Responsiveness Data

Name/Organization of Comment Originator			Comment	Response
1	Ray Bowman	Mashpee Environmental Coalition	The collective opinion of the Coalition's Board is: "Alternatives C1 and F are the best of the options listed." The following comments are provided as an overview to the Board's discussion and are not necessarily consistent with established dogma.	Preference noted.
2	Ray Bowman	Mashpee Environmental Coalition	1) MCLs are meaningless where a plume has multiple contaminants. No accurate human health risk can be computed and treatment to "below Detectable Levels" is desired.	Risk assessments are appropriate for determining human health and ecological risk associated with multiple contaminants. The goal of treatment to the plume is to treat to background and below detetion levels prior to reinjection.
3	Ray Bowman	Mashpee Environmental Coalition	2) Recirculating well technology does not appear to provide as high a removal efficiency as ETR. If EDB or phosphorus becomes a consideration RWT appears to be unacceptable.	In general this is correct. Recirculating well technology would require technical modification such as above ground liquid phase treatment to remove EDB or phosphorus.
4	Ray Bowman	Mashpee Environmental Coalition	3) Alternative A requires extraction wells in an area too close to the pond and residences plus a high silt capture and therefore has low desirability.	Assessment is correct. It is an alternative to maximize capture but with potential construction, hydrological and ecological impacts.
5	Ray Bowman	Mashpee Environmental Coalition	4) Alternative B leaves a large area unremediated.	Alternative B leaves less than 2% of the mass of the plume unremediated.
6	Ray Bowman	Mashpee Environmental Coalition	5) Alternative C has a low system capture when compared to C1 and F.	Correct.
7	Ray Bowman	Mashpee Environmental Coalition	6) Alternative D uses RWT and is unacceptable, (see 2).	Preference noted.
8	Ray Bowman	Mashpee Environmental Coalition	7) Alternatives E & G are unacceptable and require no comment.	Preference noted.
9	Judith G. Stetson	General Public	My knowledge of CS-10 and its possible clean up alternatives is very limited, but I strongly oppose natural attenuation without monitoring, the last "treatment technology" described in your Public Notice ad. This is the option we have been living (and dying) with for 50 years and it is NOT ACCEPTABLE! Natural attenuation with monitoring is only marginally better. What is known about the biochemical effects of partially attenuated chemicals on the plant and animal life of soils, sediments, marshes, estuaries and harbors over time? As I understand it, recirculating wells are still being tested. Unless this treatment technology proves to restore a greater quantity of groundwater to a greater degree of purity than the ETR technology, I would favor "pump and treat". Mr. Karson said that the used charcoal from ETR goes off-Cape for cleaning. Is this process environmentally sound? Please make sure that any solutions to our local problems do not degrade anyone else's environment.	Thank you for your opinion, it has been noted. The chemicals of CS-10 are not in any of those surface habitats and are not expected to be. It appears that recirculation wells do not provide the same level of quantity or purity but may still have application in areas where pump and treat technology is not feasible. The process of carbon regeneration is environmentaly sound. The process is managed by specialized firms and is regulated.
10	Paul Zanis	General Public	My comments are as follows; no reinjection should take place. Pump to Vineyard Sound or manmade ponds.	Reinjection is the recommended hydrologic approach which minimizes disruption to regional water flow. Pumping to Vineyard Sound is precluded by regulation and scientific practicality. Pumping to man made ponds would generate unacceptable disturbances to surface water conditions and the regional groundwater flow.
11	Jane Coojan	General Public	1) With the alternative plans presented what are the specific details of affect for residential neighborhoods?	Alternatives A, C, C1, D, and F would have construction-related impacts on the Horseshoe Bend neighborhood. This would involve drilling of extraction or recirculating wells and performance monitoring wells near Horseshoe Bend Way. If Alternative A is selected, then approximately 10 extraction wells would be installed. In addition, piping installation, similar to water line construction, connecting the wells with a treatment plant on base would be necessary. A four to six foot diameter manhole cover would be visible following restoration activities at each extraction location. Recirculating wells would not require piping to a central plant but would have similar vaults for the wells and an equipment/treatment unit which may be located above ground in a shed or below ground in an additional vault at each location.
12	Jane Coojan	General Public	2) What test results, to date, have you regarding the two pilot recirculating wells? And, how do these results compare to effective use in Europe?	The AFCEE recently completed pilot tests of two recirculating well technologies in the CS-10 plume and in the Ashumet Valley plume. The results of the pilot tests are contained in a draft report currently under review by the EPA and DEP. The pilot test results indicate that the systems are effective in removing contaminant mass for the aquifer conditions present within the CS-10 plume; however, the development of the recirculation cell appears to be fairly sensitive to geologic variability. Consequently, detailed designs of remedial systems involving these technologies will likely require additional detailed geologic data in the areas in which they are sited. In addition, they may require additional monitoring during initial operations, relative to more common extraction, treatment, and reinjection (ETR) approaches, to demonstrate compliance with performance goals. Currently, the recirculating well systems are limited to treatment of contaminants that may be "air stripped" from groundwater ETR approaches involve removal of groundwater from the aquifer, pumping to a treatment plant, fluid-phase treatment, and distribution to reinjection wells. Fluid-phase removal may enable greater treatment flexibility if contaminants that are not readily strippable are encountered.
13	Jane Coojan	General Public	3) Is the CS-10 plume migration as currently documented headed in the direction(s) of any operating or targeted public well sites? And do you have maps of the location of residential well sites in the area of or direction of the known plumes migration guestimates?	Current data indicate that the primary amount of the mass associated with the CS-10 plume is north of Ashumet Pond. Our investigations between Ashumet and Johns Ponds and to the south, currently underway, have detected what may be the leading edge of the CS-10 Plume. Monitoring well clusters, having ND (non-detect) results, indicate that the plume is deep within the aquifer and does not extend south of Southport Village or Rte 151. Private wells are known to exist in the area south and east of Johns Pond. If a potential threat to them is identified, measures will be taken to provide a municipal water connection. At this time, no existing Mashpee public supply wells are impacted. Proposed well sites may have a zone of contribution that passes through known plume areas in the upper reaches of the Massachusetts Military Reservation. These will be evaluated as part of the overall remediation alternatives.
14	Jane Coojan	Gereral Public	4) Should we, the public, presume that the highest plume capture, alternative Plan A, is or is not the highest priority of AFCEE?	No. Alternative A has notable implementation issues. AFCEE is looking for the most balanced approach, which is technically and economically feasible.
15	Jane Coojan	Gereral Public	5) Would you rank, via AFCEE priorities, plume capture, vs. potential effects on ecological habitats and versus socioeconomic impacts for me?	Plume capture is the overlying goal of the CS-10 approaches. However, they can not present unacceptable or unmanageable ecological or socio-economic impacts. The approaches must also be technically and economically feasible.
16	Jane Coojan	General Public	6) If adequate financial recompense is awarded to property owners in areas deemed to be adversely impacted by plume cleanup operations should there be a delay in installation of or start up of systems?	No delays are expected at this time. Delays, however, could occur for several reasons. For example, weather conditions could delay the construction schedule. Labor strikes or acts of God could occur. In spite of an offer of fair compensation allowable under federal law, some property owners may still choose not to participate in the cleanup, which may cause delays.
17	William O. Burwell, A.I.A.	General Public	I am interested in finding out at this particular time, if there is a symbiotic solution for the problem of access, the potential for using the infrastructure of your remediation system (or any part of it) as a future asset to the community, and the possible PR value of offering something to those most affected - in exchange for the anxiety and inconvenience they may have felt.	While your thoughts on the potential beneficial use of the infrastructure of the treatment systems being considered for MMR are extremely interesting, an in-depth consideration of these benefits is beyond the scope of this process at this time. Thank you for the background information on equipment and possible manufacturers.
18	Eugene Courier	Neighborhood	I am voting for Alternative B. I am concerned with impact to Ashumet Pond and neighborhood integrity.	Your preference has been noted.
19	Anonymous	General Public	This letter is in response to the request for public comments regarding the cleanup of the CS-10 plume. As a general comment, I have attended some of the public meetings and have heard statements from the JPAT, EPA, DEP, and others concerning a "change in focus" for the cleanup, and that the cleanup is now more important than ever thought before. However, this seems to be the choice of a small, yet vocal, minority. I agree that the focus has changed, but there are no risks with the plume if it is left to run its course (if my interpretation of the Plume Criteria information is correct). Additionally, there are other plumes out there that are not going to be cleaned up (abandoned dry cleaners, old gas stations, town landfills). Therefore, if the focus has changed, then perhaps now is the time to perform a risk evaluation, instead of rushing in with an expensive cleanup operation that will ultimately benefit no one, except the giant government bureaucracy that is trying to protect itself, at the cost of hundreds of millions of taxpayer's dollars. Following are my questions: 1) Why will a cleanup be performed when the CS-10 plume presents no risks?	Monitored Natural Attenuation and No Action are the alternatives under consideration that address lower risk. The risks presented assume no residential use of plume water, however, using MCLs there will continue to be degradation of previously uncontaminated aquifer.
20	Anonymous	General Public	2) Why will Otis plumes be cleaned up when other plumes in the western Cape Cod area will not be cleaned up?	The MMR site has been designated as a Federal Superfund site and is therefore subject to the standards established under the Federal CERCLA law. The other non-CERCLA sites in Massachusetts are being addressed for remediation in accordance with State law known as the Massachusetts Contingency Plan (MCP), 310 CMR 40.000. The MCP requires a potentially responsible party to make clean-up decisions to a level of "no significant risk". This risk determination addresses risk to human health, welfare, and the environment. The same MCP rules apply when the State agrees to clean-up a site with public money. Similar cleanup requirements exist in MCP and CERCLA. Other plumes on western Cape Cod are in different stages of the cleanup process.
21	Anonymous	General Public	3) What is the benefit (to the water supply and ecosystem) of cleaning up the Otis plumes when other plumes will not be cleaned up?	A benefit, in some cases, is protection of uncontaminated aquifer.
22	Anonymous	General Public	4) My understanding is that not all of the CS-10 plume will be cleaned up (a portion of it goes into "silt" or "escapes"). What is the benefit (to the water supply and the ecosystem) of cleaning up only a portion of the CS-10 plume while leaving some of it in the underground aquifer?	A portion of the contaminant mass contained in the plume reaches and is impeded by silt. The average groundwater velocity typical of the sandy deposits of the Mashpee Pitted Plain deposits within CS-10 are 1 foot a day while that of the silts generally are less than 0.1 foot a day. Consequently, it is not economically or technically feasible to remove contaminant mass from the silts through the use of a pump and treat approach. Removal efficiency of wells within the silts is very low. However, in addition to slowing contaminant movement, the silts often present anaerobic conditions which are ideal for bacteria that biodegrade chlorinated compounds.
23	Anonymous	General Public	5) My understanding is that there is an "Augat" plume south of Otis that contains the same types of contaminants as the CS-10 plume. Why are the EPA and MassDEP allowing the "Augat" plume to naturally disperse, but requiring the cleanup of CS-10? This seems to be an arbitrary application of the rules.	Remedy consistency is a very important aspect of the clean up process. The contamination that has been detected from the Augat facility is being studied under the States 21E program, EPA does not have any involvement on the investigations being performed or the proposed remedial actions to be conducted. The Augat site is located on Route 28 in Mashpee and is under investigation by the potentially responsible party (PRP). The plume extends approximately 7,500 feet from the Augat site to Shoestring Bay and contains primarily TCE and PCE up to 800 ppb. The PRP has completed Phase II Investigations under the MCP which the MassDEP is currently reviewing. The MassDEP has asked the PRP to do additional work to determine where the plume is entering Shoestring Bay, at what concentrations, and to perform a detailed human and ecological risk assessment for the site. The company is submitting a Scope of Work by the end of August, 1997 for the additional work. The Mashpee Public Library is serving as a public repository for all reports relative to the Augat site investigations. A decision has not been made to allow the plume to naturally dispurse.
24	Anonymous	General Public	6) There are also other plumes in the area that may or may not contain the exact same chemicals as the CS-10 plume. Some of them (that I am aware of) are old town landfills, the Jay Braden Thompson plume, and old gas stations. Even though the chemicals may not be the same, the government has led us to believe that the chemicals are harmful to humans and the ecosystem. So, if this is true, then why clean up only CS-10? If the other chemicals are harmful, what is the benefit of only cleaning up CS-10 and not the Thompson plume, for example?	Other plumes on the Cape are being cleaned up. The MMR work is at a different stage than other Cape plumes.
25	Anonymous	General Public	7) Before the Otis problems were "discovered" , we were led to believe that septic tanks and cesspools (almost every home and business has one) are the biggest threat to our water supply on the Cape. What is the benefit (to the water supply and ecosystem) of cleaning up CS-10 when there are septic tanks and cesspools still discharging to the underground aquifer?	The contaminants of concern from CS-10 are probable carcinogens not usually associated with domestic sewage. Malfunctioning septic systems and cesspools are still a threat to the Cape's water resources especially for the reason mentioned; almost every home and business in the area has one. The MassDEP strictly regulates discharges from wastewater treatment plants and recently revised 310 CMR 15.000, known as the Title V Regulations, to improve the minimum design standards required to treat residential wastewater on-site. In addition, Title V targets nitrogen-sensitive areas for added protection around public water supplies.
26	Anonymous	General Public	8) What are the impacts to ponds and the ocean (shellfishing beds, for example) from the CS-10 plume versus septic tanks and cesspools?	The impacts are expected to be non-existent (i.e. non-detectable levels of CS-10 contaminants in ponds or ocean). Impacts from septic tanks and cesspools deplete oxygen and can resilt in fish kills. Increased algae growth deminishes aesthetic quality of ponds.
27	Anonymous	General Public	9) How often do you predict that fishing in the ponds or ocean (regular fishing and shellfishing) will be restricted due to the CS-10 plume (if it is not cleaned up) versus contamination from cesspools? How often do you predict that ocean fishing will be restricted due to "red tide" (or another natural occurrence) versus the CS-10 plume (if the plume is not cleaned up)?	Never expect fishing to be restricted due to the CS-10 plume. No prediction available on fishing restrictions from other causes.
28	Anonymous	General Public	10) If the millions of dollars are spent on the CS-10 plume cleanup, will we be able to drill a well south of Otis and drink the water (within the 50 to 100 years)?	If the containment is effective water supply wells can be placed south of Otis. A goal of the program is to return effected groundwater to potential use as drinking water. Since all of the groundwater in this area is designated as a sole source aquifer, it adds more importance to restoration as a goal. Pristine water is the first choice for drinking water for all communities in the Commonwealth. The MassDEP strictly regulates drinking water supplies to ensure that clean water remains available. For example, there are some situations where a water supply inadvertently becomes contaminated and treatment must be provided at a wellhead to protect the public. Alternative sources of clean water are sought before the treatment option is considered. The cleanup of CS-10 and other MMR plumes is intended to stop the spread of contamination and treat contaminants so that future generations will have clean water sources available to them. Wellhead treatment is allowable by both agencies. However, it is not a preferred approach.
29	Anonymous	General Public	11) Will a public water supply well be allowed to be drilled anywhere south of Otis if the CS-10 plume is cleaned up?	If cleaned yes. If held in place, probably not.
30	Anonymous	General Public	12) My guess is that no matter what type of cleanup is performed, a supply well drilled south of the base will require some form of treatment. Why won't EPA and MassDEP allow well head treatment, instead of plume cleanup (at the cost of millions of tax payer's dollars) AND well head treatment?	A goal of the program is to return effected groundwater to potential use as drinking water. Since all of the groundwater in this area is designated as a sole source aquifer, it adds more importance to restoration as a goal. Pristine water is the first choice for drinking water for all communities in the Commonwealth. The MassDEP strictly regulates drinking water supplies to ensure that clean water remains available. For example, there are some situations where a water supply inadvertently becomes contaminated and treatment must be provided at a wellhead to protect the public. Alternative sources of clean water are sought before the treatment option is considered. The cleanup of CS-10 and other MMR plumes is intended to stop the spread of contamination and treat contaminants so that future generations will have clean water sources available to them. Wellhead treatment is allowable by both agencies. However, it is not a preferred approach.
31	Anonymous	General Public	13) Why does the water supply for the Town of Barnstable use wellhead treatment, but wellhead treatment does not appear to be an alternative for the CS-10 plume?	The Town of Barnstable has four private water companies which draw water from many water supply wells. Only one water company in Barnstable is using wellhead treatment. Wellhead treatment is being used for the company's Maher wells. The Maher wellfield has a large user demand and, unfortunately, became contaminated with volatile organic compounds from several sources. These plumes came from several commercial sources in the Hyannis area. The MassDEP investigates these sites as part of it's Barnstable Aquifer Protection Project, (BAPP). The water company held a District meeting with its customers and determined that wellhead treatment would be an acceptable way to deal with the contaminated wells as no other alternatives were readily available. When a water supply becomes contaminated it is addressed on a case-by-case basis by the supplier. MassDEP strictly protects public water supplies by law to avoid contamination by harmful chemicals. Prevention is the key element of the laws and regulations. (See also answers to questions #30, #35 and #47 for DEP's position on wellhead treatment.)
32	Anonymous	General Public	14) Is the Town of Barnstable allowed to use wellhead treatment (and not cleanup the landfill plume) because it is a municipality and the rules for a municipality are different?	No, the rules are not different for a municipality, such as Barnstable, regarding the applicability of wellhead treatment. Please refer to the response to question #31 for more information on why Barnstable has wellhead treatment for one wellfield. Contamination, which seems to come from the landfill, has not impacted any public water supply wells. The potentially responsible party will have to assess and clean up the plume. In the meantime, DEP's Solid Waste Division has requested that additional wells be installed for monitoring purposes between the plume and Princess Cove and ahead of the wellfields to the south of the landfill. MassDEP regulations require that unlined landfills be closed in order to protect water supplies. Barnstable is now placing waste in a lined landfill.
33	Anonymous	General Public	15) Why won't the EPA and MassDEP clearly state to the public all of the available options for the plume? For instance, well head treatment with no cleanup would be cheaper and the benefits to the public would be the same. All we hear about is an expensive cleanup, but we don't hear about any of the less expensive options that would result with the same benefits.	The remedial alternatives that were evaluated examine various cleanup options. Well head treatment might be an option a town water district would pursue with otherwise limited options.
34	Anonymous	General Public	16) If well head treatment is used instead of cleaning up all of Otis, would fewer government jobs (directly related to the Otis Project) be available?	Yes. Treatment plants will require manning for decades as will wellhead treatment systems. However, treatment plants would typically require more personnel.
35	Anonymous	General Public	17) What is the benefit of a CS-10 cleanup when the water supply will contain some hazardous chemicals, no matter what is done, and the water supply will have treated anyway (no matter what is done)?	Pristine water is the first choice for drinking water for all communities in the Commonwealth. The MassDEP strictly regulates drinking water supplies to ensure that clean water remains available. There are some situations where, for example, a water supply inadvertently becomes contaminated and treatment must be provided at a wellhead in order to protect the public. Alternative sources of clean water are sought before the treatment option is considered. The cleanup of CS-10 and other MMR plumes is intended to stop the spread of contamination and treat contaminants so that future generations will have clean water sources available to them.
36	Anonymous	General Public	18) What is the benefit of spending millions of dollars on the CS-10 cleanup versus spending a fraction of that amount on developing an alternate water supply?	Alternative water supplies are developed in response to a threat to an existing system (private or public supply well) to ensure future capacity or mitigate a contaminated system resulting from a plume emanating from MMR. The decision to spend dollars on cleanup is based on the need to protect human health and the environment (ecological). Alternative water supply development does not eliminate the need for cleanup.
37	Anonymous	General Public	19) What is the difference in impacts to property values with the CS-10 system installed and running (choose any of the systems shown on the fact sheets) versus just letting the plume take its natural course? (Please note that I am not asking about the impacts due to one system or another, I am specifically asking about any system versus no system).	As plumes migrate, or portions there of, they will continue to underrun more property off-base. The only restriction to property owners may be on the use of groundwater, but this concern is resolved with connection to public water at Air Force expense. While the plume underrunning property may be a detraction, it presents no risk and public water is an improvement to property.
38	Anonymous	General Public	20) What is the benefit of spending millions of dollars on the CS-10 cleanup versus spending a fraction of that amount on another program, like education or a healthy-start program for school children?	We appreciate your concern for other public programs and agree they are important. However, there is a mandate under several federal and state laws to identify and address contaminants to protect public health, welfare, and the environment. This will provide greater security for future generations as well.
39	Ed Weber	General Public	I favor Alternative A because I feel it is technically the best way to capture the plume.	Preference noted.
40	Deborah McDonald	General Public	I prefer Alternative A because I feel it will do the most capturing the plume without disturbing the long-term aesthetics of the neighborhood.	Preference noted.
41	Richard Koehler	General Public	The pump buildings need to be soundproof. Reduce the machinery noise, especially whatever makes that high-pitched noise, e.g., a bad bearing.	Extraction and reinjection wells associated with pump and treat systems are virtually silent, having electric submersible pumps located deep within the wells. The blowers associated with the recirculating wells that were recently pilot tested within the CS-10 plume, however, are a source of noise. These systems will be designed to minimize noise through a variety of methods including use of quieter components, sound insulation, vibration dampening, destructive interference of sound waves, and locating equipment in below ground vaults.
42	Roy Woodward	General Public	I like Alternative A because it appears that is the best way to capture most of the pollution. I also would like my voice, as a resident of Horseshoe Bend Way, to count more than people who aren't affected by any of the plans.	Your preference for Alternative A is noted. The Air Force, EPA, and MassDEP consider the preferences of the affected neighborhood separately from other members of the public. This is demonstrated by the fact that there is a separate line item in the matrix for the affected neighborhood as an acceptance group. However, all opinions must be considered equally when making a final decision.
43	Dave Nowlan	General Public	Based on the information provided I'd like to submit my preference for option "F" as demonstrated last evening. This is the most aggressive option and has the best clean up potential.	Preference noted.
44	Billy "Buff" Buffman	General Public	Here are my questions for the CS-10 plume: 1) Why are you going to spend so many millions of dollars on the CS-10 plume cleanup when there is no risks if the plume is left the way it is?	A goal of the program is to return effected groundwater to potential use as drinking water. Risk is part of the criteria, and there are Monitored Natural Attenuation and No Action alternatives, which are proposed minimal actions.
45	Billy "Buff" Buffman	General Public	2) How many government jobs will there be if the plume is cleaned up as planned? How many government jobs will there be if well head treatment is used instead of the cleanup wells and cleanup plant?	No firm estimates are available but assume that treatment plants will require more planning than wellhead treatments.
46	Billy "Buff" Buffman	General Public	3) Why isn't the JBThompson plume being cleaned up? Is it because the state is responsible and the rules are different: Aren't the pollutants the same as in CS-10?	The State has fully committed to cleaning up the J. Braden Thompson Road site (JBT) even though the MassDEP is not the responsible party. The "rules" followed by MassDEP include assessing and cleaning up the site in accordance with the Massachusetts Contingency Plan (MCP) and all work is done within the State contracting guidelines. Some of the contaminants in the JBT plume are the same as the CS-10 plume at MMR. MassDEP is completing additional investigations needed to design the final treatment system which is expected to be developed fall 1997 and put out for bid.
47	Billy "Buff" Buffman	General Public	4) If more water is needed for this area why can't this area use well head treatment like other towns in Massachusetts? Are the rules different for this part of the state?	Pristine water is the first choice for drinking water for all communities in the Commonwealth. The MassDEP strictly regulates drinking water supplies to ensure that clean water remains available. There are some situations where, for example, a water supply inadvertently becomes contaminated and treatment must be provided at a wellhead in order to protect public health. Alternative sources of clean water are sought before the treatment option is considered. The cleanup of CS-10 and other MMR plumes is intended to stop the spread of contamination and treat contaminants so that future generations will have clean water sources available to them.
48	Billy "Buff" Buffman	General Public	5) Are people drinking contaminated water now? Will they be drinking contaminated water in the future? If the CS-10 plume is not cleaned up, but well head treatment is used, would people be drinking contaminated water?	A. No MCL exceedances known in any private of public wells. B. Potentially C. No
49	Billy "Buff" Buffman	General Public	6) You used to be able to buy TCE in the hardware store to clean out your cesspool. Have you looked at the impacts due to the home use of TCE?	The chlorinated solvent Trichloroethylene (TCE) has been in use for many years in a variety of products. It has been used for degreasing and dry cleaning and is contained in printing inks, paints, lacquers, varnishes, and adhesives (U.S. EPA data). TCE detected in the CS-10 plume is likely to be primarily associated with activities at MMR due to the location, depth and extent of the plume.
50	Billy "Buff" Buffman	General Public	8) Why are we spending huge amounts of taxpayers dollars to clean up the aquifer when there are no risks (other than the risk of fewer government jobs if its not done)?	A goal of the program is to return effected groundwater to potential use as drinking water. Risk is part of the criteria, and there are Monitored Natural Attenuation and No Action alternatives, which are proposed minimal actions.
51	Billy "Buff" Buffman	General Public	9) What good does it do to clean up one plume (CS-10 for instance) when there are other plumes that won't be cleaned up (municipal landfills, for instance)? Aren't the chemical s the same? Are the rules different depending on who is responsible for the pollution?	The chemicals in many of these sites are similar types of contaminants. There is a benefit to cleanup the CS-10 plume, since the levels that have been identified are well in excess of drinking water standards, and could have an effect on existing and proposed drinking water supplies. Many other sites on the Cape are being addressed and evaluated under the State 21E program, which seeks groundwater cleanup remedies from the responsible parties. In the case of landfill closures, the State works with the individual towns to determine the most feasible cleanup option and schedule.
52	Billy "Buff" Buffman	General Public	10) Do people realize that the taxpayers on the Cape will have to foot the bill for this cleanup? How much will our taxes go up from the cleanup you recommend? How much less would our taxes go up if well head treatment was used?	Cleanup is federally funded, as part of the Department of Defense budget and the impacts to your federal tax burden will be non-detectable. It is our federal tax dollars nonetheless.
53	Bob Fitzpatrick Robert and Winifred Fitzpatrick	General Public	We wish to vote for Alternative F. As a Falmouth residents, we feel that the extraction method/configuration that will remove the most contamination from the ground water is the plan of choice. Our second choice is alternative C1.	Preference noted.
54	William Kurker	Neighborhood	In my opinion, Alt. G is the best solution. Leave it alone and let nature clear it out. It's too much tax dollars to spend for years not knowing if it will even solve the problem the only other alternative I would appr. would be Alt. A. I do not want any noisy pumps or any buildings in or around my property.	Preference and concern noted.
55	Frank Belanger	General Public	C1 and F are acceptable because they are high in both system and total capture.	Preference noted.
56	Richard G. "Gus" Johannsen	General Public	1) General. I have been a resident of Cape Cod for three years and have closely followed the events taking place at MMR during that time. I have attended several public JPAT meetings and regularly review the available materials when I am at the Falmouth Library. I also have a technical background in biology and chemistry which allows me to understand the issues fairly well. Given this, I must say that I am appalled at the way the MMR site is being handled by the various government agencies responsible for running things. I know that most of the public citizens who speak at the meetings clamor for more action, more aggressive cleanup, more investigation, etc. I however, believe most of these people are uninformed and are motivated primarily by emotion. In my option, far too much action is being proposed and considered at MMR. The reason for this is obvious to me: the Air Force, EPA, DEP, and other responsible agencies are bowing to public and political pressure for drastic cleanup measures, when such measures are absolutely not justified, either technically or legally. To justify the kind of cleanup being considered at MMR, there must be an imminent risk to public health and/or the environment. In my opinion, the risks at MMR are minimal. Risks associated with drinking tap water are much greater than those associated with the MMR plumes, I am certain. The problem is one of public perception. The public perceives there to be a major problem at MMR, and there has been no effort to convince them otherwise. Sensational articles in the local papers containing numerous exaggerations and half-truths, and politicians currying public favor (and votes) by railing against inaction and overspending at the base don't help matters either. The perception is that there is a major public threat at MMR, and the evil government is trying to hide it and get away without doing anything. I believe this is far from the truth. The Air Force seems to be doing everything it can to move the process along, but is hindered by the aforementioned public perception and a ponderous review and approval system. To actually do something that makes technical sense at MMR seems a difficult goal, given the structure of things. My suggestion is this: we need to delay the schedule (for CS-10) and all the other plumes) for a short time while the overall approach at MMR is reconsidered. It seems a foregone conclusion that extensive, drastic measures will be implemented at all the plumes at MMR. Why? Because it's MMR. Because it's Cape Cod. Because an uninformed, emotional public applies a huge amount of pressure to do as much as possible regardless of the need. The normal rules don't seem to apply to MMR. If the kind of extensive cleanup system being considered is actually installed at CS-10, I believe it will be a case of waste, fraud, and abuse of monumental proportion. The EPA, DEP, and the Air Force will have done the American taxpayer a deplorable disservice. The facts call for limited action: cleanup of hot spots, monitoring, fate and transport modeling, and continuing he policy of keeping the public informed and putting everyone who needs it on public water.	Under CERCLA and the 1990 National Contingency Plan (NCP), EPA is directed to meet certain expectations in addressing ground water contamination. Under the NCP, EPA is expected to return usable ground waters to their beneficial uses wherever practicable within a time frame that is reasonable, given the circumstances of the site. When restoration of the ground water to beneficial uses is not practicable, EPA expects to prevent further migration of the plume, prevent exposure to contaminated ground water, and evaluate further risk reduction. The preamble to the NCP states that for Class I waters, which are ground waters of high value that are irreplaceable sources of drinking water and/or ecologically vital, preliminary remediation goals should generally be set at Maximum Contaminant Levels and non-zero Maximum Contaminant Level Goals. EPA's preference is for rapid restoration, when practicable, of Class I ground waters and contaminated ground waters that are currently, or likely in the near-term to be, the source of a drinking water supply. An imminent risk requires that an immediate action be taken. The remedial program is meant to address long-term risks. The main issue is that groundwater contamination is greater than the drinking water standards, and the program goal is to determine use and value of the groundwater and to cleanup to their designated use. Since this water is designated as a sole source aquifer, the goal is stringent unless it can be proven technically impracticable. In addition, the current existing land use is residential, which supports cleanup to residential standards. It is important to ensure that this area has safe, potable drinking water supplies. If the plumes remain unchecked over time, more people will require connection to the public water supply, and there are limited options for finding new available sources in many of the surrounding towns.
57	Richard G. "Gus" Johannsen	General Public	2) My main comment after reading the Decision Criteria Matrix and supporting text is that there appears to be no risk even if no action is taken at CS-10. The risk calculations show that there is no unacceptable risk to people or the environment for the Natural Attenuation and No Action alternatives. I fail to see the use in spending $100 million of taxpayers money over 20 years of there are no benefits - no reduction in human health or ecological risk. Besides the enormous monetary cost, significant damage to the environment is likely if construction of these alternative is undertaken. Please provide a logical , defensible explanation for why such drastic action is being contemplated for what appears to be a relatively minor problem.	The contamination at MMR is not a relatively minor problem and the "no action and Monitored Monitored Natural Attenuation" alternatives do indeed fail with respect to risk considering the matrix evaluation criteria designated under IA1 and IIIB4. These alternatives propose to allow groundwater contaminated above drinking water standards to advance downgradient of MMR into residential neighborhoods gradually depleting the remaining resources of potable water available. The USGS has compiled a model of contaminant plume expansion from the base that illustrates the loss of more of the Upper Cape aquifer in the next few decades. This Superfund site is located geographically at the top the Sagamore Lens at the groundwater divide. The plumes at MMR are defined as those areas above the Maximum Contaminant Levels (MCLs) or other risk based standards. Therefore these plumes, should be catured and treated. Without treatment future water supplies would be jepordized because the contamination would spread out affecting more, private and public water supplies and natural resources for an even greater period of time.
58	Richard G. "Gus" Johannsen	General Public	3) As stated in my second comment, doing nothing at CS-10 results in no unacceptable impacts to human health or the environment. There is, however, a hot spot of contamination just north of Sandwich Road which contains high concentrations relative to the rest of the plume. It would seem reasonable to capture this hot spot before it moves into (or under) Ashumet Pond, even though there is apparently no risks associated with letting it go. Therefore, there should be an alternative the consists of capture of the hot spot, with natural degradation and long-term monitoring of the rest of the plume. This would probably only require 5 or 10 years of pumping to accomplish, and would be relatively inexpensive. This alternative would be a reasonable compromise and would fall halfway between the No Action/Natural Attenuation alternatives and the other alternatives consisting of more extensive measures - a middle ground not currently covered by any alternative. Impacts due to construction and operations of this new alternative would also be minimal. Please add this new alternative to the matrix.	The concept was evaluated at your recommendation and did point out the significance of the Sandwich Road fence.
59	Richard G. "Gus" Johannsen	General Public	4) The risk assessment performed for the IROD assumed that someone would install a water well within the plume and use it for drinking water and other residential purposes (IROD, pages 7-1). The Decision Criteria Matrix says that the drinking water pathway does not exist since everyone within the plume is automatically put on city water by the Air Force and no one drinking the water (Sections III.B.1 and III.D). Please explain this inconsistency.	Risk assessments provide a conservative evaluation of the potential impacts that an unmitigated plume of groundwater contamination may have on human health or the environment. The evaluation tends towards the worst case which here would be the installation of a private well within the plume. The IROD established the requirement of dealing with the drinking water pathway. The decision matrix resolved the exposure concern by requiring a public water supply connection to eliminate the pathway by means of an institutional control. The alternative water supply for potentially affected residences is part of the solution package for the CS-10 plume. Without that institutional control additional project activities would have been needed to address the human health risk. The matrix is consistent with the IROD.
60	Richard G. "Gus" Johannsen	General Public	5) If it is true (and it appears to be) that nobody is, or will be, drinking contaminated water at CS-10, then the risk assessment performed for the IROD is flawed and doesn't reflect reality. Therefore, since the containment action outlined in the IROD is based on a flawed risk assessment, should it not be revisited? There appears to be no legal or technical basis for the types of actions being contemplated at CS-10. Please discuss the legitimacy of the IROD in light of these issues.	Risk assessments provide a conservative evaluation of the potential impacts that an unmitigated plume of groundwater contamination may have on human health or the environment. The evaluation tends towards the worst case which here would be the installation of a private well within the plume. The IROD established the requirement of dealing with the drinking water pathway. The decision matrix resolved the exposure concern by requiring a public water supply connection to eliminate the pathway by means of an institutional control. The alternative water supply for potentially affected residences is part of the solution package for the CS-10 plume. Without that institutional control additional project activities would have been needed to address the human health risk. The matrix is consistent with the IROD.
61	Richard G. "Gus" Johannsen	General Public	6) Section II. The only ARAR not met by the No Action or Natural Attenuation alternatives is that they do not meet the containment provision specified in the IROD. All other ARARs, including federal and state groundwater quality standards, appear to be met. Is the IROD itself an ARAR? If the IROD itself is based on incorrect assumptions, shouldn't this be taken into account? Based on the facts, these alternatives should not fail this criterion and should be considered.	The Interim Record of Decision (IROD) is not an Applicable or Relevant and Appropriate Requirement (ARAR). ARARs are contained in the IROD.
62	Richard G. "Gus" Johannsen	General Public	7) Section III.C.3 says detailed fate and transport modeling would need to be performed before the persistence of the plume could be known. Why hasn't this been done? How else will it be known what would be the result if no active measures (or limited measures) are taken? The lack of fate and transport modeling adds to the perception that the Air Force is predisposed towards choosing an extensive, drastic action at the site, probably motivated by uniformed public and political pressure. Before anything else less than a full-blown cleanup system can be considered at CS-10, this modeling needs to be performed. Please provide a logical reason for why fate and transport modeling has not been performed for CS-10, and/or discuss when it will be performed.	The commenter is correct that detailed fate and transport modeling has not been done to develop the alternatives. The primary objective of the alternatives presented is to achieve the goal of 100 % capture of the plume. To meet this objective, a conservative modeling approach has been to assume that advective or physical transport is the critical parameter to characterize plume migration. This approach allows the AFCEE to evaluate how aggressive the pumping strategies will need to be, including expected location of well fences, in order to attempt to meet the 100% capture goal. The commenter is correct that the persistence of the plume, within the limits of the capture systems, is dependent upon environmental fate of the contaminants the kinetics of contaminant interaction with the aquifer media and how they are degraded by natural chemical, physical, and biological processes. Generally, the increased clean-up time expected from processes of chemical transport retardation is expected to be offset by processes of chemical, physical and biological degradation. However, it is our expectation that we will be conducting fate and transport modeling during detailed design work and prior to construction of the capture systems to develop refinements to the adopted strategy.
63	Richard G. "Gus" Johannsen	General Public	8) The threshold criterion that precludes choosing limited action at CS-10 is Section 1.A: "Exposure pathways eliminated, reduced, or controlled?" No Action and Natural Attenuation receive an open circle, thereby failing the criterion and putting them out of contention. It appears to me that this criterion inherently assumes that there is unacceptable risk to start with; this is why action is typically taken at a site - to eliminate or reduce risks to human health or the environment. Since there are no unacceptable risks at CS-10, either now or in the future, there is no need to eliminate, reduce, or control exposure pathways. Therefore these two alternatives should not fail this criterion.	Alternatives E and G fail the threshold criteria because they do not eliminate, reduce or control the groundwater exposure pathway. The IROD (pp 7-1) takes the conservative position that "contaminated groundwater would be used for drinking water and other residential uses." There is a risk from drinking contaminated groundwater (either existing or future use). A private well would therefore present an unacceptable potential risk as a completed pathway could occur. The provision of alternative water supply as an institutional control will eliminate that exposure pathway and thus could be considered in the final alternative selection process as a partial or total solution. The criterion is correct in its initial screening of the alternative. Later in the matrix, we use institutional controls to eliminate the exposure pathways and allow further consideration of the alternative.
64	Richard Hugus	General Public	My choice for the best treatment system for the CS-10 groundwater plume is for Alternative C-1, with the following additions: 1. of recirculating wells already in place in the southern hot spot being kept in operation, not shut down as is now being proposed 2. of recirculating wells being installed in the southern end of the northern high concentration area 3. that the presently undelineated toe of the CS-10 plume -- whether in, under, or beyond Ashumet Pond -- be addressed as part of the eventual full containment of the CS-10 plume. This is in line with the majority opinion of the Plume Containment Team as of its meeting July 30, 1997.	Preference noted.
65	Rick Robbins	Neighborhood	The alternative I think would be the best choice would be alternative A. I am saying this ONLY if the wells are installed down the middle of Horseshoe Bend Way. The piping could then be run down the way as well as placed under Sandwich Road to the filtration bldg to be located a short distance from the road on (sp?) gout. Property so as not to be seen or heard by those living along Sandwich Road. By placing the system along the middle of the road it would eliminate the problem of destroying wetlands as well as not needing access to private property. If I had a second choice it would be alternative B. This also eliminates accessing private property and according to the percentage plume capture chart, does a very good job of cleanup.	Preference noted.
66	CC Group of the Sierra Club Christopher Neill	General Public	The Cape Cod Group of the Sierra Club would like to thank the Air Force Center for Environmental Excellence for the chance to comment on plume capture alternatives for cleanup of the CS- 10 Plume. The Cape Cod Group of the Sierra Club has for many years been active in calling attention to the threats of groundwater pollution emanating from the Massachusetts Military Reservation in Bourne, Sandwich, Mashpee and Falmouth. We have also for many years pressed for action to clean up the plumes of toxic solvents that have contaminated more than 66 billion gallons of drinking water, forced the closing of 400 private wells and resulted in untold stress to residents of these four communities. Although it has been a long tune in coming, we are gratified to see concrete plans for specific plumes presented for comment We also commend the efforts that have been made to keep the public informed of the decision-making process. The Club believes that the maintenance of openness and full public participation in the plume cleanup plan will be essential for the ultimate success of the selected project configuration. We offer the following general comments that outline our position on what the general approach to selecting action alternatives for specific plumes should be. We focus on two areas: 1) minimizing disruption to communities that are affected by intensive cleanup activities, and 2) doing the best cleanup job with the minimum threats to natural resources. Minimizing Disruption to Communities The prospect of having a well or treatment plant on one's property or in one's neighborhood for a period of up to 30 years is a sobering one. Citizens will do their share, providing the AFCEE does its utmost to minimize disruptive impacts in eighborhoods. The following steps should be taken to lessen impacts to residential neighborhoods: - Plans that deploy extraction wells and place treatment facilities on already public road rights-of-way should be favored over placing those facilities on private home lots. Other already disturbed lands, such as utility corridors should be selected for facilities where at all possible, even if this reduces the total amount of the plume captured by a small degree. - No reinjection wells should be located where they would be upgradient from homes that currently rely on private drinking water wells, thus potentially resulting in the use of treated water. Best Cleanup with Minimum Damage The movement of millions of gallons of groundwater per day has the potential to disrupt natural hydrological patterns especially in sensitive areas such as wetlands. The AFCEE needs to strike a balance between minimizing cleanup and minimizing natural resource damage. We suggest several guidelines for achieving this goal: If a plume has hot spots of high contamination, treat hot spots first and with the heaviest rates of pumping. Use recirculating wells and not extraction, treatment and reinjection near sensitive areas like wetlands and vernal pools where large changes in water levels would be detrimental to natural habitats. The leading edge of the plumes should be treated where at all possible to prevent contamination of as much new area as possible. Monitoring needs to be included as part of each plume containment plan. Groundwater monitoring should impacts of the pumping activities on groundwater levels and on contaminant levels. This monitoring should include sampling from multiple tests from specified wells. This is crucial to judge how well the plan is working. Sensitive area monitoring should be conducted to determine water level drawdown and efficiency of contaminant removal. This should also be done at multiple times. Flexibility needs to be worked into these plans so they can adapt over time to improve their performance and can be modified should serious problems arise. The main construction impacts should occur on the Massachusetts Military Reservation. The areas of highest contamination (hot spots) north of Ashumet Pond should be captured via axial recirculating well technology. Recirculating well technology should be used adjacent to Ashumet Pond. These wells should be located on vacant lots. This will reduce socioeconomic impacts and impacts on wetlands. Extraction, treatment and reinjection with cross gradient technology should be employed elsewhere. This includes the southwest extraction fence, southern extraction fence, Sandwich Road extraction fence and extended northwest extraction fence. This is designed to minimize movement of contaminants into silts. Minimize groundwater drawdown by extraction fences and mounding by reinjection fences by placing extraction and reinjection fences as close together as possible Favored Alternative: F Next Most Favored Alternative C1	Suggestions proposed are good ones and the program has been utilizing these strategies as they are developed.
67	CC Group of the Sierra Club Christopher Neill	General Public	- Flexibility needs to be built into the long-term pumping scheme to deal with problems such as disruptive changes to the water table, that arise from the active cleanup. In here should be public input into reassessment of each plume cleanup after not less than three years.	Comment noted. The performance monitoring evaluation plans that are to be submitted will contain flexibility to allow for changing conditions over time. Under EPA regulations, AFCEE is required to assess the performance of the system and any modifications necessary every five (5) years. However, the public will be kept well informed on the operation of each of the treatment systems to be installed, and if necessary, evaluation can be performed prior to the five (5) year period if conditions warrant.
68	CC Group of the Sierra Club Christopher Neill	General Public	There should be a scheduled public review of how well each plan is working at a pre-determined time after each plume containment plan goes on line. We suggest a maximum of two years post start-up.	Comment noted. Although there is no scheduled public review on the operation of the systems, periodic updates on the operation of the systems with respect to their design characteristics should be made available for public review.
69	William Kurker	Neighborhood	I do not want any buildings built where they can be seen. I don't want to hear any noise. I go along with Alternative G, let it alone.	Preference noted.
70	Jean Innis	Neighborhood	Alternative B seems to be the best option because recirculation wells have not been proven to be effective.	Preference noted.
71	Leroy Woodwald	Neighborhood	I would like to change my rec. from A to F providing that the recirc. wells on Horseshoe Bend are totally underground and silent, and to expedite the extraction fence and recirculating wells, if this can't happen then I will stay with A.	Preference noted.
72	Charles W. Alexander	Neighborhood	1. I'm in favor of either C-1 or F.	Preference noted.
73	Edward Weher	Neighborhood	1. The Air Force buy all of Horseshoe Bend Way at full market values (market values as a clean area). 2. The Air Force lease back for 99 yrs. to the owners and their estate. Lease back at $1.00 per year.	The Air Force can only lease at or buy property at fair market value, as needed to support construction and operations.
74	Karl Prinz	Neighborhood	A major problem that I have confronted is the extremely disturbing noise that is coming from the operation of the test pump system that is located on Sandwich Road at the beginning of Horseshoe Bend. It is intolerable. Any chosen system must solve the noise problem before installation. The increasing publicity about the plumes has adversely effected the value of my property. The Air Force should look into some means of compensating the owners of property that has been affected, especially the loss in value that has been created by the MMR.	The blowers associated with the recirculating wells that were recently pilot tested within the CS-10 plume are a source of noise. These systems will be designed to minimize noise through a variety of methods including the use of quieter components, sound insulation, vibration dampening, destructive interference of sound waves, and locating equipment in below ground vaults.
75	Karl Prinz	Neighborhood	I choose Response B for the following reasons: Property access difficulties south of Sandwich Road would be huge. I would actively oppose pumping stations and other activities in this area. Ecological areas south of Sandwich Road are very sensitive and require the greatest of care. Horseshoe Bend would suffer significant socioeconomic impact "because of the intrusive nature of the system and the need for long term maintenance of wells, pumps, and pipelines in the community". The entire system would be on MMR property under this plan.	Preference noted.
76	Senior Management Board Selectmen	Senior Management Board Selectmen	The SMB Selectmen wish to state their preferences in writing regarding the remedial alternatives for CS-10 presented and discussed at the 6 August Senior Management Board meeting. We have listed our preferences by town. Please note that SMB member Nancy Caffyn has submitted her comments and preference via the Town of Mashpee's letter dated 6 August 1997. Haydon Coggeshall of Bourne prefers C1. His comments are as follows: Preferred, with additions as suggested by the JPAT. Virginia Valiela of Falmouth prefers C1 or F. Her comments are as follows: Preferred, with additions as suggested by the JPAT. Can live with this alternative. Bob Jones of Sandwich prefers C, C1 and F but will defer to the wishes of those towns most affected by this plume.	Preference noted.
77	Conservation Commission	Town of Mashpee	Alternatives A,B,D,E, and G are not favored, due to (respectively) concerns about the efficacy of mitigation measures, portions of the plume that would remain untreated and/or insufficient removal of contaminants.	Preferences noted.
78	Conservation Commission	Town of Mashpee	We would also like to insert a cautionary note concerning the threshold of 0.5 feet for changes in ambient pond levels (0.2 feet in vernal pools). While these would seem to be reasonable under most conditions, such as changes during drought/low water episodes could be more damaging to nearshore plant and animal communities than otherwise might be. Has that possibility (and possible remedies) been considered: (Ashumet, like other area ponds is relatively high now, but for much of the last ten years it, and isolated wetlands in the vicinity, have been lower than historical mean water levels.) In general, if the possibility exists to lower these thresholds even more, such would be encouraged.	The design targets are scientifically based and have been developed in conjunction with the ecological TRET. They reflect a ecological conservative estimate of change that would minimize the potential impact associated with groundwater treatment systems. The scientific basis of the design targets are presented in the Work Plan for Ecological Assessment Associated with Groundwater Plumes and Remedial Activities at MMR (AFCEE 1997). These thresholds, such as the 0.5 feet of change in water level, was developed to assist engineers and hydrogeologists in providing ecologically sound alternatives for groundwater treatment systems. However, during the operation of these groundwater treatment systems the downgradient surface water bodies will be monitored for a variety of physical, physicochemical, and chemical parameters. As part of this monitoring plan, contingencies have been developed to respond to unacceptable changes or conditions trending toward an unacceptable ecological impact. Water level data collected in 1993 (not current conditions) has been used to calibrate the groundwater and to establish a baseline water level to which the model compares drawdown/mounding. During final design additional model refinement will be conducted in an attempt to minimize potential impacts of the selection alternative.
79	Dunn. & Kulis	AVPOI	Based on information gleaned from public meetings, poster sessions, literature, news accounts and conversations with personnel associated with the clear-up of the MMR we lend our support for CS-10 Plume Response Alternative B. There are several reasons why we favor option B. The most important reason is that this option will restrict all well installation and construction to the MMR property. Alternatives A, C, D, require well installation on private property to varying degrees This has the potential to further delay implementation of the project without significant gains in the amounts of contaminants captured. This is especially true if litigation is required to gain access to the private properties on the northwestern perimeter of Ashumet Pond. Alternatives A, C, and D also have the drawback of impacting sensitive ecological habitats adjacent to the pond. We believe that the marginal benefits of near pond remediation do not out weigh these risks.	Preferences noted.
80	Dunn. & Kulis	AVPOI	Even though we support alternative B we are disappointed that none of the alternatives for treatment of CS-10 consider treatment of the phosphorus plume which lies above the northwestern most lobe of the CS-10 plume nearest to Ashumet pond. It is our understanding from conversations with the 102nd Fighter Interceptor Wing (FIW) that remediation for the phosphorus plume will be funded by the 102nd FIW. In the interests of achieving the most cost effective and expedient solution, the final design plans for CS-10 should recognize and include this parallel effort to treat the phosphorus plume. The phosphorus plume will have the most ecologically deleterious impact on the pond of all the MMR plumes. Because of the time critical nature of the threat from the phosphorus plume, it would be prudent to determine if treatment of this plume could be accelerated by including this effort with the chosen CS- 10 alternative. This could easily be accomplished, for example, by the addition of additional extraction and injection wells for the phosphorus plume and utilization of the CS-10 treatment facility to process contaminated ground water from both plumes.	Phosphorus contamination is not associated with the CS-10 plume. Phosphorus is associated with the Ashumet Valley plume which originates in the areas of the former waste water treatment infiltration basins and the former fire training area (FTA-1), each of which are closed. FTA-1 is undergoing remediation. Options for remediation of the waste water treatment basins are currently under evaluation. The hydraulic control and treatment of the Ashumet Valley plume has been presented in a series of alternatives which are currently under public comment (14 July 1997 through 2 September 1997). Although the alternatives from both the Ashumet Valley plume and CS-10 plumes are undergoing separate review/comment processes, it is quite possible that the fence controlling the phosphorus piece of the Ashumet Valley plume will be integrated into the CS-10 treatment plant.
81	Dunn. & Kulis	AVPOI	In the event that remediation of the phosphorus plume is not included in the CS-10 treatment alternative, funds to support a program of rigorous monitoring of the phosphorus plume and its impact on the pond should be secured and put in place to ensure that remediation of CS-10 does not exacerbate the intrusion of phosphorus into Ashumet Pond. The United States Geological Survey (USGS) has completed an extensive program of research on migration of phosphorus in the Ashumet Valley groundwater, and has noted that injection of treated water into the Ashumet Valley aquifer could cause the currently sorbed phosphorus to flush rapidly into Ashumet Pond. Monitoring would help to guard against this adverse ecological impact.	Phosphorus contamination is not associated with the CS-10 plume. Phosphorus is associated with the Ashumet Valley plume which originates in the areas of the former waste water treatment infiltration basins and the former fire training area (FTA-1), each of which are closed. FTA-1 is undergoing remediation. Options for remediation of the waste water treatment basins are currently under evaluation. The hydraulic control and treatment of the Ashumet Valley plume has been presented in a series of alternatives which are currently under public comment (14 July 1997 through 2 September 1997). Although the alternatives from both the Ashumet Valley plume and CS-10 plumes are undergoing separate review/comment processes, it is quite possible that the fence controlling the phosphorus piece of the Ashumet Valley plume will be integrated into the CS-10 treatment plant.
82	Susan V. Walker	REPS	Our preference is for alternatives C1 and F. These alternatives have a high degree of plume capture and prevent some contaminants from migrating to the silts. The reinjection wells near Ashumet Pond will reduce damage on sensitive ecological habitats near the pond unlike alternative A. We are hopeful that access issues for alternatives C1 and F well be less likely to delay the project than alternative A.	Preferences noted.
83	Susan V. Walker	REPS	However, we are concerned that alternative F would operate at a total flow rate of approximately 9.1 million gallons per day But we do not see any negative rating about this in the evaluation matrix. so we are assuming there is no detrimental impact.	Alternative F is the most aggressive scenario proposed, and therefore has the greatest potential to impact the regional flow field. The alternative as modeled does not pass the hydrological thresholds. It is expected that design refinements of the selected alternative will lessen the simulated impacts to surface water bodies however it is not known whether Alternative F can be designed to pass all thresholds.
84	Susan V. Walker	REPS	We agree with the position of the JPAT that C1 would be improved with recirculating wells in the hot spot. Whatever alternative in chosen REPS expects vigilant monitoring to take place. Monitoring should lead to any necessary adjustments that are needed for plume capture, human health and ecological protection.	Preferences noted. A system perfomance and compliance monitoring program will be associated with any of the active system alternatives. This will enable adjustments in system operations to be made to enhance or improve performance. Examples of the scope of the monitoring efforts typical of the proposed remedial strategies are provided by the FS-12 (soon to go on line) and SD-5 (on line 4 August 1997) performance monitoring plans which have been developed in coordination with the regulatory agencies.
85	Peter F. Boyer, Town of Falmouth	General Public	1) Regardless of what alternative is selected to capture and treat the CS-10 plume, a long-term monitoring system should be installed downstream of the treatment train to check on the effectiveness of the treatment.	A system perfomance and compliance monitoring program will be associated with any of the active system alternatives. This will enable adjustments in system operations to be made to enhance or improve performance. Examples of the scope of the monitoring efforts typical of the proposed remedial strategies are provided by the FS-12 (soon to go on line) and SD-5 (on line 4 August 1997) performance monitoring plans which have been developed in coordination with the regulatory agencies.
86	Peter F. Boyer, Town of Falmouth	General Public	2) If, in spite of treatment, concentrations of VOC's exceeding the drinking water standard continues to flow downstream towards Falmouth's municipal water supply wells, the Department of Defense (DoD) must pay for wellhead treatment on those supply wells or provide an equivalent amount of water from uncontaminated sources at no charge to the Town. DoD must include this stipulation in the Record of Decision for CS-10.	The Department of Defense is committed to protecting or replacing water supply wells and it is stated in the Decision Criteria for CS-10 as part of the alternatives. The Record of Decision will also reflect the need and responsibility for such actions.
87	Peter F. Boyer, Town of Falmouth	General Public	3) The selected alternative should not destroy the research site in the sand pit west of Sandwich Road which has been used by the U.S. Geological Survey since the late 1970's to study the hydrology of the Cape aquifer in general, and the Ashumet Valley Plume in particular. If necessary, a small portion of the CS-10 plume should be uncaptured in order to protect the research site.	Our goal has been to develop alternatives that attempt to achieve 100% capture of the CS-10 plume. However, we have been evaluating impacts of CS-10 pumping strategies on the Ashumet Valley plume with an eye toward minimizing impacts to its trajectory and flow paths. As we move past the conceptual design phase toward detailed design we will be continuing to refine well screen placements, screen lengths, and pumping rates to further reduce any impacts to the Ashumet Valley plume and the U.S.G.S. research site. The possible need for a reduction in capture associated with the selected CS-10 alternatives to ensure minimal impacts to the Ashumet Valley plume has been discussed with the RPMs. In short, potential impact to the U.S.G.S. research site will continue to be a constraint that will be evaluated as investigative and modeling work are conducted to support detailed design efforts.
88	Peter F. Boyer, Town of Falmouth	General Public	4) The selected alternative should be cognizant of the close proximity of the Ashumet Valley Plume in the Sandwich Road area and, in particular, the phosphate portion of that plume The alternative should not cause large amounts of phosphate to be released into Ashumet Pond.	The hydraulic control and treatment of the phosphorus portion of the Ashumet Valley plume in the vicinity of Ashumet Pond has been presented in a series of alternatives which are currently under public comment (14 July 1997 through 2 September 1997). These strategies are designed to minimize potential migration of phosphorus to Ashume