KGS_2018c_2017_Annual_Long-Term_Monitoring_and_Maintenance_Report_AOC_A7_Sudbury_Devens.pdf

KOMAN Government Solutions, LLC Phone (508) 366-7442 293 Boston Post Road West, Suite 100 Fax (508) 366-7445 Marlborough, Massachusetts 01752 www.komangs.com

March 21, 2018

U.S. Army Corps of Engineers New England District 696 Virginia Road Concord, MA 01742 Attn: Ms. Penelope Reddy

RE: Draft 2017 Annual Long-Term Monitoring and Maintenance Report Area of Contamination A7 Former Sudbury Training Annex, Sudbury, MA Contract No. W912WJ-15-C-0002

Dear Ms. Reddy, KOMAN Government Solutions, LLC (KGS) is pleased to provide with this letter, electronic and paper copies of the Draft 2017 Annual Long-term Monitoring and Maintenance Report Area of Contamination (AOC) 7, Former Sudbury Training Annex in Sudbury, MA. The report describes the work conducted in 2017 for the landfill inspection, maintenance, and monitoring program; the groundwater monitoring program; and the maintenance of institutional controls.

In accordance with the Federal Facility Agreement, agency review is requested within 45 days (May 5, 2018).

Please contact me at (508) 219-6771 or jropp@komangs.com if you have any questions or require additional information.

Sincerely, KOMAN Government Solutions, LLC

James Ropp, P.E.

Project Manager cc: Robert Simeone, BRAC Devens, MA Christine Williams, EPA Region 1, Boston, MA David Chaffin, MassDEP Boston Tom Eagle, USFWS, Sudbury, MA

KGS File

March 2018

Prepared for:

U.S. Army Corps of Engineers

New England District Concord, Massachusetts

Prepared by:

293 Boston Post Road West, Suite 100

Marlborough, MA 01752 Contract No.: W912WJ-15-C-0002

2017 ANNUAL

LONG-TERM MONITORING

AND MAINTENANCE REPORT

AREA OF CONTAMINATION A7

FORMER SUDBURY TRAINING ANNEX

SUDBURY, MA

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NOTICE

The United States Department of Defense, Department of Army, funded wholly or in part the preparation of this document and work described herein under Contract No. W912WJ-15-C- 0002. Mention of trade names or commercial products does not constitute endorsement or recommendation for use.

This page is intentionally left blank.

TABLE of CONTENTS Section Page i

INTRODUCTION ........................................................................................................... 1-1 REPORT ORGANIZATION ............................................................................... 1-1 SITE BACKGROUND ........................................................................................ 1-1

LONG-TERM GROUNDWATER MONITORING ....................................................... 2-1 PREPARATION FOR SAMPLING .................................................................... 2-1

SAMPLING ......................................................................................................... 2-1 EQUIPMENT DECONTAMINATION .............................................................. 2-1 INVESTIGATION-DERIVED WASTE ............................................................. 2-1

GROUNDWATER ELEVATION MEASUREMENTS ..................................... 2-1

LABORATORY TESTING AND ANALYSES ............................................................. 3-1 ANALYSES ......................................................................................................... 3-1 ANALYTICAL RESULTS ................................................................................. 3-1

QUALITY CONTROL .................................................................................................... 4-1

FIELD QUALITY CONTROL............................................................................ 4-1

DATA EVALUATION FOR THE FALL 2017 SAMPLING EVENT .............. 4-1

LANDFILL MONITORING ........................................................................................... 5-1 FALL 2017 INSPECTION REPORT .................................................................. 5-1

YEARLY LANDFILL MAINTENANCE .......................................................... 5-2

INSTITUTIONAL CONTROLS ..................................................................................... 6-1 DOCUMENT REVIEWS .................................................................................... 6-1

INSTITUTIONAL CONTROL INTERVIEWS .................................................. 6-1

PHYSICAL ON-SITE INSPECTIONS ............................................................... 6-1

6.3.1 Area of Contamination A7 ....................................................................... 6-2

6.3.2 Areas of Contamination P31 and P58 ...................................................... 6-2 INSTITUTIONAL CONTROL SUMMARY...................................................... 6-2

CONCLUSIONS.............................................................................................................. 7-1

REFERENCES ................................................................................................................ 8-1 ii

FIGURES

Figure 1-1 Site Location, Former Sudbury Training Annex Figure 1-2 Site Layout, AOC A7 Figure 1-3 Site Layout, AOC P31 and AOC P58 Figure 2-1 Interpretive Water Table Elevation, AOC A7, January 15, 2018

TABLES

Table 2-1 Sample Analysis Methods, Containers, Holding Times, and Preservatives Table 2-2 AOC A7 Groundwater Monitoring Locations Table 2-3 AOC A7 Groundwater Elevations, January 2018 Table 3-1 AOC A7 Groundwater Analytical Results Table 3-2 Summary of Historical Groundwater Target Compounds at AOC A7, 1996 - 2017

APPENDICES

APPENDIX A Groundwater Field Sampling Forms

APPENDIX B Laboratory Analytical Reports

APPENDIX C Analytical Data Validation Reports

APPENDIX D Geotechnical Engineering Annual Inspection Report Fall 2017

APPENDIX E Annual Land Use Control Checklists and Interviews

APPENDIX F Responses to Comments [reserved] iii

ACRONYMNS AND ABBREVIATIONS

AOC Area of Contamination Army U.S. Army CERCLA Comprehensive Environmental Response, Compensation and Liability Act CMR Code of Massachusetts Regulations COC Chemical of Concern COD chemical oxygen demand DO dissolved oxygen DoD Department of Defense FEMA Federal Emergency Management Agency IC Institutional Control KGS KOMAN Government Solutions, LLC LTM long-term monitoring LTMM long-term monitoring and maintenance LTMMP Long-Term Monitoring and Maintenance Plan MassDEP Massachusetts Department of Environmental Protection NAE New England District NPL National Priorities List ORP oxidation-reduction potential OU Operable Unit PCE tetrachloroethene QSM Quality Systems Manual RCRA Resource Conservation and Recovery Act ROD Record of Decision Sudbury Annex former U.S. Army Sudbury Training Annex USACE U.S. Army Corps of Engineers USEPA U.S. Environmental Protection Agency USFWS U.S. Fish and Wildlife Service VOC volatile organic compound iv

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INTRODUCTION

KOMAN Government Solutions, LLC (KGS) prepared this Annual Report to present results of the long-term monitoring and maintenance (LTMM) activities conducted in 2017 for Area of Contamination (AOC) A7, known as the Old Gravel Pit Landfill, located at the former U.S. Army (Army) Sudbury Training Annex (Sudbury Annex). The report also presents inspection activities conducted at AOCs P31 and P58 (together termed the Sudbury Road Dump), for which a Five-Year Review [U.S. Army Corps of Engineers (USACE), New England District (NAE), 2006] indicated that further review was warranted. KGS prepared this report on behalf of the USACE-NAE, under contract number W912WJ-15-C-0002.

Report Organization

This Annual Report is organized as follows:

Section 1.0 provides the project background and a brief overview of the Sudbury Annex history;

Section 2.0 summarizes the long-term monitoring (LTM) sampling activities;

Section 3.0 presents the 2017 LTM sampling analytical results;

Section 4.0 summarizes the field data and analytical data quality control;

Section 5.0 summarizes the 2017 landfill inspection, monitoring, and maintenance activities;

Section 6.0 presents a summary and evaluation of the Institutional Controls (IC);

Section 7.0 presents conclusions; and

Section 8.0 presents the references used in the preparation of this document.

The activities discussed in this Annual Report were conducted in accordance with the Long-Term Monitoring and Maintenance Plan (LTMMP) [Sovereign Consulting, Inc. and HydroGeologic Inc.

(Sovereign/HGL), 2015] to fulfill the requirements of the Source Control Record of Decision (ROD) (O.H. Materials Remediation Services Corporation, 1995), which includes the LTM and Institutional Control (IC) protocols at AOC A7. This report also includes IC verification activities for AOCs P31 and P58.

Site Background

The Sudbury Annex was listed on the National Priorities List (NPL) site from February 1990 through January 2002, in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980. The former training annex occupies approximately 4.3 square miles in the Massachusetts towns of Hudson, Marlborough, Maynard, Stow, and Sudbury. A site location map indicating the general site location and physical setting is presented on Figure 1-1. Hudson Road/Sudbury Road divides the installation into a larger northern section and a smaller southern section. The Sudbury Annex became part of Fort Devens in 1982 (U.S. Army Garrison Fort Devens).

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AOC A7 is a 10-acre landfill located between Patrol Road and the Assabet River along the northern installation boundary (Figure 1-2). AOC P31 and AOC P58 are located at the southwestern boundary of the northern part of the former Annex (Figure 1-3).

Access to the AOC A7 landfill is gained from Patrol Road or Track Road via locked gates. The northern edge of the site is less than 100 feet from the Assabet River at its closest point. The landfill is located on the northern lower slope and toe of a hill that slopes downward to the Assabet River.

The ROD for the Source Control of the Operable Unit (OU) at AOC A7 was signed by the Army and U.S. Environmental Protection Agency (USEPA) in September 1995. The ROD for Management of Migration was signed by the Army and USEPA in September 1997. The Massachusetts Department of Environmental Protections (MassDEP) concurred with the RODs and the selected source remedy which included:

removal and off-site disposal of chemical waste debris in the laboratory dump area;

construction of a Resource Conservation and Recovery Act (RCRA) Subtitle C landfill cap to contain the remaining site contaminants;

operation and maintenance;

ICs and land use restrictions to limit future use of land at AOC A7;

long-term groundwater monitoring; and, Five-Year Reviews to assess whether the remedy remains protective of human health and the environment.

The Sudbury Annex site was removed from the NPL in January 2002. At that time, 2,205 acres were transferred to the U.S. Fish and Wildlife Service (USFWS), 4.1 acres were transferred to the U.S. Air Force, and 71.4 acres were transferred to the Federal Emergency Management Agency

(FEMA).

The current monitoring program consists of annual groundwater monitoring, annual visual inspection of the landfill cap and surrounding area, and landfill gas vent monitoring that is conducted every five years prior to the five-year review (Sovereign/HGL, 2015). Annual mowing of the landfill is also conducted, and other maintenance activities are conducted as the maintenance needs are identified. The LTMMP is designed to satisfy federal and state applicable or relevant and appropriate regulations related to post-closure care of the landfill.

The current LTMMP (Sovereign/HGL, 2015) includes the previous LTMMP (HGL, 2009) and changes implemented based on annual sampling results and recommendations in the 2016 Five- Year Review:

Remove metals analyses from the LTM program via a recommendation in the 2016 f i v e-year review report. This recommendation was included in the 2016 Five-Year Review Report for the Former Sudbury Training Annex (KGS, 2016a).

Remove well OHM-A7-51 from the LTM sampling program based on the last groundwater analytical exceedance documented in October 2003 [ te t rachloroethene (PCE)] and a compliance point, per 310 Code of Massachusetts Regulations (CMR) 19.132 (2), that is located hydraulically downgradient (SUD-A07- 065).

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Remove well OHM-A7-09 from the LTM sampling program based on no historical groundwater analytical exceedances and a compliance point, per 310 CMR 19.132(1)(b), is located hydraulically downgradient (SUDWP-A07-01).

Continue sampling upgradient monitoring well SUD-A07-14 on an annual basis and revise sampling frequency to biennial, based on no groundwater analytical exceedances, after the 2016 five-year report. The 2016 Five-Year Review Report for Former Sudbury Training Annex (KGS, 2016a) recommended biennial sampling based on the lack of groundwater analytical exceedances. Upgradient monitoring well SUD-A07-14 is planned to be sampled again in 2018.

Continue sampling OHM-A7-08 and SUD-A07-065 on an annual basis until the 2 0 1 6 five-year review; and revise sampling frequency to biennial if a downward trend is maintained. The 2016 Five-Year Review Report for Former Sudbury Training Annex (KGS, 2016a) identified statistically significant downward concentration trends in OHM-A7-08 and SUD-A07-065 and recommended biennial sampling for these wells.

Wells OHM-A7-08 and SUD-A07-065 are planned be sampled again in 2018.

Recommend reducing the landfill gas vent monitoring from an annual frequency to every 5 years prior to the five-year review report.

Utilize global positioning system (GPS) coordinates and a GPS unit to locate surface water gauges during the annual sampling event.

The current groundwater monitoring program at AOC A7 includes biennial sampling from three monitoring wells and annual sampling of one well point, plus annual hydraulic gauging at thirteen monitoring wells and two staff gauges located across the AOC (Figure 1-2). The analytical parameters monitored include volatile organic compounds (VOC), organochlorine pesticides, total cyanide, chemical oxygen demand (COD), and field water quality parameters (temperature, dissolved oxygen [DO], pH, oxidation/reduction potential [ORP], specific conductance, and turbidity). The next biennial event is planned for 2018.

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LONG-TERM GROUNDWATER MONITORING

The LTM program at AOC A7 was conducted in accordance with the LTMMP (Sovereign/HGL, 2015) to monitor COC concentration trends over time. The 2017 sampling activities were conducted in December 2017 and January 2018.

Preparation for Sampling

The groundwater sampling event at AOC A7 was performed in accordance with the low-flow procedures documented in Low Stress (low flow) Purging and Sampling Procedure for the Collection of Groundwater Samples from Monitoring Wells [U.S. Environmental Protection Agency (USEPA) Region 1, 2017]. The field instruments used to measure water quality parameters (temperature, DO, pH, ORP, specific conductance, and turbidity) were calibrated daily in accordance with the manufacturer’s instructions and in accordance with USEPA’s Calibration of Field Instruments Standard Operating Procedure (USEPA Region 1, 2010). Details on analytical sample container and preservation requirements are presented in Table 2-1. Completed groundwater low-flow sampling forms documenting sampling and groundwater quality measurements, are presented in Appendix A.

Sampling

Groundwater at AOC A7 is sampled annually as part of the fall LTM events. Well point location, SUDWP-A07-01, was sampled on December 4, 2017. A description of the location, depth, screened interval, and sampling frequency for each well is listed in Table 2-2.

Equipment Decontamination

Non-dedicated sampling and monitoring equipment was decontaminated before and after use to prevent cross-contamination between wells. Decontamination was performed in accordance with the LTMMP (Sovereign/HGL, 2015).

Investigation-derived Waste

Investigation-derived waste generated during the LTMM activities consisted of purge water from wells and equipment decontamination water. Purge water was discharged back to the ground at the site of generation after sampling was completed in accordance with the LTMMP.

Groundwater Elevation Measurements

Groundwater elevation measurements were recorded on January 15, 2018. The depth to water was measured within a 24-hour period at each of the monitoring wells. The condition of the monitoring well network was inspected during the water level monitoring event. A summary of the water level measurements and the corresponding water elevation data is presented in Table 2-3. Groundwater elevation contours are presented on Figure 2-1.

Figure 2-1 shows groundwater generally flowing to the north-northwest towards the Assabet River, consistent with historical groundwater flow observations. The groundwater gradient was

0.071 feet per foot during the January 2018 event. The groundwater gradients were calculated

2-2 using locations considered to be representative of average conditions across the site (SUD-A01- 014 and OHM-A7-09). Although the groundwater gradient generally varies based on seasonal variations in groundwater elevations, the illustrated flow paths are deemed as generally representative of site conditions. The overall groundwater flow direction and seasonal variability at AOC A7 is well documented over 15 years of monitoring with little change in the nature of groundwater flow across the site.

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LABORATORY TESTING AND ANALYSES

Groundwater samples were collected from well point location SUDWP-A07-01 on December 4, 2017. TestAmerica Laboratories, Inc. (TestAmerica) of Savannah, Georgia was the primary contract laboratory used for the analysis of groundwater samples for the fall 2017 LTM event.

TestAmerica is compliant with the Department of Defense (DoD) Quality Systems Manual (QSM) for Environmental Laboratories, version 5.0 (DoD, 2013) under the DoD Environmental Laboratory Accreditation Program and holds current accreditation for all applicable analytical methods. The laboratory analytical report for the Sudbury 2017 sampling event is provided in Appendix B.

Analyses

The groundwater sample was analyzed at the laboratory for VOCs, organochlorine pesticides, total cyanide, and COD. The analytical methods and procedures used for the groundwater samples collected at AOC A7 are presented in Table 2-1.

Analytical Results

One field duplicate sample was collected for each of the analytical methods and was submitted as a blind duplicate to the laboratory with the native sample. One trip blank sample was submitted and analyzed for VOCs only. Analytical results from the 2017 sampling event were consistent with the results from 2006 through 2016. The 2017 sample results for the well point sample are presented in Table 3-1 and historical results for target COCs are summarized in Table 3-2.

The Fall 2017 results for VOCs, pesticides, total cyanide, and COD from the well point sample were non-detect for all target compounds as presented in Table 3-1. The 2017 non-detect results from the well point sample location are consistent the 2016 sample results, except for a low-level detection of COD (8.2 milligrams per liter [mg/L]) in 2016; The well point was not sampled in 2015 due to low water level.

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QUALITY CONTROL

As part of the 2017 groundwater sampling event, quality assurance/quality control samples were collected to evaluate sample collection, transportation, and analysis procedures.

Field Quality Control

One field duplicate sample was collected from well point SUDWP-A07-01 during the December 2017 sampling event and submitted for analysis. The field duplicate sample results are shown in Table 3-1. One trip blank sample was collected and submitted for VOC analysis.

Data Evaluation for The Fall 2017 Sampling Event

The analytical results from the 2017 sampling event were evaluated for data acceptability in accordance with the USEPA Region 1 data validation guidelines (USEPA New England, 2013) and the Quality Assurance Project Plan (QAPP) for the Annual Long-Term Monitoring (LTM) Program (KGS, 2016b). The method requirements from the DoD QSM version 5.0 (DoD, 2013) and the USEPA SW-846 QC guidance (USEPA, 2014) were also used as supplemental information. The data validation report for the 2017 Sudbury AOC A7 LTM sampling event are presented in Appendix C.

Based on the data evaluation elements reviewed (including holding times, blank sample results, field duplicate results, surrogate recoveries, laboratory control sample/laboratory control sample duplicate recoveries, and matrix spike/matrix spike duplicate recoveries), all data were acceptable as reported. No qualifications were needed.

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LANDFILL MONITORING

The November 2017 landfill inspection report is summarized in the following sections.

Fall 2017 Inspection Report

The AOC A7 RCRA cap and the surrounding area are monitored on an annual basis through visual inspections and field monitoring performed with landfill gas detection equipment. The landfill gas monitoring event performed in November 2017 is presented in the Geotechnical Engineering Annual Inspection Report Fall 2017 (Appendix D).

The AOC A7 landfill cap was inspected on November 15, 2017 by USACE personnel.

Observations were made regarding the vegetative cover, vegetation types, erosion, settlement, and general condition of the various features. The following list summarizes the findings and recommendations of the 2017 fall inspection:

The landfill cap is in generally excellent condition with no actively eroding areas or settlement. In general, the cap vegetation appears healthy, dense, and provides complete coverage of most areas of the cap, with grass and clover predominating. The cap and adjacent area vegetation were mowed on November 7, 2017, and a large tree leaning on the southeast portion of the fence was removed. No encroachment of wetland species on the cap was seen. It is recommended that future mowing of the cap continue to include mowing of the field area adjacent to the cap to prevent encroachment of woody and wetland species on the cap.

The access road from the entry gate and into the cap area is in relatively good condition;

however, vegetation has overgrown and established upon the gravel surface. There are no ruts, potholes, or eroded areas.

The security perimeter fence is in moderate condition. The large tree observed leaning on the southeastern section of the fence during the fall 2016 inspection was removed in April 2017 and the damaged section of fence was repaired in August 2017. Multiple trees are growing through and against the northern perimeter fencing. These small to medium trees should be removed, if feasible, before they damage the fence. Additionally, the access gate on the northern central portion of the fence line near monitoring well OHM-A7-09 was observed to be leaning and causing a gap in the gate which could facilitate trespassing. The gate was partially secured with a second new chain after the 2016 inspection and a new third chain was added higher on the gate in February 2018. Otherwise, there were no sagging or leaning fence sections noted during the inspection, and the main gate is operating normally. In general, trees should periodically be cleared from fence area as they naturally grow or fall onto the fence to avoid the potential for people to trespass across the cap or to prevent easier entry of wildlife that could burrow and become established around or within the cap soil cover. Trees leaning against the western, southern, and eastern portions of the fence were removed in February 2018. Trees along the northern fence will be addressed at a later date, as feasible.

The cap drainage system is in good condition. Drainage channels are free of sediment and debris; however, vegetation removal or cutting flush to ground should be more frequent and vigilant to eliminate unwanted vegetation. The grass on drainage channel bottoms is

5-2 generally in excellent condition, but some overgrown weedy plants are present in isolated areas. The vegetation on the side slopes is healthy and dense.

The toe drain appears to be functioning properly, and there are no associated slope stability or erosion problems. Toe drains were cleared of moss growth and other debris which is accumulating on the geotextile covering the drainage stone in February 2018. The excess loose geotextile fabric was removed in February 2018. Based on review of the cap design drawings, the observed geotextile fabric appears to be excess from construction (i.e., unnecessary to the current operation of the cover system) and extends too far over the coarse aggregate. The toe drain should continue to be monitored for vegetative growth, and the growth should be periodically cut down or removed to maintain the proper operation of the toe drain and coarser boulder rip rap at the northwest and northeast corners of the landfill cap.

The gas vent system is in good condition. The vent pipes are intact and functioning as intended. The four gas vents need the bird/insect screen replaced with a fitting that can be easily removed as one unit with a screwdriver. The four gas vents should be relabeled on two sides of the vent (north and south) to facilitate identification. New vent screens and labels are planned to be installed in 2018.

Per the LTMMP (Sovereign/HGL, 2015), landfill gas vent monitoring will be conducted every five years. The next landfill gas vent monitoring will be completed in 2020 to support the five-year review. The four landfill gas vents were inadvertently monitored during the 2017 landfill inspection and the results, which are discussed below, are consistent with past results. VOCs concentrations were negligible in the four gas vents (0.1 to 0.2 parts per million). Hydrogen sulfide, carbon monoxide, and/or methane were not detected. Landfill gas constituents represented by low oxygen (6.0 to 6.6 percent) and relatively high carbon dioxide (4.9 to 6.2 percent) were more prevalent on the two gas vents on the northern side of the landfill (V-2 and V-3) compared to the southern side of the landfill (V-1 and V-4), which may reflect differences in types of waste buried within the landfill. Oxygen was measured in the southern gas vents at concentrations of 16.3 to 16.9 percent, and carbon dioxide was measured at concentrations of 3.0 to 3.1 percent.

The detailed discussion of the 2017 landfill inspection and recommendations for 2018 are presented in the Geotechnical Engineering Annual Inspection Report Fall 2017 (Appendix D).

Yearly Landfill Maintenance

Trees leaning against the fence were removed in April 2017. The fence was repaired in August 2017. Landfill mowing was performed outside the flagged wetland boundary, by Gatsby Grounds of Lancaster, MA, in November 2017.

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INSTITUTIONAL CONTROLS

The 1995 Source Control OU ROD included ICs in the selected remedy for AOC A7 to restrict changes in land use at that location. An addendum to the 1998 LTMMP was approved in 1999 that prescribed IC inspection criteria to be performed annually. The 1999 addendum also included provisions for ICs at AOCs P31 and P58 to monitor for significant changes in site use and increases in exposure potential. The IC criteria include the following: 1) document reviews, 2) interviews, and 3) physical on-site inspections, each to be completed and reported with checklists.

Document Reviews

The following document, generated during 2017, was reviewed in accordance with the LTMMP:

2016 Annual Report: Long-Term Monitoring and Maintenance, Area of Concern A7, Former Sudbury Training Annex, Sudbury, Massachusetts (KGS, 2017).

Protectiveness Assessment for AOC P31/P58, Former Sudbury Training Annex, Stow, Massachusetts, Concord, Massachusetts (USACE-NAE, 2007).

In accordance with the LTMMP, a checklist has been prepared to illustrate how the documents were used to evaluate the ICs. The checklists for AOC A7, and AOCs P31 and P58 are included in Appendix E.1 and Appendix E.2.

Institutional Control Interviews

IC interviews are conducted on an annual basis to monitor the status of ICs at sections of the former Sudbury Annex that are no longer under Army control. Relevant federal agencies contacted include: USFWS (for the National Wildlife Refuge) and FEMA (six small parcels of the former training annex). Interviews with representatives from these agencies that are familiar with day-to-day activities on the property were conducted by telephone and/or e-mail. The interviews included discussions of the following content:

Status of past redevelopment or other construction or demolition activities.

Review of approved conditional exemptions, amendments and/or releases.

Review of any unauthorized uses and activities.

Review of corrective action to resolve unauthorized uses and activities.

Overall effectiveness of the institutional controls.

Status of anticipated future redevelopment or other construction or demolition activities.

Summaries of the interviews are presented in Appendix E.2 and E.3. The IC interviews indicated that no significant changes in site use or evidence of increased exposure potential were apparent for the 2017 reporting period.

Physical On-site Inspections

Physical on-site inspections are conducted on an annual basis at AOC A7, and AOCs P31 and P58 in accordance with the LTMMP. The inspections at AOC A7 include a comprehensive assessment of the landfill cap and its drainage features, as well as the condition of the site security fence and

6-2 the grassy/woodland area surrounding the landfill cap. The inspections at AOCs P31 and P58 are consisted of visual observations regarding the condition of the sites. The physical on-site inspections address each of the following items:

Land use conditions (presence of buildings and level of recreational use);

Evidence of any changes to the use of the AOC A7, P31, and P58 sites;

Evidence of any disturbance to the integrity of the landfill containment system or to the function of the monitoring system in place at AOC A7;

Evidence of any significant excavation or surface or subsurface soil disturbance at

AOC A7;

Evidence of any activities that have disrupted or otherwise negatively impacted the subsurface soil at the AOC A7, P31 and P58 sites below the depth of four feet; and

Other such conditions as the Army, USEPA, and MassDEP Project Managers may deem necessary to evaluate in order to continue the protectiveness of the ICs. The party conducting the inspection notes all observations, including observation of any known or suspected violations, on an inspection checklist.

6.3.1 Area of Contamination A7

Inspections of the AOC A7 landfill and the surrounding area were conducted by USACE on November 15, 2017. The landfill cap, the drainage features and surrounding area were found to be in good or excellent condition. A summary of the inspection is presented in Section 5.0 and specific details of the inspections and recommendations are included the Geotechnical Engineering Annual Inspection Report Fall 2017 (Appendix D).

6.3.2 Areas of Contamination P31 and P58

Visual inspections of AOCs P31 and P58 were conducted on November 7, 2017 and showed no evidence of any changes to the use of AOCs P31 and P58. The sites were vegetated and there was no evidence of dumping. An inspection checklist is included in Appendix E.4.

Institutional Control Summary

Document reviews, IC interviews and physical on-site inspections during the 2017 reporting period revealed no significant changes in site use or evidence of increased exposure potential for AOC A7, P31 and P58. The remedies implemented at these AOCs remain protective of human health and the environment.

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CONCLUSIONS

The 2017 sampling event occurred on December 4, 2017. Well point SUDWP-A07-01 was sampled. The laboratory analytical results were non-detect, thus there were no exceedences of the Massachusetts Groundwater-1 or Groundwater-3 standards. Groundwater level monitoring data recorded on January 11, 2018 was consistent with the historically-established north/northwest groundwater flow direction at the site.

The AOC A7 landfill cap remains in excellent condition based on the November 15, 2017 inspection. The drainage system and gas vent monitoring system are in good condition and functioning as intended. The access road and security fence are in good condition. The large tree observed leaning on the southeastern section of the fence has been removed. The access gate on the northern central portion of the fence line near monitoring well OHM-A7-09 is leaning and causing a gap in the gate. A chain and a lock were installed in February 2018 to eliminate the gap in the gate. The landfill and adjacent area were mowed during fall 2017.

LTMM activities at AOC A7 and AOCs P31 and P58, including groundwater sampling, landfill cap inspections, IC interviews, and IC inspections indicate that the selected remedies continue to be effective.

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REFERENCES

Department of Defense (DoD), 2013. DoD Quality Systems Manual for Environmental Laboratories, Version 5.0. Department of Defense Environmental Data Quality Workshop, July.

Hydrogeologic, Inc. (HGL), 2009. Long-Term Monitoring and Maintenance Plan. Former Sudbury Training Annex. Sudbury, Massachusetts. March.

O.H. Materials Remediation Services Corp., 1995. Record of Decision - Source Control Operable Unit, AOC A7, the Old Gravel Pit Landfill, AOC A9, the POL Burn Area, Fort Devens Sudbury Training Annex, Sudbury, Massachusetts. September.

KOMAN Government Solutions, LLC (KGS), 2016a. 2016 Five-Year Review Report for Former Sudbury Training Annex, Sudbury, Massachusetts. September.

KGS, 2016b. Quality Assurance Project Plan (QAPP) for the Annual Long-Term Monitoring (LTM) Program, Former Fort Devens Army Installation, Devens, Massachusetts. October.

KGS, 2017. 2016 Annual Report, Long-Term Monitoring and Maintenance, Area of Contamination A7, Former Sudbury Training Annex, Former Fort Devens Army Installation, Devens, MA. July.

Sovereign Consulting, Inc. and HydroGeologic, Inc (Sovereign/HGL), 2015. Long-Term Monitoring and Maintenance Plan for Former Fort Devens Army Installation and Sudbury Training Annex, Sudbury, Massachusetts. February.

U.S. Army Corps of Engineers, New England District (USACE-NAE), 2006. 2006 Five Year Review, Second Five Year Review Report for Former Sudbury Training Annex Sites, Sudbury, MA. September.

USACE-NAE, 2007. Protectiveness Assessment for AOC P31/P58, Former Sudbury Training Annex, Stow, Massachusetts, Concord, Massachusetts. April.

U.S. Environmental Protection Agency (USEPA), 2014. Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, SW-846, Fifth Edition, Update V. Office of Solid Waste and Emergency Response. July. (www.epa.gpv/hw-sw846/sw-846-compendium).

USEPA New England, 2013. USEPA New England, EPA – New England Environmental Data Review Program Guidance. April.

USEPA, Region 1, 2010. Calibration of Field Instruments, standard operating procedures, (temperature, pH, dissolved oxygen, conductivity/specific conductance, oxidation/reduction potential [ORP], and turbidity. North Chelmsford, MA. January.

USEPA, Region 1, 2017. Low Stress (low-flow) Purging and Sampling Procedure for the Collection of Groundwater Samples from Monitoring Wells (EQASOP-GW 004).

September.

FIGURES

Summer Street

Main Street

Maynard

Sudbury Road Pine Lake

Hudson Road

Pine Rest

Du tto n R oa d

Moore Road

Main Street

Former Sudbury Training Annex

Former Sudbury Training Annex

Assabet River

Lake Boon

White Pond

Willis Lake

Puffer Pond

UV27

UV117UV62

UV27

UV62

Sudbury

AOC P31 & AOC P58

AOC A7

Legend !( Area of Contamination (AOC)

Area of Contamination Perimeter Surface Water Course Major Road Former Sudbury Training Annex

2017 Annual Report Former Sudbury Training Annex

Former Fort Devens Army Installation Sudbury Training Annex, Sudbury, MA

293 Boston Post Road West, Suite 100, Marlborough, MA 01752

Figure 1.1

Date:

03/08/2018

0 2,0001,000

Feet µ Figure 1.1

Site Location Former Sudbury Training Annex

Former Sudbury Training Annex

MA

CT

NHVT

NY

RI

ME

Aerial Sources: Esri, DigitalGlobe, GeoEye, i-cubed, USDA FSA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community

Location Map

File: AR2017_SudburyTrainingAnnex.mxd

#0

#0

!A

!A

!A

!A

A7-3

A7-2

A7-1

A7-4

OHM-A7-12

OHM-A7-10

OHM-A7-52

OHM-A7-45

OHM-A7-11

OHM-A7-09

OHM-A7-51

OHM-A7-08

OHM-A7-46

SUDWP-A07-01

JO-A07-M61

SUD-A07-014

SUD-A07-M65

Eastern Staff Gauge

Northern Staff Gauge

Assabet River

Patrol Road

Track Road

Gate

Gate

Replicated Wetland

AOC A7

188184

8 20 4 20

Legend &< LTM Sample Well

&< LTM Well - Gauge Only

#0 Staff Gauge

")> Monitoring Well - Damaged

!> Monitoring Well - Abandoned !A Gas Vent

OHM-A7-08 Well/Gauge/Vent Identification [ Fence

Stump Pile Area

AAAAAAA

AAAAAAA

AAAAAAA

AAAAAAA Rip Rap

Area of Contamination (AOC) Topographic Contour (ft AMSL)

Figure 1.2 Site Layout

AOC A7

2017 Annual Report Former Sudbury Training Annex (AOC A7)

Former Fort Devens Army Installation Sudbury Training Annex, Sudbury, Massachusetts

293 Boston Post Road West, Suite 100, Marlborough, MA 01752

Figure 1.2

Date:

03/08/2018

0 12060

Feetµ

Notes:

LTM = long term monitoring JO-A07-M62 damaged and was replaced by SUDWP-A07-01 JO-A07-M61 could not be located Aerial Sources: Esri, DigitalGlobe, GeoEye, i-cubed, USDA FSA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community

File: AR2017_A7_Layout.mxd

Lake Boon

Lake Boon

AOC P31

AOC P58 Legend Areas of Concern Former Fort Devens Boundary

Figure 1.3 Site Layout

AOC P31 and AOC P58

2017 Annual Report AOC P31 and AOC P58

Former Fort Devens Army Installation Sudbury Training Annex, Sudbury, Massachusetts

293 Boston Post Road West, Suite 100, Marlborough, MA 01752

Figure 1.3

Date:

03/08/2018

0 15075

Feetµ

Aerial Sources: Esri, DigitalGlobe, GeoEye, i-cubed, USDA FSA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community

File: AR2017_AOCP31_P58.mxd

#0

#0

!A

!A

!A

!A

A7-3

A7-2

A7-1

A7-4

OHM-A7-12

OHM-A7-10

OHM-A7-52

OHM-A7-45

OHM-A7-11

OHM-A7-09

OHM-A7-51

OHM-A7-08

OHM-A7-46

SUDWP-A07-01

JO-A07-M61

SUD-A07-014

SUD-A07-M65

Eastern Staff Gauge

Northern Staff Gauge

Assabet River

Patrol Road

Track Road

Gate

Gate

Replicated Wetland

(213.19)

(202.25)

(194.46)

(182.87)

(179.44)

(177.35)

(196.57)

(184.32)

(179.88)

(179.02)

(178.82)

(180.59)

204202200198

AOC A7

Legend &< LTM Sample Well

&< LTM Well - Gauge Only #0 Staff Gauge

")> Monitoring Well - Damaged !> Monitoring Well - Abandoned !A Gas Vent

OHM-A7-08 Well/Gauge/Vent Identification (179.88) Groundwater Elevation (ft NGVD)

Groundwater Contour (ft NGVD) (Interval = 2 Feet) Groundwater Flow Direction

[ Fence Stump Pile Area

AAAAAAA

AAAAAAA

AAAAAAA

AAAAAAA Rip Rap

Area of Contamination (AOC)

Figure 2.1 Interpretive Water Table Elevation

Sudbury Annex - AOC A7 January 15, 2018

2017 Annual Report Former Sudbury Training Annex (AOC A7)

Former Fort Devens Army Installation Sudbury Training Annex, Sudbury, Massachusetts

293 Boston Post Road West, Suite 100, Marlborough, MA 01752

Figure 2.1

Date:

03/08/2018

0 12060

Feetµ

Notes:

NGVD = National Geodetic Vertical Datum of 1929 LTM = long term monitoring OHM-A7-11 was not used in calculating contours JO-A07-M62 damaged and was replaced by SUDWP-A07-01 Aerial Sources: Esri, DigitalGlobe, GeoEye, i-cubed, USDA FSA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community

File: AR2017_A7_Jan2018GWC.mxd

TABLES

Table 2-1

Sample Analysis Methods, Containers, Holding Times, and Preservatives

Former Sudbury Traning Annex, Sudbury, Massachusetts

Parameter Analysis

Method1 Sample Container 2 Preservative Holding Time

VOCs SW8260C 3 x 40-mL vials with teflon septa screw caps

HCl to pH < 2 (no headspace); 4 ± 2°C 14 days

Pesticides SW8081B 2 x 1-Liter amber glass 4 ± 2°C 7 days to extract; 40 days to analyze

COD E410.4 1 x 500-mL amber glass H2SO4 to pH < 2; 4 ±

2°C 28 days

Cyanide SW9012B 1 x 250-mL HDPE NaOH to pH > 12; 4 ±

2°C 14 days

Notes:

2 Additional sample containers/volume are required for matrix quality control samples.

1 “Methods for Chemical Analysis of Water and Wastes”, Cincinnati, OH July 2014, EPA 600-4-79-020. “Test Methods for Evaluating Solid

Waste, Physical and Chemical Methods”, USEPA SW-846, 5th Edition.

Table 2-2

AOC A7 Groundwater Monitoring Locations

Former Sudbury Training Annex, Sudbury, Massachusetts

Monitoring

Wells

Top of PVC

Riser Elevation

(ft NGVD)

Total Depth

(ft below

TOC)

Screened

Interval Depth

(ft below

TOC)

Top of Well

Screen Elevation

(ft NGVD)

Bottom of Well

Screen Elevation

(ft NGVD)

Screen

Length

(feet)

Location Description and Well

Depth Notes

Monitoring

Program

OHM-A7-08 219.84 35.6 20.6 - 35.6 199.24 184.24 15

Downgradient of former Lab Waste

Area (west end of landfill cap).

Biennial (2018), VOCs, Pesticides, COD, CN

OHM-A7-09 186.21 14.9 6.9 - 14.9 179.31 171.31 8

North of cap (at center) along Track

Road.

Water Level Only

OHM-A7-10 181.2 11.6 3.6 - 11.6 177.6 169.6 8

Along Track Road, east of OHM-A7-

9.

Water Level Only

OHM-A7-11 181.73 30.9 20.9 - 30.9 160.83 150.83 10 Adjacent to OHM-A7-10. Water Level Only

OHM-A7-12 187.09 20.8 5.8 - 20.8 181.29 166.29 15

East of toe drain on eastern edge of landfill.

Water Level Only

OHM-A7-45 210.01 22.2 7.2 - 22.2 202.81 187.81 15

West of cap near the west drainage ditch.

Water Level Only

OHM-A7-46 217.87 19.6 13.1 - 19.6 204.77 198.27 6.5

West end of cap; well-depth was measured on 10/17/2002 as 19.55 feet below TOC.

Water Level Only

OHM-A7-51 189.22 22.6 7.6 - 22.6 181.62 166.62 15

Northern boundary along Track

Road, west end.

Water Level Only

OHM-A7-52 188.11 21.7 6.7 - 21.7 181.41 166.41 15

Northern boundary along Track

Road, west end.

Water Level Only

JO-A07-M61 180.9 6.0

1 - 6

(measured depth

5.1 ft)

179.9 174.9 5

Between fence line and Assabet

River, north of OHM-A7-52. Water Level Only

SUD-A07-014 226.37 22.01 12.0 - 22.0 214.37 204.37 10

Background for AOC 47;

replacement for OHM-A7-13. Well is inside the A7 enclosure, at the southern side of the site.

Biennial (2018), VOCs, Pesticides, COD, CN

Table 2-2

AOC A7 Groundwater Monitoring Locations

Former Sudbury Training Annex, Sudbury, Massachusetts

Monitoring

Wells

Top of PVC

Riser Elevation

(ft NGVD)

Total Depth

(ft below

TOC)

Screened

Interval Depth

(ft below

TOC)

Top of Well

Screen Elevation

(ft NGVD)

Bottom of Well

Screen Elevation

(ft NGVD)

Screen

Length

(feet)

Location Description and Well

Depth Notes

Monitoring

Program

SUD-A07-065 178.62 10 4.5 - 9.5 174.12 169.12 5

Replacement for JO-A07-M63; 15.1 feet south of M63; between fence line and Assabet River, between JO-

A07-M61 and JO-A07-M62.

Biennial (2018), VOCs, Pesticides, COD, CN

SUDWP-A07-01

(well point) 1 NA 6.93 3.93 to 6.93 NA NA 3

Approximately 10 feet northwest of

JO-A07-M62; trees have been marked with paint for easy location.

Annual, VOCs, Pesticides, COD, CN

Notes:

Depths and screened intervals are in feet below the tops of the PVC risers based on the November 2006 survey. COD = chemical oxygen demand

Vertical elevation datum is National Geodetic Vertical Datum (NGVD) 1929. CN = cyanide ft = feet Pest = pesticides

TOC = top of casing VOC = volatile organic compound

NA = not available

1 - This well point replaced damaged well JO-A07-M62. It is a steel 1-inch diameter well point installed in fall 2013.

This well point has not been surveyed and elevations are not available.

Table 2-3

AOC A7 Groundwater Elevations, January 2018

Former Sudbury Training Annex, Sudbury, Massachusetts

Well Date

DTW

(ft below TOC)

TOC

Elevation (ft

NGVD)

GW Elevation

(ft NGVD) Notes

SUD-A07-014 01/15/2018 13.18 226.37 213.19

OHM-A7-46 01/15/2018 15.62 217.87 202.25

OHM-A7-08 01/15/2018 25.38 219.84 194.46

OHM-A7-45 01/15/2018 13.44 210.01 196.57

OHM-A7-52 01/15/2018 3.79 188.11 184.32

OHM-A7-51 01/15/2018 6.35 189.22 182.87

OHM-A7-09 01/15/2018 6.77 186.21 179.44

OHM-A7-11 01/15/2018 1.14 181.73 180.59 not used in contour map

OHM-A7-10 01/15/2018 2.18 181.2 179.02

OHM-A7-12 01/15/2018 8.27 187.09 178.82

JO-A07-M61 01/15/2018 1.02 180.9 179.88

SUD-A07-065 01/15/2018 1.27 178.62 177.35

SUDWP-A07-01

1 01/15/2018 4.05 NA NA

Notes:

DTW = depth to water ft = feet

TOC = top of casing

GW = groundwater

NGVD = National Geodetic Vertical Datum 1929

1 - This well point replaced damaged well JO-A07-M62. It is a steel 1-inch diameter well point installed in fall 2013.

This well point has not been surveyed and elevations are not available.

Table 3-1

AOC A7 Groundwater Analytical Results

Former Sudbury Training Annex, Sudbury, Massachusetts

Method/Analyte Historical

Maximum

MCP GW‐1

Groundwater

Standard

MCP GW‐3

Groundwater

Standard

Units SUDWP‐A07‐01 Q

SUD‐DUP01

(SUDWP-A07-01)

Q

TRIP

BLANK

Q

12/4/2017 12/4/2017

Volatile Organic Compounds (SW8260B) cis ‐1,2‐Dichloroethene 19 70 50,000 µg/L 1.0 U 1.0 U 1.0 U trans ‐1,2‐Dichloroethene 6.0 100 50,000 µg/L 1.0 U 1.0 U 1.0 U

1,1,2,2‐Tetrachloroethane 31 2.0 50,000 µg/L 1.0 U 1.0 U 1.0 U

Tetrachloroethene 140 5.0 30,000 µg/L 1.0 U 1.0 U 1.0 U

Trichloroethene 40 5.0 5,000 µg/L 1.0 U 1.0 U 1.0 U

Pesticides (SW8081B) 4,4'‐DDD 0.48 0.20 50 µg/L 0.012 U 0.010 U NA 4,4'‐DDE 0.10 0.05 400 µg/L 0.012 U 0.010 U NA

4,4'‐DDT 0.36 0.30 1.0 µg/L 0.021 U 0.018 U NA

Aldrin 0.058 0.50 30 µg/L 0.021 U 0.018 U NA alpha‐BHC 0.042 NS NS µg/L 0.012 U 0.010 U NA beta‐BHC 0.058 NS NS µg/L 0.021 U 0.018 U NA Chlordane (technical) -- 2.0 2.0 µg/L 0.36 U 0.30 U NA delta‐BHC 0.31 NS NS µg/L 0.021 U 0.018 U NA

Dieldrin 0.12 0.10 0.5 µg/L 0.012 U 0.010 U NA

Endosulfan I 0.058 10 2.0 µg/L 0.012 U 0.010 U NA

Endosulfan II 0.12 NS NS µg/L 0.012 U 0.010 U NA

Endosulfan sulfate 0.12 NS NS µg/L 0.012 U 0.010 U NA

Endrin 0.12 2.0 5.0 µg/L 0.012 U 0.010 U NA

Endrin aldehyde 0.12 NS NS µg/L 0.012 U 0.010 U NA

Endrin ketone 0.05 NS NS µg/L 0.012 U 0.010 U NA gamma‐BHC (Lindane) 17.0 0.20 4.0 µg/L 0.012 U 0.010 U NA

Heptachlor 0.058 0.40 1.0 µg/L 0.021 U 0.018 U NA

Heptachlor epoxide 0.058 0.20 2.0 µg/L 0.012 U 0.010 U NA

Methoxychlor 0.058 40 10 µg/L 0.021 U 0.018 U NA

Toxaphene 1.2 NS NS µg/L 0.95 U 0.80 U NA

Cyanide (SW9012B) Cyanide, Total 11 200 30 µg/L 5.0 U 5.0 U NA

Chemical Oxygen Demand (E410.4) COD 190 NS NS mg/L 10 U 10 U NA

Field Parameters Temperature ° C pH SU

Specific Conductance mS/cm

ORP mV

Dissolved Oxygen mg/L

Turbidity NTU

Notes:

NA = Not analyzed Temp/°C = Temperature/degrees Celsius NS = No standard pH/SU = standard units µg/L = microgram per liter mS/cm = millisiemens per centimeter mg/L = milligram per liter ORP/mV = Oxidation Reduction Potential/millivolt U = Non-detect (ND) NTU = Nephelometric Turbidity Unit ND results are reported at the Limit of Detection (LOD)

NANS NA3.80

NA

NS NA4.17 NA

NS NA+115

NA

NA

NS NA71 NA

NS NA6.17

NS NA10.57

Table 3-2

Summary of Historical Groundwater Target Compounds at AOC A7, 1996 - 2017

Former Sudbury Training Annex Sudbury, Massachusetts

Well Number

MCP GW‐1

Groundwater

Standard

(µg/L)

MCP GW‐3

Groundwater

Standard

(µg/L)

Jul-96 Oct-96 Apr-97 Oct-97 Apr-98 Oct-98 Apr-99 Oct-99 Apr-00 Oct-00 May-01 Oct-01 Apr-02 Oct-02 Apr-03 Oct-03 Apr-04 Oct-04

1,1,2,2-Tetrachloroethane

OHM-A7-51 2.0 50,000 66 85 34 29 11 9 6.5 19 7.7 4.9 (1) 6.0 (1) 6.1 4.8 2.4 2.7 4.4

JO-A07-M63/SUD-A07-065

1 2.0 50,000 13 21 24 26 20 31 23 22 12 20 12 14 20 13 5.1 3.8 4.8 (1.8)

Tetrachloroethene

OHM-A7-08 5.0 30,000 12 27 120 120 92 130 94 92 43 71 40 59 14 33 24 23J 21 13

OHM-A7-51 5.0 30,000 82 65 26 20 7.3 8.4 7.9 13 8.3 6.8 (2.1) 6.5 6.3 7.8 6.4 5.8J (4.6J) (4)

JO-A07-M63/SUD-A07-065

1 5.0 30,000 14 14 28 21 28 32 30 24 17 25 40 16 23 14 (1.9) (3.0) (2.9) (0.62)

Trichloroethene

JO-A07-M63/SUD-A07-065

1 5.0 5,000 10 15 24 25 (1) 36 36 30 21 37 17 29 40 33 5.9 11 17 9.3 gamma-BHC (Lindane)

OHM-A7-08 0.20 4.0 0.538 2.8 17 (0.052) 16 13 12 6.7 9.6 5.1J 7 4.3 1.4 2.6 2.6 2.0 1.4 0.82J

SUD-A07-065 0.20 4.0 NS NS NS 0.31 ND 0.38 0.32 0.33 (0.07) ND 0.25 0.31 0.25 0.24 (0.12) (0.041J) ND (0.10)

JO-A07-M62/SUDWP-AO7-01

2 0.20 4.0 NS ND ND ND ND ND ND ND ND 0.84 ND ND ND ND ND ND ND ND

4,4'-DDD

OHM-A7-08 0.20 50 NS NS NS 0.35 5.0 5.6 0.3 5.0 0.28 2.0 (0.10) 0.25 (0.13) 2.0 0.21 0.40 0.29 (0.11)

Arsenic

OHM-A7-08 10 900 NS NS ND ND ND ND ND ND (7.9) 13 10 15 (8.7) 24 (1.8) 21 14 15.8

JO-A07-M63/SUD-A07-065

1 10 900 ND ND ND ND ND ND ND ND ND ND ND ND (5.9) (6.2) (1.5 J) (1.1 J) (0.99) (4.1)

JO-A07-M62/SUDWP-AO7-01

2 10 900 NS NS ND ND ND ND ND ND ND ND ND ND ND (1.2 J) ND (0.88 J) ND ND

Lead

OHM-A7-08 15 10 NS NS 485 290 17 (10) (11.7) (10) (11) (5.8) (10) (4.4) (5.2) (7.9) (0.9) (14) (9.5) (9.3)

JO-A07-M63/SUD-A07-065

1 15 10 ND ND ND ND ND ND ND ND (1.9 J) ND ND ND ND (2) (1.4) (0.46 J) (2.7) (3.4)

JO-A07-M62/SUDWP-AO7-01

15 10 NS NS 27.4 ND (3.1) ND ND ND ND ND ND ND ND (3) (0.15 J) (0.082 J) (0.14) ND

Notes:

Bold values exceed the MCP GW-1 standard.

µg/L - micrograms per liter

NS - Not sampled

ND - Not detected

Well SUD-A07-M65 was installed in 2006 to replace JO-A07-M63, which was decommisioned in 2013.

Well SUPWP-A07-01 was installed in 2013 as a replacement for damaged well JO-A07-M62.

The number in (parentheses) denotes that the concentration is below the MCP

GW-1 Standard.

Table 3-2

Summary of Historical Groundwater Target Compounds at AOC A7, 1996 - 2017

Former Sudbury Training Annex Sudbury, Massachusetts

Well Number

MCP GW‐1

Groundwater

Standard

(µg/L)

MCP GW‐3

Groundwater

Standard

(µg/L)

1,1,2,2-Tetrachloroethane

OHM-A7-51 2.0 50,000

JO-A07-M63/SUD-A07-065

1 2.0 50,000

Tetrachloroethene

OHM-A7-08 5.0 30,000

OHM-A7-51 5.0 30,000

JO-A07-M63/SUD-A07-065

1 5.0 30,000

Trichloroethene

JO-A07-M63/SUD-A07-065

1 5.0 5,000 gamma-BHC (Lindane)

OHM-A7-08 0.20 4.0

SUD-A07-065 0.20 4.0

JO-A07-M62/SUDWP-AO7-01

2 0.20 4.0

4,4'-DDD

OHM-A7-08 0.20 50

Arsenic

OHM-A7-08 10 900

JO-A07-M63/SUD-A07-065

1 10 900

JO-A07-M62/SUDWP-AO7-01

2 10 900

Lead

OHM-A7-08 15 10

JO-A07-M63/SUD-A07-065

1 15 10

JO-A07-M62/SUDWP-AO7-01

15 10

Notes:

Bold values exceed the MCP GW-1 standard.

µg/L - micrograms per liter

NS - Not sampled

ND - Not detected

Well SUD-A07-M65 was installed in 2006 to replace JO-A07-M63, which was decommisioned in 2013.

Well SUPWP-A07-01 was installed in 2013 as a replacement for damaged well JO-A07-M62.

The number in (parentheses) denotes that the concentration is below the MCP

GW-1 Standard.

Jun-05 Sep-05 Nov-06 Oct-07 Oct-08 Nov-09 Jun-11 Oct-11 Oct-12 Nov-13 Oct-14 Oct-15 Oct-16 Dec-17

2 (1.4) (1.9) 2.4 2 (0.94) (1.2) (0.58) (1.77) (1.22) ND NS NS NS

2 4.1 3.6 4.2 3.6 2.3 3.3 2.1 3.14 2.34 ND (1.80) (1.30) NS

8.7 25.4 16.4J 6.2J 8.1 11 5.6 6.2 8.18 7.46 ND (4.20) (2.70) NS

(3.1) (3.8) (3.8) (3.1J) (4.5) (2.6) (4) (2.9) (3.56) (4.33) ND NS NS NS

(1.5) 11.6 8.9 11.9 13 12 15 9.9 13.2 14.0 14.8 12.5 9.3 NS

(3.8) 25.4 7.1 9.3 (4.6) (4.4) (4.7) (1.3) 6.77 8.35 6.7 6.9 (3.9) NS

1.1 1.84 1.91 0.58 0.52J 0.522 0.332 0.45 0.529 0.366…