Fact Sheet #2000-08
October 2000

Federal Facility Agreement (FFA) Schedule Amendments

A fact sheet providing an update on the Federal Facility Agreement Schedules

The purpose of this fact sheet is to describe the updates that have been made to the schedules, which are part of the revised Federal Facility Agreement (FFA) signed in 2000.

  • The current FFA is an agreement between the Air Force, the National Guard Bureau and the U.S. Environmental Protection Agency (EPA), guiding the Superfund cleanup of the Massachusetts Military Reservation (MMR). It contains the schedules and deadlines for all sites on the base that are being investigated and cleaned up under the Installation Restoration Program (IRP), the base cleanup program for past environmental contamination.
  • According to the FFA, EPA may grant extensions to enforceable deadlines when circumstances are determined to constitute good cause.
  • Changes to the enforceable deadlines are associated with two types of cleanup actions: [1] Source Area Actions and [2] Groundwater Plume Response Actions.
  • A table summarizing all of the new schedule amendments to the FFA is provided on pages 5 and 6.

Words that appear in italics are defined in the glossary at the end of this fact sheet. This fact sheet is an update to a previously published one (#99-10 in October 1999). The following acronyms are used throughout this document: (CS) Chemical Spill; (CY) Coal Yard; (FS) Fuel Spill; (FTA) Fire Training Area; (LF) Landfill and (SD) Storm Drain.

Background

The first schedule, contained in Appendix III, Timetable 2 of the FFA, established enforceable deadlines for ongoing source control actions at the MMR. Specifically, this schedule sets deadlines for decisions for areas requiring soil and/or sediment cleanup.

The second schedule contains the enforceable deadlines pertaining to groundwater plume response actions, the cleanup of contaminated groundwater, at and originating from the MMR. This schedule was added to the FFA as Appendix III, Timetable 3 on May 30, 1997.

The attached FFA Milestone Changes Summary table indicates where changes to previous deadlines have been made. The table references a source area or groundwater plume, the document to which the deadline applies, the former date, the revised date, and the justification for making the change. EPA has agreed to the noted changes. EPA and the Air Force Center for Environmental Excellence (AFCEE) have consulted with the Commonwealth of Massachusetts Department of Environmental Protection (DEP) regarding these changes.

Source Area Actions

CS-16/CS-17, CS-10/FS-24, SD-5/FS-5, SD-3/FTA-3/CY-4, SD-4, SD-2/FS-6/FS-8, CS-5, CS-11, Drum Disposal Unit (DDOU), FS-18, CS-4(CG)/FS-1 (CG), FS-7, and FS-9: The Record of Decision (ROD) for these sites specified asphalt batching as the agreed option for cleanup. After the ROD was signed, new milestones for these sites were added to the FFA, as required.

  • The new FFA milestone for the Draft Source Area Work Plan Addendum is February 26, 2001. There was no old FFA date for this document.
  • The new FFA milestone for the excavation start-up date is April 25, 2001. There was no old FFA date for this milestone.
  • The new FFA milestone for the Draft Final Remedial Action Closeout Report is May 22, 2002. There was no old FFA date associated with this document.

CS-10/FS-24(Detail C), Petroleum Fuel Storage Area (PFSA)/FS-10/FS-11 and FTA-2/LF-2: The Record of Decision (ROD) for these sites specified soil vapor extraction (SVE) and biosparging as the agreed option for cleanup. After the ROD was signed, new milestones for these sites were added to the FFA, as required.

  • The new FFA milestone for the submission of the Draft Final SVE and biosparging design is January 18, 2001. There was no old FFA milestone associated with this document.
  • The new FFA milestone for SVE/biosparging system start-up is October 8, 2001. There was no old FFA date associated with this milestone.
  • The new FFA milestone for the Draft Interim Remedial Action Closeout Report is June 5, 2002.

Fuel Spill 2 (FS-2): Originally, the FS-2 site was to be considered part of the Southwest Operable Unit (SWOU) program. After review by the regulatory agencies, the FS-2 site was then listed individually, and thus new FFA milestones were added.

  • The new FFA date for the submittal of the draft Streamlined Remedial Investigation (RI) Workplan was March 18, 2000. This deadline was met.
  • The new FFA date for the submittal of the draft RI Addendum was October 15, 2000. This deadline was met.
  • The new FFA date for the submittal of the draft Proposed Plan (PP) is March 2, 2001. There was no old FFA date associated with this document.
  • The new FFA date for the submittal of the draft ROD is July 29, 2001. There was no old FFA date associated with this document.

Groundwater Plume Response Actions

Ashumet Valley (Axial): Pursuant to provisions of Section VII and XIV of the FFA between AFCEE, the NGB, and EPA, new milestones were added to the FFA in 2000.

  • The new FFA date for the submission of the Draft Interim Remedial Action Closeout Report is January 19, 2002. There was no old FFA date associated with this document.

Chemical Spill 10 (CS-10) Groundwater Operable Unit: In 1999, new enforceable deadlines were added to the FFA to finalize previous cleanup decisions for the entire CS-10 groundwater operable unit. However, AFCEE and the regulatory agencies have decided that additional investigative work must be accomplished in the area of Ashumet and Johns Ponds that was not part of the original (RI) scope of work. This additional work has necessitated a change in the enforceable milestone.

  • The new FFA date for the submittal of the draft RI Workplan was February 10, 2000. This deadline was met.
  • The old FFA date for the submittal of the draft RI was October 24, 2000. The new FFA date is March 6, 2001.
  • The old FFA date for the submittal of the draft Feasibility Study (FS) was June 11, 2001. The new FFA date is November 17, 2001.
  • The old FFA date for the submittal of the draft PP was November 2, 2001. The new FFA date is March 22, 2002.
  • The old FFA date for the submittal of the draft ROD was March 31, 2002. The new FFA date is August 16, 2002.

Chemical Spill 10 (Sandwich Road, In-plume, and Southern/Southwest): Pursuant to provisions of Section VII and XIV of the FFA between AFCEE, the NGB, and EPA, new milestones for the submission of the Draft Interim Remedial Action Closeout Report were added to the FFA in 2000.

  • The new date for this milestone is March 5, 2001. There was no old FFA date associated with this document.

Chemical Spill 19 (CS-19): The newly revised milestone dates reflect those changes based on the non-availability of funding, which was determined by the regulatory agencies to be in accordance with the "Force Majeure" provision under the FFA. Furthermore, the current agreement to perform additional investigations at the CS-19 site in 2000-2001 have also required a change or extension to some of the original schedules.

  • The old FFA date for the submittal of the draft RI Workplan was August 14, 1999. This deadline was met.
  • The old FFA date for the submittal of the draft RI was April 27, 2000. The new FFA date was June 28, 2000. This deadline was met.
  • The old FFA date for the submittal of the draft FS was November 18, 2000. The new FFA date is to be determined.
  • The old FFA date for the submittal of the draft PP was March 16, 2001. The new FFA date is to be determined.
  • The old FFA date for the submittal of the draft ROD was August 4, 2001. The new FFA date is to be determined.

Fuel Spill 1 (FS-1): After the FS-1 ROD was signed, new milestones for this groundwater plume were added, as required by the FFA.

  • The new FFA date for the submission of the Draft Wellfield Design Report is June 18, 2001. There was no old FFA milestone for this document.
  • The new FFA milestone for system start-up is October 30, 2002. There was no old FFA milestone.

Fuel Spill 12 (FS-12): Pursuant to provisions of Section VII and XIV of the FFA between AFCEE, the NGB, and EPA, new milestones for the submission of the Draft Interim Remedial Action Closeout Report were added to the FFA in 2000.

  • The new FFA date for this milestone is January 19, 2001. There was no old FFA milestone for this document.

Landfill 1 (LF-1): Pursuant to provisions of Section VII and XIV of the FFA between AFCEE, the NGB, and EPA, new milestones for the submission of the Draft Interim Remedial Action Closeout Report were added to the FFA in 2000.

  • The new FFA date for this milestone is January 19, 2002. There was no old FFA milestone for this document.

Storm Drain 5 (SD-5 North and South): Pursuant to provisions of Section VII and XIV of the FFA between AFCEE, the NGB, and EPA, new milestones for the submission of the Draft Interim Remedial Action Closeout Report were added to the FFA in 2000.

  • The new FFA date for this milestone is February 3, 2001. There was no old FFA milestone for this document.

Southwest Operable Unit (SWOU-Phase II): A 45-day extension was added to the normal 30-day public comment period on the Proposed Plan for the FS-28/29 groundwater plumes at the request of the public. This activity impacted the previously agreed to schedule.

  • The old FFA date for the submittal of the draft ROD was March 25, 2000. The new FFA date was June 15, 2000. This deadline was met.

GLOSSARY

biosparging—Biosparging is the use of injected air (oxygen) into soil or groundwater to speed up bioremediation-a treatment process where naturally occurring microorganisms (yeast, fungi, or bacteria) breaks down hazardous substances into less toxic or nontoxic substances.

cold-mix asphalt batching—Cold-mix asphalt batching is a process where soils with low concentrations of contaminants are made into paving material by the addition of a heated emulsion at less than 120°F. The process is regulated by the Massachusetts Department of Environmental Protection (DEP) and the final product is used statewide as a base under asphalt paved surfaces.

enforceable deadlines—the time limitation applicable to issuance by the lead agency of all primary documents up to an including all record of decisions (RODs) for which a limitation has been specifically established under the terms of the FFA. Also sometimes referred to as enforceable milestones.

Feasibility Study (FS)—a report that identifies and screens potential cleanup alternatives for a site that requires further remedial action.

Force Majeure—any event arising from causes beyond the control of the party that causes a delay in, or prevents the, performance of any obligation.

Proposed Plan (PP)—a document that summarizes the preferred remedial action for a site and presents the rationale for the preference.

Record of Decision (ROD)—a document presenting the remedial action selected under agreement with the regulatory agencies and also includes a record of public comments and the responsiveness summary

Remedial Action Closeout Report—The Remedial Action Report documents the activities that occur under each specific remedial action operable unit at a site. It also provides documentation that a particular operable unit has met its objectives, and certifies that all items in the settlement agreement and any incorporated documents have been met.

Remedial Investigation (RI)—an investigation to gather and analyze data necessary to determine the nature and extent of contamination of a site.

Soil Vapor Extraction (SVE)— SVE extracts contaminants from the soil in vapor form. By applying an air vacuum through a system of underground wells, contaminants are pulled to the surface in vapor form. Often, in addition to vacuum extraction wells, air injection wells are installed to increase the airflow and improve the removal rate of the contaminant vapor. Vapors extracted by the SVE process are typically treated using carbon filtration. Once the carbon filters are spent, they are taken off-site and recycled.

Source Area Workplan Addendum—a site specific workplan that delineates the boundaries of impacted soils for excavation and/or on-site remediation.

Wellfield Design Report—a document that denotes the complete design for remediation of a specific site, most often involving groundwater plumes. The report details the approximate number, location, and type of extraction wells needed and also what type of discharge from the treatment plant there will be (i.e. reinjection, infiltration gallery or surface).

For more information:

Doug Karson, Community Involvement Specialist
HQ AFCEE/MMR
322 East Inner Road
Otis ANGB Base, MA 02542-5028
Phone: (508) 968-4678 x 2 Fax: (508) 968-4673
e-mail:
doug.karson@mmr.brooks.af.mil

Jim Murphy, Community Involvement Coordinator
USEPA New England Region, Suite 1100
One Congress St (RAA)
Boston, MA 02203
Phone: (617) 918-1028 Fax: (617) 918-1029
Toll free # (888) 372-7341 ext. 81028
e-mail:
murphy.jim@epa.gov

 

Table 1: FFA Milestone Changes Summary

SOURCE AREA RESPONSE ACTIONS

ASPHALT BATCHING

Site

Draft Document

Old FFA Date

New FFA Date

Reason for change

CS-16/CS-17

Source Area Workplan Addendum

Asphalt Batching – Excavation Startup Date

Final Remedial Action Closeout Report

N/A

February 26, 2001

 

April 25, 2001

May 22, 2002

These documents are required by the FFA after the signature of the Final ROD.

CS-10/FS-24

SD-5/FS-5

SD-3/FTA-3/CY-4

SD-4

SD-2/FS-6/FS-8

CS-5

CS-11

DDOU

FS-18

CS-4 (CG)/FS-1(CG)

FS-7

FS-9

SOIL VAPOR EXTRACTION/BIOSPARGING

CS-10/FS-24(Detail C)

PFSA/FS-10/FS-11

FTA-2/LF-2

Soil Vapor Extraction and Biosparging Final Design

N/A

January 18, 2001

These documents are required by the FFA after the signature of the Final ROD.

System Startup Date

October 8, 2001

Interim Remedial Action Closeout Report

June 5, 2002

OTHER

Fuel Spill-2 (FS-2)

Streamlined Remedial Investigation Work Plan

N/A

March 18, 2000

Originally, the FS-2 site was to be considered under the SWOU program. After review by the regulatory agencies, FS-2 was then listed individually, and thus FFA milestones were established.

Remedial Investigation Addendum

October 15, 2000

Proposed Plan

March 2, 2001

Record of Decision

July 29, 2001

Deadlines were based on a comparison between:

  1. Appendix III, Timetable 2 to FFA milestones (30 August 99 versus 30 Oct 00)
  2. Appendix III, Timetable 3 to FFA milestones (30 August 99 versus 30 Oct 00)

 

Table 1 (con’t): FFA Milestone Changes Summary

GROUNDWATER PLUME RESPONSE ACTIONS

Site

Draft Document

Old FFA Date

New FFA Date

Reason for change

Ashumet Valley (axial system)

Interim Remedial Action Closeout Report

N/A

January 19, 2002

This report is required by the FFA.

Chemical Spill 10 (CS-10) Groundwater Operable Unit

Remedial Investigation

October 24, 2000

March 6, 2001

Additional investigative work to be accomplished in the area of Ashumet and Johns Pond that was not part of the original remedial investigation scope of work.

Feasibility Study

June 11, 2001

November 17, 2001

Proposed Plan

November 2, 2001

March 22, 2002

Record of Decision

March 31, 2002

August 16, 2002

Interim Remedial Action Closeout Report

N/A

March 5, 2001

This report is required by the FFA.

Chemical Spill-19 (CS-19)

Remedial Investigation

April 27, 2000

June 28, 2000

Original draft RI report submission was delayed due to the non-availability of funding. Remainder of FFA milestones under discussion due to requirement to perform additional field investigations agreed to by all signatories to the FFA.

Feasibility Study

November 18, 2000

To be determined

Proposed Plan

March 16, 2001

To be determined

Record of Decision

August 4, 2001

To be determined

Fuel Spill–1 (FS-1)

Wellfield Design Report

N/A

June 18, 2001

These milestones are required by the FFA after the signature of the Final ROD.

System Start-up

October 30, 2002

Fuel Spill-12 (FS-12)

Interim Remedial Action Closeout Report

N/A

January 19, 2001

This report is required by the FFA.

Landfill-1 (LF-1)

Interim Remedial Action Closeout Report

N/A

January 19, 2002

This report is required by the FFA.

Storm Drain-5 (SD-5) North and South

Interim Remedial Action Closeout Report

N/A

February 3, 2001

This report is required by the FFA.

SWOU (Phase II):

Fuel Spills-28 and -29 (FS-28/FS-29)

Record of Decision

March 25, 2000

June 15, 2000

A 45-day extension was added to the normal 30-day public comment period on the Proposed Plan.

Deadlines were based on a comparison between:

  1. Appendix III, Timetable 2 to FFA milestones (30 August 99 versus 30 Oct 00)
  2. Appendix III, Timetable 3 to FFA milestones (30 August 99 versus 30 Oct 00)
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