 South Post Impact Area (SPIA) Record of Decision, the Army will evaluate potential impacts to New Cranberry Pond ecological receptors from AOC 41.

AOC 9, AOC 11, SA 13, AOC 40

The selected remedy component for AOC 9 will assist the civilian redevelopment effort at Devens and remove the potential, future threat of contaminant release to area groundwater.

Planned expansion of the nearby wastewater treatment facility, which provides service to the expanding Devens community, would be inhibited by the presence of AOC 9 debris. Increased use of the treatment plant could raise the water table at AOC 9 and increase the potential for contaminants to come into contact with groundwater. Removal of landfill debris allows unimpeded expansion of the treatment facility and eliminates the potential, future release of contaminants to site groundwater.

The selected remedy component for AOC 11 supports the ongoing community effort to improve the water quality of the Nashua River. To preclude further discussion on whether landfill debris or upstream industrial activity represents the source of contaminants in river sediment near the landfill, the Army has agreed to remove AOC 11 debris. The selected action eliminates AOC 11 debris as a possible current and future source of risk to fish and wildlife resources, and as a possible contaminant contributor to nearby wetlands and downstream areas of the Nashua River.

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And Areas of Contamination 9, 11, 40, and 41 U.S. Army RFTA, Devens, Massachusetts

The selected remedy component for SA 13 assists civilian redevelopment at Devens. Removal of debris at SA 13 eliminates the threat of potential risk within an area of possible redevelopment. Potential risks to sensitive aquatic receptors may exist at SA 13 in the wet area downgradient of the landfill. Removal of debris and wet area soil, followed by site restoration, will address the potential ecological risks.

The selected remedy component for AOC 40 eliminates the threat of potential, future risk to a nearby public groundwater supply well, thus assisting civilian redevelopment at Devens.

Expanded use of the nearby Patton water supply well, which provides service to the expanding Devens community, would otherwise be prohibited due to the presence of AOC 40 debris;

increased use of the Patton well would draw groundwater from AOC 40 toward the well.

Removal of landfill debris allows unimpeded, expanded use of the water supply well. Debris removal will also allow the planned realignment of Patton Road to proceed unhampered by the presence of an abutting landfill. The proposed road realignment was initially envisioned in the Approved Reuse Plan for Devens.

Debris from AOC 9, AOC 11, SA 13, and AOC 40 will be excavated and either consolidated at a new landfill cell to be constructed at the former Golf Course Driving Range, or disposed of offsite. If constructed, the new cell will be lined and capped, and long-term groundwater quality monitoring will be performed. Debris excavations at the four sites will be backfilled and regraded.

Major components of the selected remedy are:

No further action

SA 12, AOC 41

• Surface debris removal

• Known hot-spot removal

• Site monitoring

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And Areas of Contamination 9, 11, 40, and 41 U.S. Army RFT A, Devens, Massachusetts

AOC 9, AOC 11, SA 13, AOC 40

• Debris excavation, backfill, and regrading

• Wetlands restoration at AOC 9, AOC 11, and AOC 40

• Consolidation of excavated debris at onsite Consolidation Landfill, or transport to an offsite landfill

• If applicable, cover system monitoring and maintenance, and institutional controls at the

Consolidation Landfill

• Institutional controls and five-year site reviews at those sites where unrestricted future use is not achievable or economical

STATE CONCURRENCE

The Commonwealth of Massachusetts has concurred with the selected remedy. Appendix E of this ROD contains a copy of the Declaration of State Concurrence.

STATUTORY DETERMINATIONS

The selected remedy is consistent with CERCLA and, to the extent practicable, the NCP. The remedy is protective of human health and environment, and complies with federal and Commonwealth requirements that are legally applicable or relevant and appropriate to the remedial action. The remedy uses permanent solutions to the maximum extent practicable.

Because treatment of the principal source of contamination was found not to be practicable, this remedy does not satisfy the statutory preference for treatment as a principal element.

Institutional controls and five-year reviews will be implemented at those sites where debris is excavated and removed, but unrestricted future land use is not achievable or economical.

Institutional controls will also be implemented for the consolidation landfill, should onsite consolidation be selected as the debris disposal option.

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DECLARATION FOR THE RECORD OF DECISION

Study Areas 6, 12, and 13 And Areas of Contamination 9, 11, 40, and 41 U.S. Army RFTA, Devens, Massachusetts

The foregoing represents the selection of a remedial action by the U.S. Department of the Anny and the U. S. Environmental Protection Agency, with the concurrence of the Commonwealth of Massachusetts Department ofEnvirorunental Protection.

Concur and recommend for immediate implementation:

U.S. DEPARTMENT OF THE ARMY

R;y(md J . Fatz Deputy Assistant Secretary of the Anny for Environmental Safety and Occupational Health

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Date

DECLARATION FOR THE RECORD OF DECISION

Study Areas 6, 12, and 13

And Areas of Contamination 9, 11, 40, and 41 U.S. Army RFTA, Devens, Massachusetts

The foregoing represents the selection of a remedial action by the U.S. Department of the Army and the U. S. Environmental Protection Agency, with the concurrence of the Commonwealth of Massachusetts Department of Environmental Protection.

Concur and recommend for immediate implementati_on:

U.S. ENVIRONMENTAL PROTECTION AGENCY

---1 ~ \ \_._~' ~ John P. DeVillars Regional Administrator U.S. Environm_ental Protection Agency, New England

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DECISION SUMMARY

And Areas of Contamination 9, 11, 40, and 41 U.S. Army RFT A, Devens, Massachusetts

DECISION SUMMARY

I. SITE NAME, LOCATION, AND DESCRIPTION

Fort Devens is a Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) National Priorities List (NPL) site located in the Towns of Ayer and Shirley (Middlesex County) and Harvard and Lancaster (Worcester County), approximately 35 miles northwest of Boston, Massachusetts. Prior to closure, the installation occupied approximately 9,600 acres and was divided into the North Post, Main Post, and South Post (Figure 1 in Appendix A).

This Record of Decision (ROD) addresses landfilled debris at Study Areas (SAs) 6, 12, and 13, and Areas of Contamination (AOCs) 9, 11, 40, and 41. AOC 9 is located on the Former North Post of Devens. AOCs 11 and 40, and SA 13 are located on the Former Main Post of Devens.

SAs 6 and 12, and AOC 41 are located on the South Post Reserve Forces Training Area (RFTA) (see Figure 1 in Appendix A).

A. SA6

SA 6 is located on the eastern side of Shirley Road on the South Post (see Figure 1 in Appendix A). The South Post is to be retained by the Army for continued military training. SA 6 was used between 1850 and 1920, prior to Army ownership, for disposal of household debris.

Debris was deposited in a low area, less than one-quarter acre in size, south of the access road (see Figure 2 of Appendix A). SA 6 is moderately forested with hardwood trees. The disposal area has not been covered, and debris is visible on the ground surface.

Army investigations at SA 6 determined that the landfill contains household debris, primarily metal and glass. The volume of debris in the landfill is approximately 500 cubic yards ( cy).

Archaeologists have determined that SA 6 may be valuable in researching the socioeconomic status and trash disposal behavior of 19th Century northern Lancaster residents.

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And Areas of Contamination 9, 11, 40, and 41 U.S. Army RFTA, Devens, Massachusetts

B. AOC9

AOC 9 is located on the former North Post, north of Walker Road and west of the wastewater treatment plant (see Figure 1 in Appendix A). The landfill was operated from the late 1950s until 1978 and was used by the Army, National Guard, contractors, and off-post personnel. Landfill material at AOC 9 is generally demolition debris, including wood, concrete, asphalt, metal, brick, glass, and tree stumps. Debris volume is estimated to be approximately 112,000 cy. Because of the extent of the partially vegetated cover, the area is generally not recognizable as a former landfill.

A geophysical survey was conducted during the site investigation to supplement information derived from evaluation of aerial photographs and to help delineate the actual limits of the landfill. The results of the survey assisted in the placement of test pits and groundwater monitoring wells, and provided insight into the distribution of landfill debris. Results of the geophysical survey indicated that the landfill consists of five areas: a larger northern pod containing the majority of landfilled materials, and four smaller southern pods adjacent to the wetlands containing mostly near-surface debris (see Figure 3 of Appendix A).

C. AOC 11

AOC 11 is located east of Lovell Road on the Main Post, adjacent to the Nashua River (see Figure 1 in Appendix A). The two-acre landfill received wood-frame hospital demolition debris from 1975 to 1980. Debris volume is estimated to be approximately 35,000 cy. The landfill is within a wetlands complex that runs along the western side of the Nashua River (see Figure 4 in Appendix A). East of the landfill, a 40-ft wide soil berm separates the landfill from the Nashua River. Refuse, including large pieces of metal, wood, bricks, and other construction debris is exposed at the ground surface throughout the site, except where an access road has been constructed over the fill. The landfill area is vegetated and is bordered on the north and south by wetlands.

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D. SA 12

Study Areas 6, 12, and 13

And Areas of Contamination 9, 11, 40, and 41 U.S. Army RFTA, Devens, Massachusetts

SA 12, about one-half acre in size, is located on a steep, wooded slope adjacent to the Nashua River floodplain and partially encroaching on wetlands on the South Post. The landfill is located across Dixie Road from Band P Ranges (see Figures 1 and 5 in Appendix A). SA 12 was used by the Army beginning in 1960, was still in use in 1982, and appeared in 1988 to have been inactive for several years. The debris came from construction and range operations.

Debris at SA 12 consist mostly of lumber, sheet metal, concrete, and leaves mixed with soil.

Debris volume is estimated to be approximately 8,700 cy.

E. SA 13

SA 13 was used between 1965 and 1990 for disposal of construction debris, stumps, and brush.

Debris volume is estimated to be approximately 10,000 cy. The landfill is less than one acre in size and is located on the west side of Lake George Street near Hattonsville Road on the former Main Post (see Figures 1 and 6 in Appendix A).

In 1989, recently disposed stumps, branches, steel fencing, plumbing fixtures and pipes were removed from the site. The landfill is currently closed to debris disposal.

SA 13 is surrounded by large trees, but no trees are growing on the landfill itself. Tree stumps, limbs, and trunks have been deposited on the surface of the landfill and down the steep lower slope. A wetland is located at the base of this slope.

F. AOC40

AOC 40 occupies approximately four acres along the edge of Patton Road in the southeastern part of the former Main Post of Fort Devens. It extends for approximately 800 feet along Patton Road and out into the former wetland along Cold Spring Brook, now mostly submerged beneath Cold Spring Brook Pond (see Figures 1 and 7 in Appendix A). The upper surface of the landfill slopes gently toward the north and east. The surface is densely covered with small trees and

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And Areas of Contamination 9, 11, 40, and 41 U.S. Army RFTA, Devens, Massachusetts scrub, the trees being predominantly pines. The edge of the landfill falls off abruptly to the wetland or to the pond with an elevation drop that ranges between 10 and 20 feet.

Debris in the landfill is mostly wood, concrete, asphalt, metal, brick, wire, ash, stumps, and logs.

Debris volume is estimated at approximately 110,000 cy. The AOC 40 landfill is located approximately 600 feet from the Patton water supply well, within the well's recharge zone.

G. AOC41

AOC 41 is located on the former South Post of Fort Devens, approximately one-half mile west of the Still River Gate, on the north shore of New Cranberry Pond (see Figures 1 and 8 in Appendix A). The landfill, less than one-quarter acre in size, was used up to the 1950s for disposal of nonexplosive military and household debris. The site is overgrown with trees and brush.

Debris at AOC 41 includes beverage cans, bottles, and motor vehicle parts. Debris volume is estimated to be approximately 1,500 cy.

II. SITE IDSTORY AND ENFORCEMENT ACTIVITIES

A. Land Use and Response History

Fort Devens was established in 1917 as Camp Devens, a temporary training camp for soldiers from the New England area. In 1931, the camp became a permanent installation and was renamed Fort Devens. Throughout its history, Fort Devens served as a training and induction center for military personnel, and as a unit mobilization and demobilization site. All or portions of this function occurred during World Wars I and II, the Korean and Vietnam conflicts, and operations Desert Shield and Desert Storm. During World War II, more than 614,000 inductees were processed, and Fort Devens reached a peak population of 65,000.

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And Areas of Contamination 9, 11, 40, and 41 U.S. Army RFTA, Devens, Massachusetts

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

Fort Devens was selected for cessation of operations and closure under the Department of Defense Base Realignment and Closure Act of 1990 (Public Law 101-510). The installation was officially closed in 1996.

Descriptions of the landfill sites, including contamination assessments and risk evaluations, where applicable, can be found in the following data packages, Site Investigation (SI) reports, and Remedial Investigation (RI) reports:

Site

SA6

SA 12, SA 13

AOC9

AOC 11

AOC40

AOC41

TABLE 1

SUMMARY OF REPORTS

Investigation Report Reference

Landfill Study Data Package (ABB-ES, 1994b) Supplemental Site Investigation Data Packages (ABB Environmental Services, Inc. [ABB-ES], 1994a) SI Report (ABB-ES, 1995b) SI Report (ABB-ES, 1996a) SI Report (Arthur D. Little, 1994) RI Report (Arthur D. Little, 1995) RI Report (E&E, 1993) Supplemental RI Report (ABB-ES, 1993) SI Report (ABB-ES, 1995b) RI Report (ABB-ES, 1996c)

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And Areas of Contamination 9, 11, 40, and 41 U.S. Army RFT A, Devens, Massachusetts

B. Enforcement and Study History

On December 21, 1989, Fort Devens was placed on the NPL under CERCLA as amended by the Superfund Amendments and Reauthorization Act (SARA). A Federal Facilities Agreement (Interagency Agreement [IAG]) was developed and signed by the Army and U.S. Environmental Protection Agency (USEPA) New England on May 13, 1991, and finalized on November 15, 1991. The IAG provides the framework for the implementation of the CERCLA/SARA process at Fort Devens.

In 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 an Enhanced Preliminary Assessment (PA) in 1992. The Enhanced PA identified and characterized Areas Requiring Environmental Evaluation (AREEs) associated with historical and current uses of the Devens property. The Enhanced PA recommended that site reconnaissance and a geophysical survey be conducted at each of the seven landfills to determine their exact location and areal extent. A field investigation comprised of surface water, sediment, soil, and/or groundwater sampling would follow.

Sis were conducted at SAs 12 and 13, and AOCs 9, 40, and 41 to verify the presence or absence of environmental contamination and to determine whether further investigation or remediation was warranted. In addition, supplemental SI activities were conducted at SAs 12 and 13, and AOC 41 to address data gaps identified in the SI reports. Rls were completed at AOCs 11, 40, and 41 to further assess contaminant distribution; the Rls included baseline human health and ecological risk assessments for the three sites.

Predesign investigations were conducted at SAs 6, 12, and 13, and AOC 9 (ABB-ES, 1994b) to define depth, areal extent, type of waste, composition of waste, and site conditions to help identify appropriate remedial alternatives.

The Landfill Consolidation Feasibility Study (FS) Report (ABB-ES, 1995a) evaluated options to consolidate debris from the seven landfills into a single waste disposal site. After reviewing the FS report, the U.S. Army Forces Command (FORSCOM) requested evaluation of non-

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And Areas of Contamination 9, 11, 40, and 41 U.S. Army RFTA, Devens, Massachusetts consolidation, containment options such as capping landfills in-place. In response to FORSCOM comments, the Debris Disposal Area Technical Memorandum (ABB-ES, 1996b) was issued in February 1996. The memorandum evaluated a cap-in-place and a consolidation option for each of the seven landfills.

To further respond to FORSCOM comments, the Landfill Remediation FS Report was prepared (ABB-ES, 1997). This FS report evaluated nine debris management alternatives, including various combinations of no further action, capping in-place, and debris removal and consolidation.

In the December 1997 Proposed Plan, the Army proposed an alternative that consisted of debris removal at three of the debris disposal areas (AOCs 9 and 40, and SA 13), with consolidation at a new landfill to be constructed in the area near the existing Shepley's Hill Landfill. Public comment on the Plan indicated a community preference for debris disposal either in an offsite landfill, or in a new onsite landfill in an alternate location. Because of the site's proximity to the Nashua River floodplain, the community also indicated a preference for full excavation and removal of debris from AOC 11.

In response to public comment, the Army issued a second Proposed Plan in November 1998.

The proposed alternative included full debris removal at AOCs 9, 11, and 40, and SA 13, with disposal either at an offsite landfill, or at a new onsite landfill to be constructed at the former Golf Course Driving Range.

The Responsiveness Summary in Appendix C presents public comment received on each of the Army's two proposals, along with Army responses. The information in Appendix C helps describe how public comments influenced remedy selection.

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And Areas of Contamination 9, 11, 40, and 41 U.S. Army RFTA, Devens, Massachusetts

III. COMMUNITY PARTICIPATION

The Army has held regular and frequent information meetings, issued fact sheets and press releases, and held public meetings to keep the community and other interested parties informed of activities at the seven landfills.

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

The Army, as part of its commitment to involve the affected communities, forms a RAB when an installation closure involves transfer of property to the community. The Fort Devens RAB was formed in February 1994. The RAB initially consisted of 28 members (15 original TRC members plus 13 new members) representing the Army, USEPA New England, MADEP, local governments, and citizens of the local communities. The RAB currently consists of 19 members.

It meets monthly and provides advice to the installation and regulatory agencies on the Devens

RFT A cleanup programs. Specific responsibilities include: addressing cleanup issues such as land use and cleanup goals; reviewing plans and documents; identifying proposed requirements and priorities; and conducting regular meetings open to the public.

On December 8, 1997 the Army issued the first of two Proposed Plans to interested citizens and organizations. The Army made the Proposed Plan available to the public at information repositories at the town libraries in Ayer, Shirley, Harvard, and Lancaster, and at the Devens BRAC Environmental Office. The Army responded to a request by the Town of Ayer selectmen

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And Areas of Contamination 9, 11, 40, and 41 U.S. Army RFTA, Devens, Massachusetts by mass-mailing copies of the Proposed Plan to residential address in six central Massachusetts U.S. Postal Service zip codes, including 01432 (Ayer), 01451 (Harvard), 01464 (Shirley), 01467 (Still River), 01523 (Lancaster), and 01561 (South Lancaster). The December 1997 Proposed Plan described the Army's preferred remedy for cleanup of the seven landfills. Debris at three of the landfills (AOCs 9 and 40, and SA 13) would be completely excavated and relocated at a new landfill to be constructed near the existing Shepley's Hill Landfill. The Proposed Plan described opportunities for public participation in the decision process, and provided details on the public comment period and public meeting planned for January 8, 1998.

Public notices announcing the January 8 meeting were published on three different occasions. A notice appeared in the Times Free Press/Public Spirit, the Worcester Telegram, and the Fitchburg-Leominster Centennial and Enterprise during the weeks of December 7 and December 28, 1997, and January 4, 1998. A notice appeared in the Lowell Sun during the week of December 7, 1997, and twice during the week of January 4, 1998. At the meeting, the Army announced the extension of the public comment period from the CERCLA-typical 30 days to 90 days. During the public comment period, the Army accepted comments on the alternatives presented in the FS report and the Proposed Plan, and on other documents released to the public.

The 90-day comment period began on December 8, 1997, and ended on March 9, 1998.

A second public meeting was conducted on February 25, 1998. During the meeting, the Army presented additional details of the preferred alternative presented in the December 1997 Proposed Plan. A public notice announcing the February 25 meeting appeared the week of February 15, 1998 in the Times Free Press/Public Spirit, the Worcester Telegram, the Fitchburg-Leominster Centennial and Enterprise, and the Lowell Sun.

Public comment on the December 1997 Proposed Plan indicated a community preference for debris disposal either in an offsite landfill, or in a new onsite landfill in an alternate location.

Because of the site's proximity to the Nashua River floodplain, the community also indicated a preference for full excavation and removal of debris from AOC 11.

In response to public comment, the Army issued a revised Proposed Plan on November 25, 1998.

The proposed alternative in the November 1998 Proposed Plan included full debris removal at

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And Areas of Contamination 9, 11, 40, and 41 U.S. Army RFTA, Devens, Massachusetts

AOCs 9, 11 , 40, and SA 13, with disposal either at an offsite landfill, or at a new onsite landfill to be constructed at the former Golf Course Driving Range. A Feasibility Study Addendum Report (Harding Lawson Associates [HLA ], 1998) evaluated the proposed alternative, and others formulated in response to public comment.

The Army made the November 1998 Proposed Plan available to the public at information repositories at the town libraries in Ayer, Shirley, Harvard, and Lancaster, and at the Devens BRAC Environmental Office. As with the previous Proposed Plan, the November 1998 Proposed Plan was mass-mailed to residential addresses in the six central Massachusetts zip codes which comprise the former Fort Devens. The November 1998 Proposed Plan described opportunities for public participation in the decision process, and provided details on the public comment period and public meeting planned for December 10, 1998.

Public notices announcing the December 10 meeting were published in the Times Free Press/Public Spirit during the week of November 29, 1998, and in the Worcester Telegram, the Fitchburg-Leominster Centennial and Enterprise, and Lowell Sun during the week of December 6, 1998. At the meeting, the Army announced the extension of the public comment period from the CERCLA-typical 30 days to 45 days. During the public comment period, the Army accepted comments on the alternatives presented in the FS report and the Proposed Plan, and on other documents released to the public. The 45-day comment period began on November 25, 1999, and ended on January 11, 1999.

As with the two previous meetings, the December 10 public meeting provided opportunity for open discussion concerning proposed cleanup. Transcripts of the three public meetings, public comments, and the Army's response to comments are included in the Responsiveness Summary (Appendix C).

Supporting documentation for the decision regarding the seven landfills is contained in the Administrative Record. The Administrative Record is a collection of all the documents considered by the Army in choosing the remedy for the seven landfill sites. The Army has made the Administrative Record available for public review at the Devens BRAC Environmental Office, and at the Ayer Town Hall, Ayer, Massachusetts. An index to the Administrative

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