August 1997

Federal Facility Agreement Schedule Changes

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

The purpose of this fact sheet is to describe the updates that have been made to the schedules which are a part of the Federal Facility Agreement (FFA). The FFA is an agreement between the Air Force Center for Environmental Excellence (AFCEE), the National Guard Bureau, the U.S. Coast Guard, and the U.S. Environmental Protection Agency (EPA) that guides the cleanup of the Massachusetts Military Reservation (MMR). The FFA contains the operative schedules for all sites on the base that are being investigated under the Installation Restoration Program, the base cleanup program for past environmental contamination.

The first schedule, contained in Appendix III, Timetable 2 of the FFA, established enforceable dates for numerable ongoing source control actions at the MMR. Specifically, this schedule set deadlines for decisions for areas requiring soil and sediment cleanup. This schedule was last updated in August 1995. The second schedule contains the enforceable dates 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.

Under the FFA, extensions of enforceable deadlines may be granted by EPA under certain circumstances which are determined to constitute good cause. Some of the circumstances which led to extensions or other changes in the schedule include:

  • Completion of a basewide underground drainage structure removal program which has resulted in a determination that no further cleanup is necessary at several sites.
  • Revisions to the Risk Assessment Handbook, which governed the approach to evaluating the risk of potential actions, required the reevaluation of data at several sites.
  • A decision not to implement recirculating well pilot tests at two locations because AFCEE could extrapolate the needed data from other ongoing pilot tests and had difficulties in obtaining access at those two locations.
  • A government shutdown and the resulting funding delays.

The following tables indicate where changes to previous dates have been made. The first table indicates the changes made to source control deadlines (Timetable 2); the second summarizes the revisions to the plume response schedule (Timetable 3). Each table references the source area or 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 AFCEE regularly consult with the state on major schedule changes.

None of the extensions granted to date have resulted in any changes to end dates for plume response activities. The timetable for ultimate plume decisions remains on schedule. Therefore, EPA and AFCEE believe that the revised schedules represent aggressive yet realistic timetables for the implementation of the MMR cleanup.

Several acronyms used in the tables are defined at the end of this fact sheet.

For more information, please contact:

Vanessa Musgrave
AFCEE Community Involvement Manager
508-968-4678
or
Johanna Hunter
EPA Community Relations
617-565-3425

SOURCE CONTROL ACTIONS

AOC

Document

Old Date

New Date

Reason for Change
CS-1

CS-2

CS-3

FS-23

CS-2 (CG) CS-9

CS-14

 DD

DD

DD

DD

DD

DD

DD

 none

none

none

none

none

none

none

 4/97

4/97

5/97

5/97

6/97

5/97

5/97

 Completed the DSRP for source area closure prior to submitting Decision Document
CS-10 Source FS

PP

ROD

 10/95

5/96

12/96

 10/96

12/97

5/98

 The shutdown of the Federal government delayed the receipt of funding to support contract activity and the EPA required additional time to complete review of the feasibility study resulting in an extension of time for future activities
SD-4 PP

ROD

 6/96

3/97

 2/97

9/97

 EPA required additional time to complete review of the feasibility study resulting in an extension of time for future activities
FS-19 FS

PP

ROD

 5/96

12/96

9/97

 9/96

9/97

2/98

 Revisions to the Risk Assessment Handbook necessitated a rewrite of the RI Report. A decision was made to do a multi-site FS to
FS-17 FS

PP

ROD

 3/96

10/96

7/97

 9/96

9/97

2/98

 expedite the selection of a remedial alternative by combining sites with similar characteristics
FS-9 FS

PP

ROD

 4/96

11/96

8/97

 9/96

9/97

2/98

  
CS-3 (CG) FS

PP

ROD

 2/96

8/96

3/97

 9/96

9/97

2/98

  
LF-2/FTA-2 FS

PP

ROD

 12/95

6/96

1/97

 7/96

2/97

9/97

  
SD-5/FS-5 FS

PP

ROD

 12/95

6/96

1/97

 7/96

2/97

9/97

  
PFSA/

FS-10/FS-11

 FS

PP

ROD

 12/95

6/96

1/97

 7/96

2/97

9/97

  
CS-16/17 FS

PP

ROD

 12/95

6/96

1/97

 9/96

9/97

2/98

  
SD-3/

FTA-3/CY-4

 FS

PP

ROD

 12/95

6/96

1/97

 7/96

2/97

9/97

  
SD-2/

FS-6/FS-8

 FS

PP

ROD

 12/95

6/96

1/97

 7/96

2/97

9/97

  
FS-1 RI

PP

ROD

 TBD 11/97

2/98

9/98

 Additional field work summer of 1997 with revised RI report to be prepared
FS-2 RI TBD TBD Site will be included in SWOU effort

GROUNDWATER PLUME RESPONSE ACTIONS

AOC

Document

Old Date

New Date

Reason for Change
FS-12 Plume Phase II System Start-up TBD 5/15/98 Project scoping needed to be completed prior to setting schedule
CS-10 Plume Completion of 2 pilot ETR extraction wells 6/3/97 deleted Approach for the Pilot ETR was modified to a Conceptual Design, the Data Gap Tech Memo replaced the pilot ETR Test Data Report without a schedule change
Ashumet Valley Plume Draft Full Scale Execution Plan 10/9/97 10/28/97 Approach for the Pilot ETR was modified to a Conceptual Design, the Data Gap Tech Memo replaced the pilot extraction wells and ETR Test Data Report
LF-1 Plume Recirculating Well Technical Assessment Report 10/15/97 9/17/97 Approach to the Recirculating well pilot test was changed to Technology Input. Intermediate steps for field construction and start-up were eliminated and replaced with data extrapolation shortening the schedule
LF-1 Plume Completion of 2 Pilot ETR extraction wells 7/23/97 deleted Approach for the Pilot ETR was modified to a Conceptual Design, the Data Gap Tech Memo replaced the pilot extraction wells and ETR Test Data Report without a schedule change
SD-5 South Plume Recirculating Well Technical Assessment Report 1/31/98 10/22/97 Approach to the Recirculating well pilot test was changed to Technology Input. Intermediate steps for field construction and start-up were eliminated and replaced with data extrapolation shortening the schedule
SD-5 South Plume Completion of 2 Pilot ETR extraction wells 8/26/97 deleted Approach for the Pilot ETR was modified to a Conceptual Design, the Data Gap Tech Memo replaced the pilot extraction wells and ETR Test Data Report without a schedule change
SD-5 South Plume Draft Full Scale Execution Plan 3/24/98 2/2/98 Approach change to Conceptual Design shortened the schedule by eliminating the field pilot test
Western Aquafarm Eastern Briarwood Monitoring Annual Evaluation Report TBD 9/30/97 Project scoping needed to be completed prior to setting schedule
Dates were based on a comparison between:
  1. Appendix III, Timetable 2 to FFA milestones (15 August 1995 versus 18 July 1997)
  2. Appendix III, Timetable 3, dated 30 May 1997 versus current status of 18 July 1997 including all EPA approved modifications (extensions/deletions).

Acronyms

AOC: Area of Concern
CG: Coast Guard
CS: Chemical Spill
CY: Coal Yard
DSRP: Drainage Structure Removal Program
EPA: Environmental Protection Agency
ETR: Extraction, Treatment, and Reinjection
FS-#: Fuel Spill
FS: Feasibility Study
FTA: Firefighter Training Area
LF: Landfill
PFSA: Petroleum Fuel Storage Area
PP: Proposed Plan
ROD: Record of Decision
RI: Remedial Investigation
SD: Storm Drain
SWOU: Southwest Operable Unit
TBD: To Be Determined

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