Fact Sheet #99-10
October 1999

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 Federal Facility Agreement (FFA).

• The FFA is an agreement between the Air Force, the National Guard Bureau, the U.S. Coast Guard, and the U.S. Environmental Protection Agency (EPA), guiding the 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 4 and 5.

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 (#98-15 in September 1998).

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 sediment cleanup.

The second schedule contains the enforceable deadlines pertaining to 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 the source area or the plume affected, 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 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

The study areas, U.S. Coast Guard Chemical Spill 8 (USCG CS-8) and Chemical Spill 22 (CS-22) have been added to the FFA. These study areas are currently undergoing a preliminary assessment/site investigation (PA/SI) and enforceable deadlines will be established if and when a remedial investigation & feasibility study (RI/FS) is warranted.

Priority 2 & 3 Sites/Drum Disposal Operable Unit (DDOU): In accordance with the requirements of the FFA, enforceable deadlines for these sites were added to the FFA upon completion of the Action Memorandum. More specifically, the submittal of the draft 100% remedial design as a result of the Engineering Evaluation/Cost Analysis (EE/CA) and Action Memorandum that was signed in June 1999 was added.

The Priority 2 & 3 sites are made up of the following: Chemical Spill 5 (CS-5), Chemical Spill 11 (CS-11), Chemical Spill 15 (CS-15), Fuel Spill 4 (FS-4), Fuel Spill 18 (FS-18), United States Coast Guard Chemical Spill 4 (USCG CS-4), United States Coast Guard Fuel Spill 1 (USCG FS-1), the DDOU and Fuel Spill 7 (FS-7).

• Since the last update (September 1998), a final design schedule was negotiated. That date is December 6, 1999.

Fuel Spill 1 (FS-1): For the FS-1 source area, additional alternatives analysis and resubmittal of the feasibility study (FS) were required prior to proceeding with the Proposed Plan (PP) and ROD process.

• The old date for the draft PP was December 14, 1998. The new date was March 25, 1999. This deadline was met.
• The old date for the draft ROD was March 25, 1999. The new date was August 25, 1999. This deadline was met.

Groundwater Plume Response Actions

Ashumet Valley (Pond Fence): In lieu of an active remedial system startup of the Ashumet Valley pond fence, the FFA milestone was modified to recognize the submittal of the draft Phosphorus Management Plan.

• The old FFA date (September 2, 1999) associated with system startup for the Ashumet Valley pond fence has been deferred. However, a new FFA date was established for submittal of the draft Phosphorus Management Plan of September 2, 1999. This deadline has been met.
• In addition, a new FFA deadline was established associated with the submittal of draft Phosphorus Action Recommendation/Action Schedule. The new deadline for submittal of this draft document is February 18, 2000.

Chemical Spill 10 (CS-10) Groundwater Operable Unit: New enforceable deadlines were added to the FFA to finalize previous decisions leading to the ROD for the entire CS-10 groundwater operable unit. New sets of enforceable FFA deadlines were agreed upon, as listed below. There were no old FFA dates associated with these new additions to the FFA.

• The new FFA date for the submittal of the draft RI Workplan is February 10, 2000
• The new FFA date for the submittal of the draft RI is October 24, 2000.
• The new FFA date for the submittal of the draft FS is June 11, 2001.
• The new FFA date for the submittal of the draft PP is November 2, 2001.
• The new FFA date for the submittal of the draft ROD is March 31, 2002.

Chemical Spill 10 (CS-10) South/Southwest Fence: A new FFA date was added to meet the previously agreed upon full system startup date of April 30, 2000.

• There is no old FFA date associated with CS-10 South/Southwest Wellfield Design Report. The new FFA date was October 21, 1999.

Storm Drain 5 South (SD-5S): In accordance with the original FFA deadline (June 22, 1999), two re-circulating wells were installed in the main body of the SD-5S plume. Several changes have been made in the remedial approach to cleaning up the remainder of the SD-5S plume. Recent investigations in that area discovered a new plume area (TCE plume) between Ashumet and Johns Ponds. Consequently, a Time Critical Removal Action (TCRA) was added for the TCE plume and to further capture the leading edge of the SD-5S plume.

• The new FFA date for the submittal of the draft wellfield design report was July 12, 1999. This deadline was met.
• The new FFA date for startup of the SD-5S ETR system is January 31, 2000.

Southwest Operable Unit (SWOU, phase I): During the SWOU investigation, several new plume areas were discovered- CS-20 and CS-21. CS-4 and FS-13 were already known before the SWOU investigation. Due to the complex nature of CS-4, CS-20, CS-21 and FS-13, the public comment period on the proposed plan was extended from 30 days to 60 days.

• The old FFA date for submittal of the draft ROD for these plumes was August 17, 1999. The new FFA date for submittal of the draft ROD for these plumes was October 5, 1999. This deadline has been met.

Southwest Operable Unit (SWOU-Phase II): As part of the original SWOU program to investigate the already known FS-28 plume area, another plume area, FS-29 was discovered. Based on regulatory input, the FS-28 and FS-29 plumes were separated into a second phase of the SWOU program. Additional data collection was required by the regulatory agencies and additional remedial alternatives were requested for those plumes based upon this additional work. This was a modification of the original scope of work in the SWOU program. New sets of enforceable FFA deadlines were agreed upon, as listed below.

• The new FFA date for the submittal of the draft FS was July 11, 1999. This deadline was met.
• The new FFA date for the submittal of the draft PP was October 11, 1999. This deadline was met.
• The old FFA date associated with the submittal of draft ROD for FS-28 and FS-29 was August 17, 1999
• The new FFA date for the submittal of the draft ROD is March 25, 2000.

Fuel Spill 1 (FS-1): For the FS-1 groundwater plume, additional alternatives analysis and resubmittal of the feasibility study (FS) were required prior to proceeding with the Proposed Plan (PP) and ROD process.

• The old date for the draft PP was December 14, 1998. The new date was March 25, 1999. This deadline was met.
• The old date for the draft ROD was March 25, 1999. The new date was August 25, 1999. This deadline was met.

GLOSSARY

Action Memorandum—A decision document that presents the selected removal action alternative and explains the rationale for the selection. The Action Memorandum also includes responses to public comments and concerns raised during the comment period.

enforceable deadlines—the time limitations 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.

Engineering Evaluation/Cost Analysis (EE/CA)—An expedited Superfund process of identifying and evaluating cleanup alternatives for a site where there is a potential threat to human health or the environment. The EE/CA must be made available for a 30-day public comment period prior to the signing of the Action Memorandum.

extraction, treatment, and reinjection (ETR)—a system that extracts groundwater, treats it to reduce or eliminate contaminants and reinjects the treated water into the aquifer.

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

Phosphorus Management Plan—a document that evaluates pond phosphorus management options. It offers various remedial approaches to phosphorus loading to surface water bodies, namely Ashumet Pond.

Preliminary Assessment/Site Investigation (PA/SI)- The Preliminary Assessment (PA) and Site Inspection (SI) are used by EPA to evaluate the potential for a release of hazardous substances from a site.

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 Investigation/Feasibility Study (RI/FS)—an investigation to gather and analyze data necessary to determine the nature and extent of contamination of a site. A feasibility study identifies and screens potential cleanup alternatives for a site that requires further remedial action.

Time Critical Removal Action (TCRA)—a regulatory approach used when quick actions are needed to clean up a hazardous material spill, but when fewer than six months are available to design the treatment system.

100% Remedial Design—plans, drawings and specifications for a remedial action alternative suited for a specific site.

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 Region I, Suite 1100
One Congress St (RAA)
Boston, MA 02203
Phone: (617) 918-1028 Fax: (617) 918-1029
e-mail: murphy.jim@epa.gov

Deadlines were based on a comparison between:
Appendix III, Timetable 2 to FFA milestones (30 August 98 versus 30 Aug 99)
Appendix III, Timetable 3, dated 30 August 98 versus 30 Aug 99

Click here to download Appendix III, timetable 2 in excel format
Click here to download Appendix III, timetable 3 in excel format

Complete 1st 10 Wells