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PUBLIC HEALTH ASSESSMENT

FORT DEVENS-SUDBURY TRAINING ANNEX
SUDBURY, MIDDLESEX COUNTY, MASSACHUSETTS


PATHWAYS ANALYSES

To determine whether people are exposed to contaminants migrating from STA, ATSDR evaluated the environmental and human components that lead to human exposure. A pathways analysis consists of five elements: source of contamination (e.g., landfills), an environmental medium (media) in which contaminants may be present or from which contaminants may migrate (e.g., movement of contaminants through groundwater), a human exposure point (e.g., contaminated private wells), a human exposure route (e.g., ingestion, inhalation, or dermal contact), and a potentially exposed population (e.g., people using private well water).

ATSDR identifies exposure pathways as completed or potential. Completed exposure pathways exist when the five elements of a pathway link the contaminant source to an exposed population. Potential exposure pathways exist when information on one or more of the five elements is missing.

A. Completed Exposure Pathways

Groundwater Pathway - On-Site Water Supply

Five wells within the STA installation boundary were previously used for drinking water (4). The wells are currently not used as potable water sources.

The only substances detected in groundwater from on-site potable wells, at levels above comparison values, were selenium, manganese and iron (see Table 6). The STA potable wells are no longer used for drinking water. Selenium was detected in groundwater from the USAF well in March 1991 at a concentration exceeding the Massachusetts standard. The facility switched to bottled water during the same time frame. Drinking water standards are considered protective of human health based on a consumption rate of 2 liters per day (for an adult) over a lifetime (70 years). Staff who previously drank water from the USAF well were expected to have exposures of less than 2 liters per day, 5 days per week. Manganese was detected in groundwater samples from the Civil Defense, Guest House and Deputy Commander's House wells. Iron was detected in groundwater samples from the Civil Defense and Deputy Commander's House wells. Although the manganese and iron concentrations exceed the drinking water standards, such levels commonly occur in groundwater/wetland systems regionally. The secondary drinking water standard for iron is primarily based on aesthetic (taste, odor, metal oxide laundry stains, etc) rather than health criteria. The health implications of selenium, manganese, and iron in drinking water are discussed in the Toxicological Evaluation section of this document.

Food Chain Pathway

Consumption of mercury-contaminated fish from Puffer Pond is a past completed exposure pathway at STA. Fillets from one chain pickerel contained 1.2 ppm of total mercury; the FDA action level for methylmercury is 1 ppm (60). The FDA action level is the maximum allowable level of poisonous and deleterious substances in human food and animal feed (72). Based on the concentration of mercury detected in the chain pickerel, if an adult ate one half pound of fish per week, they would ingest 272 micrograms of mercury. This exceeds the limit set by the World Health Organization of 210 micrograms of mercury per week (73).

The exposed population could be anyone eating fish from Puffer Pond. However, the actual number of people who eat fish from the pond, the amount of fish eaten and at what frequency, and the specific species eaten are not known. Further, the available fish data for Puffer Pond are incomplete. The sample size is small and not all edible fish species were sampled. Because the mercury level in a single chain pickerel exceeds the FDA action level, fishing in Puffer Pond is currently restricted to catch and release only (16,74).

Previously, anglers who fished Puffer Pond signed in at the STA gatehouse and received a permit, free-of-charge. Approximately 5 to 15 people fished Puffer Pond per week (75). Recreational use of the Annex is no longer allowed at this time. Trespassers could also fish in the pond. However, "catch and release fishing only" signs are posted along the shoreline in areas accessible to fisherman. Considering the data limitation regarding potential contamination of fish, posting is an appropriate measure to discourage anglers from eating any fish caught in Puffer Pond. Additional fish sampling is planned as part of the Phase II remedial investigation; the proposed study addresses current data gaps (5,68).

Fish sampling was also done in the Assabet River in a study unrelated to environmental investigations at the Annex. In 1985, the Massachusetts Department of Environmental Protection had five sampling stations between Maynard and Shrewbury. The highest concentration of mercury detected in fish tissue was 0.3 ppm, which is below the FDA action level of 1 ppm (98).

No other fish sampling information is available for surface waters in the vicinity of STA (Vose Pond, Cutting Pond, Willis Pond, Crystal Lake, Boons Pond, and White Pond). ATSDR reviewed environmental data regarding possible contaminant migration from STA study areas to nearby off-site surface waters (4,52). A few contaminants (bis[2-ethylhexyl]phthalate, arsenic, manganese, iron and lead) were detected in surface water and sediment from the Assabet River, Lake Boon drainage, and Willis Pond (see Environmental Contamination section). However, none of those substances are likely to biomagnify in the food chain (55,57-59,77). Biomagnification is the increase in tissue concentration of a toxic substance as it passes up through two or more trophic levels (progression of lower organisms to higher organisms in the food chain) (61).

Surface water and sediment sampling has not been done at Vose Pond, Cutting Pond, or Crystal Lake. Vose and Cutting ponds are upgradient of study areas in Watershed 1A; therefore, contaminants from STA would not migrate toward either pond. Watershed 6 drains toward Crystal Lake. Groundwater from the boundary monitoring well (BW3) between study areas within that watershed and the off-post lake did not contain any substances that would bioconcentrate in aquatic organisms.

B. Potential Exposure Pathways

Trespasser Pathway

Trespassers in areas of STA with surface soil contamination could be exposed to chemicals through incidental ingestion of soil or dust, and direct skin contact. Generally, trespassers are school-aged children or adults who dirt bike, skate board, or target shoot on STA property. Such unauthorized activity is intermittent and for short periods of time. Surface soil contamination within the installation boundary is primarily limited to isolated areas where spills occurred or drums leaked. Sampling to determine the extent of contamination at localized areas is being pursued and any drums found in those areas have been removed. Because surface soil contamination is not widespread, trespassers are not likely to come in contact with the chemicals. Even if exposure did occur, it would be limited to incidental ingestion of contaminated surface soil (in dusts or from soiled hands) or skin contact.

Probably of greater public health concern is the possibility of trespassers being injured by physical hazards in some of the study areas on STA. Areas of particular concern are A7, P22, P32, P36 and P37 where trespassing has occurred (4,18). Descriptions of physical hazards in those study areas are listed in Appendices 4 and 8.

Although STA is fenced, some of the fencing is in disrepair and trespassing has been a chronic problem. The Army has attempted to restrict access to known or potentially contaminated areas on the installation. The property boundary along Sudbury Road from the Marlboro Sudbury State Forest extending to study area A7 on Track Road was recently fenced (spring 1993). Within STA, two areas of contamination are also fenced (A7 and A9). The doorways to the abandoned buildings at P36 and P37 have either been fenced or welded shut (Appendix 8). Roads within the installation are periodically patrolled by security personnel and a guard controls access to STA via the main gate on Hudson Road (18). Community members also have the responsibility of refraining from trespassing on STA in order to avoid the potential hazards.

Lead and benzo(a)pyrene were detected in surface soil (drum confirmation sample) in study area P31, which is in the Marlboro Sudbury State Forest (4). Although the contaminant concentrations exceed comparison values (see Table 4), limited exposure to the localized spill is expected. The area is used by the public for dirt biking. If exposure occurred, it would be intermittent, for short periods of time, and limited to incidental ingestion of contaminated surface soil (in dusts or from soiled hands) or skin contact. The drum has been removed and additional sampling is planned to delineate the extent of contamination (5).

Groundwater Pathway - Off-Site Water Supply

Possible groundwater pathways at STA are off-site public wells or surface water supplies, and off-site private wells. However, the currently available data reviewed by ATSDR show that public water supplies off site have not been affected by disposal practices at STA. Further investigations planned for study areas that could affect off-site private wells are presented in this section. Each groundwater pathway is discussed separately because the various drinking water supplies and the study areas potentially affecting groundwater are geographically dispersed; groundwater flow direction varies; and potentially affected populations differ.

Public Water Supply

The drinking water supply for the towns of Maynard, Hudson and Sudbury have not been affected by contamination from STA. Groundwater monitoring is appropriate for assessing potential migration of groundwater contamination from STA toward municipal wells and White Pond (Maynard surface water source of potable water). The locations of the nearest municipal wells to STA are shown on Figure 5 (TW1 - Maynard town well No. 3; TW2 - Hudson Cranberry well; TW3 - Sudbury town well No. 3). Groundwater from two monitoring wells adjacent to Maynard well No. 3 contained bis (2-ethylhexyl) phthalate (BEHP); however, the BEHP is thought to be associated with sample handling either in the field or the laboratory. The municipal well water does not contain BEHP. Maynard well No. 3 is not used for drinking water because of taste and odor problems and will remain off-line until environmental investigations at STA are completed (43).

Private Wells

The Army has not sampled groundwater from any off-site private wells. Migration of possible groundwater contamination from STA study areas toward off-site private wells in each town is discussed here.

Maynard:
Private well locations within STA watersheds are shown on Figure 5 (RW1 - watershed 1A; RW3 - watershed 3). Residential wells on Old Puffer Road and Parker Street (RW1) are hydraulically crossgradient of STA study areas; therefore, potential on-site contaminants in groundwater are not likely to migrate toward those private wells. However, private wells on Riverside Park (RW3) are hydraulically downgradient of study area A9/P12. The private wells are about one-quarter mile from monitoring well DM9A. Groundwater sampled from that well contained explosives at concentrations exceeding comparison values. However, widespread explosives contamination in groundwater was not evident; other monitoring wells in A9/P12 did not contain those substances. Although VOCs and residual petroleum hydrocarbons have contaminated groundwater at A9/P12, the levels of those constituents in DM9A are below comparison values (4). To evaluate the potential for contaminant migration from the site toward the private wells, monitoring wells were installed between well DM9A and the downgradient private wells (5). ATSDR will review the sampling results when they are available and make public health recommendations as needed.

Hudson:
Hudson private wells are downgradient of Watershed 2 (Figure 5, RW2). Manganese and iron were detected at concentrations exceeding comparison values; however, such levels commonly occur regionally. The secondary drinking water standard for iron is primarily based on aesthetic (taste, odor, metal oxide laundry stains, etc.) rather than health criteria. The health implications of manganese and iron in drinking water are discussed in the Toxicological Evaluation section of this document.

Sudbury:
Private well locations within Watershed 6 are shown on Figure 5 (RW6 - RW8). Private wells along Maynard Road near Willis Hill (RW7) are hydraulically upgradient of any STA study areas and, therefore, would be unaffected by potential groundwater contamination from those sites. Two monitoring wells (BW3 and a proposed well at study area P2) are between study areas in Watershed 6 and off-site private wells. No contamination exceeding comparison values has been detected in groundwater from BW3. Recent sampling at study area P2 shows that past fuel and pesticide spills have not contaminated groundwater (40).

Stow:
Stow private wells on Thicket Circle, Wildwood Road and Lakewood Road are downgradient of Watershed 4 (Figure 5, RW4). Two groundwater monitoring wells between study areas A6 and P22 and the private water supplies (Figure 6) have been sampled. Metals were detected at levels above drinking water standards only in unfiltered samples from study area A6. Those metals are attributed to suspended solids and are not likely to affect downgradient drinking water wells. It does not appear that past activities at Watershed 6 study areas have contaminated groundwater (40).

Lake Boon (Boons Pond) Drainage:
Private wells on Lake Boon are downgradient of Watershed 5 (Figure 5, RW5). Homes with drinking water wells closest to STA study areas P31/P58 are in Stow on Northshore Drive, Hallocks Point, and Dawes Road (Figure 7). Monitoring wells in these study areas contain metals (arsenic, lead, manganese, aluminum and iron) at concentrations above drinking water standards. The sources of the metals are thought to be a combination of naturally occurring levels and metal debris (40). Because homes on Dawes Road are less than 500 feet hydraulically downgradient of P31/P58, there is concern that site contaminants could affect private wells.

Surface Water and Sediment Pathway

With the exception of White Pond, none of the surface waters on or adjacent to STA are used for drinking water. No contamination was detected in sediment and surface water sampled from White Pond.

Concentrations of bis(2-ethylhexyl)phthalate, endrin, and metals (arsenic, manganese, iron and lead) exceeding comparison values were detected in surface water and sediment from the Assabet River, Lake Boon drainage, and Willis and Puffer ponds. People might come in contact with the contaminated surface water or sediment while fishing, wading or swimming. However, if people are exposed to contaminated surface water or sediment via skin contact or incidental ingestion, no adverse health effects are likely to occur. The possibility of contaminants in sediment and surface water entering the food chain were previously discussed in the Food Chain Pathway section of this document.


PUBLIC HEALTH IMPLICATIONS

In this section, ATSDR discusses health effects that may result from exposures to site contaminants. Chemicals released into the environment do not always result in human exposure. People can only be exposed to a site contaminant if they breathe, eat, drink or come in contact with the contaminant.

In order to understand health effects that may be caused by a specific contaminant, it is helpful to review factors related to how the human body processes the contaminant after exposure. Those factors include the exposure concentration (how much), the duration of exposure (how long), the route of exposure (breathing, eating, drinking, or skin contact), and the multiplicity of exposure (combination of contaminants).

Health effects are also related to such characteristics as age, sex, nutritional and health status, life style, and family traits, all of which may influence how a specific chemical is absorbed (taken up by the body); metabolized (broken down by the body); and excreted (eliminated from the body).

To determine the possible health effects produced by specific chemicals, ATSDR considers physical and biological factors as well as information from scientific literature, research reports, and reports from other federal agencies.

A. Toxicological Evaluation

The following section evaluates potential health effects from contaminant exposure at STA. Health effects are related to contaminant concentration, exposure route, exposure frequency, and characteristics of the potential exposed population. Populations known or suspected of being sensitive to the contaminant are included. In some cases, not enough information is available to fully evaluate potential health effects resulting from exposure. Information will be presented primarily for completed exposure pathways at STA.

On-Site Water Supply

Selenium:
In March 1991, 30 µg/L of selenium was detected in a groundwater sample from the US Air Force well (OS2 on Figure 5). Up to that time, that well was used for drinking water at the USAF Radar facility on STA; bottled water is now used. Workers who previously drank water from the Radar facility well would have consumed less than 2 liters per day, 5 days per week. The Massachusetts Primary Drinking Water Standard for selenium is 10 µg/L. That standard is based on a consumption rate of 2 liters of water/day for an adult for a lifetime (70 years).

Workers who previously drank water from the USAF well are not expected to experience any adverse health effects. Drinking water generally contributes little to the total daily selenium intake. Most diets in North America provide approximately 150 µg of selenium per day. Even if workers had consumed 2 liters of water per day containing 30µg/L of selenium, they would have consumed only 60 µg of selenium. That concentration is 40% of the average daily dietary level of selenium. Further, in a study of a population residing in a rural Colorado community, consumption of water containing 50 to 125 µg/L caused no increase in the incidence or prevalence of any of 85 health parameters measured (76-78).

Iron:
Iron concentrations in surface water samples from P31/P58 (study areas upgradient of Boons Pond)(see Table 8) and in STA wells previously used for drinking water (see Table 6) exceeded the secondary drinking water standard (300 ppb). That standard is based on taste rather than health criteria. Assuming the standard ingestion rate of 2 liters of water per day for an adult, consumption of iron at that concentration in drinking water is 0.6 mg/day. However, it is unlikely that daily intakes between 25 - 75 mg will produce deleterious effects in healthy humans. Iron overload is a rare disorder which will occur regardless of manipulation of dietary iron intake (78).

The surface water is not used for drinking water, and exposures from incidental ingestion are not likely to cause adverse health affects. Even if the surface water was used as a drinking water source, people would have to consume between 3 and 10 times the normal daily intake of 2 liters of water to ingest potentially deleterious levels of iron. Based on the highest concentration of iron measured in surface water (3720 ppb [Table 6] or 3.7 mg/L), a person would have to drink more than 6 liters of contaminated surface water per day to ingest the equivalent of 25 mg of iron. The highest concentration of iron measured in groundwater from on-post potable wells (2640 µg/L) is below that detected in surface water (see Table 6).

Manganese:
Manganese concentrations in groundwater samples from STA monitoring wells and potable wells exceed drinking water standards (see Table 6). Groundwater samples considered to be background also exceed those standards (4). These findings suggest that manganese levels detected in groundwater are typical for the area and not necessarily site related. Groundwater from on-post potable wells also contained manganese; Civil Defense (442 µg/L), Guest House (77 µg/L) and Deputy Commander's House (109 µg/L). Using the highest manganese concentration and a daily intake rate of 2 liters of water, the exposure dose is 0.88 mg/day. That value is below the 2.5-5 mg/day amount that the Food and Nutrition Board of the National Research Council estimates is safe and adequate intake of manganese for adults. Animal studies indicate that oral exposure to manganese may lead to neurologic effects. In those studies, doses of about 980 mg/day for adults were calculated as the neurologic effect level. It was also found that the neurological effects subside when oral exposure to manganese ceased (59).

The on-post drinking water wells are currently not used. Past exposure to the manganese concentrations detected in groundwater from those wells is not expected to cause adverse health effects. Even at the highest concentration, it is unlikely that the total daily intake (food and water) for an adult would approach the neurological effect level.

It is generally considered that uptake across skin is very limited for most inorganic metal ions. Therefore, dermal exposure to water containing selenium, iron and manganese, at the concentrations measured, is not a health concern.

Fish from Puffer Pond

Although people who eat fish from Puffer Pond could be exposed to methylmercury, data are too limited to determine actual exposure levels. Exposures may have occurred in the past, but are less likely now that the pond is posted as catch and release fishing only. No information is available regarding who eats the fish, how much fish is eaten and how often, and which fish species are preferred. Furthermore, not all species of edible fish in Puffer Pond have been sampled, and of the species sampled, only a single fish (chain pickerel) contained total mercury (1.2 ppm) at a concentration slightly above the FDA action level (1 ppm methyl mercury). The actual concentration of methylmercury in the pickerel is not known. Similar total mercury levels have also been measured in predatory fish from "clean" ponds in the state.

The FDA action level of 1 ppm for methylmercury is based on economic impacts of food regulation as well as the potential human health risks on a national basis. The national per capita average fish consumption rate is 6.5 grams per day (79). However, local fish consumption rates by recreational anglers may differ from the national average.

Mercury occurs in organic and inorganic forms. The form of mercury that can build up in certain fish populations is methylmercury. Long-term exposure to either inorganic or organic mercury can result in damage to the kidneys, nervous system, and developing fetuses (65). Data are too limited to determine what, if any, adverse health effects would have occurred in persons who ate mercury-contaminated fish from Puffer Pond. Future exposures are not expected because fishing at the pond is restricted to "catch and release." Additional information regarding the toxic effects of mercury are presented in Appendix 9.

B. Health Outcome Data Evaluation

ATSDR analyzed cancer incidence data from 1982 to 1986 for the four towns surrounding STA. Those data were provided by the Community Assessment Unit of the Division of Environmental Health Assessment at the Massachusetts Department of Public Health (MDPH). ATSDR normally does not evaluate cancer rates unless a completed exposure pathway has been identified. However, at the time the data were initially evaluated, little environmental data relating groundwater contamination at STA to drinking water supplies were available. Organic solvents, some of which may cause cancer, were suspected groundwater contaminants at some study areas on STA. More recent environmental data indicate little likelihood of people contacting contaminants at STA. Even if exposures did occur, people were not being exposed to contaminants at levels that pose health concerns. Because of the limited exposures, additional health outcome data were not reviewed.

Standardized Incidence Ratios (SIRs) were calculated for each town as a whole and at the census tract level for the towns containing more than one census tract (Hudson and Sudbury). An SIR is an estimate of the occurrence of disease in a population in relation to what might be expected if the population had the same cancer experience as some larger population designated as "normal." In this case, the state population is used for comparison. Specifically, an SIR is the ratio of the observed number of cancer incident cases to the expected number of cases multiplied by 100. An SIR of 100 shows that the number of cancer cases in the population of interest is equal to the number of cases expected. An SIR greater than 100 shows that more cancer cases occurred than were expected; an SIR less than 100 shows that fewer cases occurred than expected (e.g., an SIR of 175 shows a 75 percent excess of cases over what was expected).

To determine if the observed number of cases is significantly different from the expected number or if the difference may only be due to chance, a 95 percent confidence interval is calculated. This confidence interval is a range of SIR values that has a 95 percent probability of containing the true SIR for the population. If the range does not include 100, then there is a significant difference in the number of cases from the number in the "normal" population and there is less than five percent chance that this difference is due to chance alone. If the range includes 100, then the difference is probably due to chance.

Cancer incidence in the towns of Sudbury, Hudson, and Stow occurred essentially as would be expected; there were no significant elevations observed. An elevation in cancer of the pancreas was noted in Sudbury. Cancer incidence in the town of Maynard also occurred generally as expected; however, a significant elevation was observed in liver cancer (5 cases observed/0.9 cases expected; SIR = 586; CI = 190 - 1364). Those data for each of the towns are summarized in Tables A-4 through A-7 in Appendix 5.

Census Tract Analysis

Analysis of individual census tracts 3651 and 3652 in Sudbury indicated that cancer incidences in these areas are essentially as would be expected. No cases of liver cancer were observed in census tract 3651. A significant elevation in kidney cancer was observed among males in this census tract (5 observed/ 1.2 expected; SIR = 405; CI = 131 - 945). Cancer of the pancreas was significantly elevated among males in census tract 3652 (5 observed/1.6 expected; SIR = 311; CI = 101 - 724). It is noted that one bladder cancer and two lung cancer cases were not included in the analyses due to insufficient residential information. Data are summarized in Table A-3 in Appendix 5.

Cancer incidence in census tracts 3221-3224 in Hudson generally occurred as would be expected. There were no statistically significant elevations noted. One lung cancer case was not included because of insufficient residential information. These data are summarized in Table A-4 in Appendix 5.

Smoking Status

Smoking status was examined for those cancers in which it is considered a major risk factor. These included the pancreas and kidney cancer cases in Sudbury. It did not include the cases of lung cancer in Sudbury, Hudson, and Stow because these cancers had occurred slightly less than would be expected.

Four of the male pancreatic cancer cases in Sudbury reported being a current or former smoker at the time of diagnosis. Smoking status was not known for one case and the other case reported having never been a smoker. Neither of the two female pancreatic cancer cases had ever smoked. Three of the seven male kidney cancer cases in Sudbury were current or former smokers. There were no cases of kidney cancer observed in females in Sudbury.

About 83% (n=19) of the male lung cancer cases in Maynard reported being current or former smokers. The smoking status of three of the male cases was unknown. About 78% (n=7) of the female lung cancer cases in Maynard were current or former smokers. The remaining two had never smoked.

This analysis of the cancer incidence data around STA does not indicate any pattern of occurrence that is of increased public health concern at the present time. There were no consistent elevations in all 4 towns. Maynard had a significant elevation in liver cancer (5 cases observed/0.9 expected). One area of Sudbury had a significant elevation in kidney cancer among males. A different area in Sudbury had an elevation of pancreatic cancer among males. There is no consistent pattern of any cancer occurring in both sexes that would suggest an environmental factor is playing a role. With rare occurrences such as liver cancer, small numbers make analysis difficult because the rates tend to fluctuate a great deal.

Cancer Mortality Data

Cancer mortality data were provided from the MDPH for the years 1987-1988. There were 68 deaths due to cancer in the towns of Hudson, Stow, Maynard, and Sudbury during that two year period. Lung cancer accounted for 53% of those cancer deaths. Cancers of the digestive system accounted for the next highest number of deaths. Cancers of the lung and digestive system are typically the two leading causes of cancer death.

Special Education

The community has expressed a concern that there are excess numbers of special needs children in the area. To look at this concern, information was obtained from the Massachusetts Department of Education Summary report for 1989-1990 and from the superintendents at the school districts in the area. It was not possible to obtain information on the specific type of special need child at the neighborhood level. A summary of this information is included in Table 10 (see Appendix 2). These figures represent the total number of special needs students in the area. "Special needs" includes the following: mentally disabled, hearing impaired, deaf, speech impaired, visually impaired, emotionally disturbed, orthopedically impaired, other health impaired, specific learning disabled, deaf and blind, and multihandicapped. Because each of these categories have different causes, they cannot be grouped together for the purpose of studying those causes. The number includes those students who do not live in the area but are enrolled in the special education programs in the districts.

The Massachusetts Department of Education issued the 766 Regulations in September of 1986 that deals with the special education programs in the state. In these regulations a "child in need of special education" is defined as "a child who has been determined by the Administrator of Special Education (or his/her designee) to need special education in accordance with the provisions of 322.2, or has been referred to a program described in 502.7 (home or hospital program) (80). Such determination of referral must be based upon a finding that a child, because of temporary or more permanent adjustment difficulties or attributes arising from intellectual, sensory, emotional or physical factors, cerebral dysfunctions, perceptual factors, or other specific learning impairments, or any combination thereof, is unable to progress effectively in a regular education program and requires special education. Children of ages three and four shall qualify as children in need of special education if they have a substantial disability in one or more of the areas listed above. Substantial disability for children three and four years of age is defined as any condition which would interfere with that child's educational growth and development and deter that child's ability to progress effectively in a regular elementary school classroom when he/she attains school age" (80).

The Hudson, Sudbury, Maynard, and Stow school districts provided information on the number of students enrolled in the district and the number of special education students. That information is contained in Tables 11 through 14.

Using the information provided by the school districts, the average percentage of children in these four towns receiving special education services in 1990 is between 13% and 20%. Four Town FOCUS provided information on the number of children in the Boons Pond area who had ever received special education services. When they compared this number to the 381 people under the age of 18 who lived in the Boons Ponds area in 1990, FOCUS estimated that 18% were special needs students. Even though FOCUS compared time periods of different lengths, the 18% rate for the Boons Pond area is still consistent with the rates in Massachusetts (17% of children received special education services in the 1990 school year) (81). Because the category of special needs children is large and encompasses such a broad range of needs, it is impossible to actually compare these figures. The definition of a special needs child in Massachusetts is significantly different from that in federal law P.L. 94-142 governing special education. In Massachusetts there is no categorical programming, all children receiving services are referred to as having a special need. It is also not possible to relate this broad, general information to any specific exposure.

C. Community Health Concerns Evaluation

ATSDR staff members have addressed the following community health concerns relating to STA:

1. Community members are concerned that analysis of samples from STA has not included all compounds that were previously used at the facility (such as explosives and chemical agents).

The methods used in the Remedial Investigation, Site Investigation report (4), Phase II Feasibility Studies (5)(6) and Phase II Site Investigation (40) are appropriate for characterizing contamination at STA. Environmental samples were analyzed for specific chemicals (or known breakdown products) suspected to have been used in the study areas being investigated. In study areas where contaminants have been detected, additional sampling is planned to characterize the extent of contamination. Please see the Quality Assurance and Quality Control section of this document for a discussion of specific analytical limitations.

2. Many community members who live around Boon Pond (also called Lake Boon) are concerned about the effects of the eutrophication of the pond on their health. They are also concerned that explosives, particularly RDX, from the installation may be contributing to the eutrophication of Lake Boon.

Eutrophication is the slow aging process during which a lake evolves into a bog or marsh and eventually disappears. Eutrophication refers to natural or artificial addition of nutrients to bodies of water and to the effects of added nutrients (54). The two nutrients that act as limiting, or critical, factors for eutrophication are phosphorus and nitrogen. Important sources of nitrogen and phosphorus are domestic sewage, urban runoff, and agricultural runoff (82).

There is little information available on the health effects from recreational use of eutrophic water bodies. Studies examining health effects in populations having contact with sewage-contaminated water have reported a significant increase in symptoms such as vomiting, diarrhea, itchy skin, fever, lack of energy, and loss of appetite after the contact (83). These types of symptoms are very common in the general population and often are caused by infectious organisms.

Four Town FOCUS (FTF) and the Lake Boon Association have been sampling the pond for phosphorus and nitrogen. They reported that the levels of phosphorus in the lake have been rising and the levels of nitrogen have been stable (84).

It is not likely that explosives-containing wastes on the installation are affecting the eutrophication of Lake Boon. Although nitrogen is contained in practically all explosives (e.g., RDX, TNT, nitroglycerin) (85), phosphorus is not a common constituent of explosives. White Phosphorus is one munition which does contain phosphorus. White phosphorus was reportedly one of the explosives disposed of in study area A6 (demolition ground II) (71). In 1984, 500 ppm of total phosphorus was detected in a surface soil sample from the demolition ground (63). The average concentration of phosphorus in the soil in Massachusetts is 2,400 ppm (86). Additional surface soil samples were collected in the area during the spring of 1992 (4). Orthophosphate, which is the only form of phosphorus available as a nutrient to aquatic plants, was detected at a maximum concentration of 1.7 ppm. Study area A6 drains into the Assabet River downstream from Lake Boon and, therefore, is not likely contributing any phosphorus to Lake Boon.

Data regarding phosphorus and explosives levels measured in environmental samples from study areas within the watershed drainage to Lake Boon (see Table 5 and Figure 7) were also reviewed. The only monitoring well that contained either contaminant in groundwater was OHM-BW-4. Samples were collected in June and October 1992. Phosphate concentrations were 40 ppb and 15 ppb for those sampling dates. Although the unconfirmed explosives 4-nitrotoluene (3.8 ppb) and cyclonite (5.5 ppb) were measured in June, neither was present in subsequent sampling (4). Previously measured total phosphorus concentrations in groundwater from generally the same area were within the range expected to be naturally occurring (49).

RDX, the particular explosive about which the community expressed concern does not contain phosphorus (Figure 9). Studies at Army Ammunition Plants have shown that nitrate and sulfate levels are the water quality parameters that increase in concentration downstream of the plants (87)(88). Based on the above information, it is not likely that any explosives or phosphate-containing substances on the installation would greatly affect the phosphorus levels in Lake Boon.

The shores of the lake are lined with homes. The lake was always a popular seasonal resort. However, watershed development has changed from seasonal housing to year-round housing. The population within the Boons Pond watershed relies on septic tanks with leachfields or cesspools to dispose of household wastes. Many of the soils within the watershed have properties which limit the effectiveness of these systems for wastewater disposal (54). Therefore, development along the pond's shoreline is potentially a direct cause of the eutrophication.

3. Community members are concerned about potential contamination of area water supplies by past disposal practices at STA. Their specific concerns are:

a. The water in private wells in Stow and Hudson has not been tested for contaminants that were disposed of on STA.

Phase II sampling has been done for study areas on STA that potentially could contaminate groundwater used for drinking water in Stow and Hudson. Previous studies had not shown widespread contamination. Additional monitoring wells were installed between STA study areas and downgradient off-site private wells in Stow and Hudson. ATSDR reviewed phase II groundwater data (40) and recommended that the Army sample private wells on Dawes Road in Stow. ATSDR will review the private well data when it is available. Additionally, phase II sampling results for A9/P12 will be reviewed to determine if further off-post sampling is needed. Please see Appendix 10 and the Environmental Contamination and Pathways sections of this document for more detailed discussions.

b. The Maynard water line from White Pond to Summer Hill crosses STA. Breaks in the line could contaminate the water supply.

The Maynard Board of Selectmen state that the Maynard water transmission line is not located in areas of known contamination. The transmission line is under pressure, and lines under pressure will leak out and not in. The water distribution line is located approximately four feet below the ground surface, and at least four feet above the groundwater surface (44).

When breaks in the water main occur, repairs are made and the pipe is flushed to prevent contaminants from entering the distribution system. Water is sampled at the distribution point after repairs are completed (24).

4. There is concern that area ponds -- on or near the Annex -- could be contaminated by chemicals that were dumped at the Annex. If contamination of surface water and sediment occurred, would edible fish be contaminated as well?

To determine whether or not past disposal activities at STA have contaminated surface water, sampling has been done in Puffer Pond, on-site streams, White and Willis ponds, the Assabet River, and drainage to Lake Boon. Fish sampling has also been done in Puffer Pond. A summary of those studies are presented here with more detailed information available in the Environmental Contamination and Pathway Analyses sections of this document.

Surface water and sediment from Puffer Pond contain pesticides and metals. Fish tissue also contained pesticides and metals; however, with the exception of mercury in a single chain pickerel, none of the contaminants detected were at levels of health concern. Based on the results of the fish studies, the Army posted Puffer Pond for "catch and release fishing only". Because of data limitations in previous Puffer Pond studies, additional surface water, sediment and fish sampling is planned.

A few substances (metals and a semivolatile organic compound) were detected in surface water and sediment from the Assabet River, Lake Boon drainage, and Willis Pond. Those chemicals are not necessarily attributed to past disposal practices at STA nor are the substances likely to increase in tissue concentration as they pass through the food chain (from lower organisms to higher organisms). However, additional sampling at surface water outfalls from STA is planned to further evaluate whether or not contaminants could migrate toward off-post water bodies.

 

5. Community members are concerned that the public has access to potentially contaminated areas at STA. Specific concerns are:

a. Public access to contaminated areas on STA is NOT effectively controlled.

The Army has taken several measures to limit access to contaminated areas on STA. Fencing has been improved along the western property boundary where trespassers previously gained access to STA. On-site study areas A7, A9 and P36 are fenced. Entrances to abandoned buildings where trespassing has been a problem have been welded shut (study areas P36 and P37). Puffer Pond has been posted as catch and release fishing only because mercury was detected in a chain pickerel at a concentration exceeding FDAs action level.

There are still some portions of the perimeter fence surrounding STA that are in disrepair. Security personnel have attempted to keep trespassers off the installation by controlling access at the main gate and by patrolling installation roads. Concrete barriers or cables have been placed across other roads leading to STA.

The Army has taken appropriate actions to limit public access to STA. Although surface soil contamination at STA is not widespread, localized chemical contamination exists in some areas. Disposal areas and abandoned structures also contain physical hazards. Persons who continue to use STA for unauthorized activities could be exposed to chemical contaminants in surface soil or be injured by physical hazards.

b. There is particular concern about A7, an area of contamination that was fenced in October 1991. Prior to that time, children rode dirt bikes in the area. Citizens were alarmed when environmental sampling at A7 was done by remedial workers, who were wearing "moon suits."

Persons who rode dirt bikes in A7 could have been exposed to surface soil contamination and possibly injury by physical hazards. However, the extent of chemical contamination in surface soil is not widespread. There are few locations where levels of pesticides, polychlorinated biphenyls or polyaromatic hydrocarbons in surface soil exceed comparison values (see Table 4). Those isolated areas of surface soil contamination are underneath drums or where there had been a localized fuel spill (4). It is not very likely that persons who used the area for dirt biking in the past would have come in contact with the few areas containing surface soil contamination. Even if exposure did occur, it would be limited to skin contact with or incidental ingestion of contaminated surface soil (in dusts or from soiled hands). Such exposures are not expected to cause illness.

Remediation workers who collected environmental samples from study area A7 were required to wear level B personal protective equipment ("moon suits") because of the potential hazard associated with their work (possible day-to-day exposure to a variety of environmental hazards from many different sites). Use of personal protective equipment (PPE) is required by Occupational Safety and Health Administration (OSHA) regulations and reinforced by U.S. Environmental Protection Agency (EPA) regulations for all private contractors working on Superfund sites (89). The level of protection used is based on the general types of hazards to which workers may be exposed during site activities. Site Safety Plans, which establish policies and procedures to protect workers and the public from the potential hazards posed by a hazardous waste site, must be developed before site activities proceed. As more information about the nature and extent of site contamination is available, the level of protection required may be upgraded or downgraded as needed.

At STA, the level of PPE anticipated for specific work tasks is outlined in the site-specific Health and Safety Plan (90). Workers excavating test pits during site investigation/remedial investigation activities are required to wear level B protection. Because test pits were excavated at study area A7, remedial workers wore level B protection. Level B protection includes hooded tyvek coveralls and Sarans, double gloves, a full-face air-supplied respirator, a hard hat, and steel-toed work boots with overboots. Such PPE is assumed to be what community members described as "moon suits." The use of "moon suits" does not necessarily mean that a site is extremely hazardous; rather, their use is merely a required precautionary measure to protect workers from possible unknown hazards encountered during field investigations.

Public access to A7 was restricted before the test pits were excavated. The study area was fenced in October 1991 and the initial excavation of test pits began on December 4, 1991.

c. Community members are also concerned that portions of STA that were turned over to the state, and are now used as recreation areas, may be contaminated. The specific study areas identified were P7, P17, P31, P43A and P43B (see Figure 2 for site locations).

ATDSR reviewed environmental data pertaining to the study areas on excessed STA land (4). Study area P7 could have been used as a miscellaneous waste chemical disposal area between 1940 and the 1950s. Currently the area is mostly overgrown with vegetation and only a few small areas are cleared. Although surface soil was not sampled, the concentration of contaminants detected in test pit soils and groundwater samples were within background ranges or did not exceed comparison values (4).

Study area P17, which is now part of the Marlboro Sudbury State Forest, was used for burial of contaminated cloth in 1960s. No record of what contaminant was used on the cloth could be found. Additional materials (clothing and combat gear) were also buried at the site in the 1970s (see Appendix 4 for more information). One drum was also found at the study area. Analysis of soil samples from burial areas indicate little or no contamination. The only exception is the drum confirmation sample which contained 220 ppm of arsenic. The drum may have contained an arsenic-based herbicide (4). Potential exposure to the arsenic-contaminated soil is not likely considering limited land use in the area. Additional surface soil samples will be collected at the former drum location to identify the extent of contamination (4).

Study area P31 is part of the Marlboro Sudbury State Forest and is used by the public for dirt biking. Limited quantities of household refuse and building material were found dumped in the area. Surface soil was not sampled. Geophysical surveys were done to identify burial sites; a variety of buried debris was found with test pits were excavated (4). Groundwater monitoring at the site is planned (5). There is no indication of widespread surface soil contamination at P31.

Study areas P43A and P43B are in the woods behind the Green Meadow Elementary School. The "areas of stressed vegetation" were initially identified by EPA in 1981 from aerial photographs (high resolution infrared images) (4). However, results of subsequent investigations do not indicate that past disposal of chemicals occurred at either study areas (4). ATSDR staff members walked trails and dirt roads in the wooded area in October 1992 and saw discarded beverage containers, miscellaneous trash, and remnants of campfires.

6. A community member was concerned that a cobalt 60 source was brought to STA and stored in a bunker.

An August 6, 1958 memo regarding Allocation of Igloos at Maynard Quartermaster Test Activity proposed that a cobalt source could be placed in an existing igloo at the Maynard Test area (101). Historical information about the use of cobalt 60 (Co-60) by the U.S. Army Natick Research and Development Command (NARADCOM) is presented in November 1977 (91, 104) and May 1980 (92) reports. Those reports include information about NARADCOM activities at both STA and Natick Laboratories. Neither of the reports indicate that a Co-60 source, or any other radiation source, were ever used on STA. However, the Radiation Laboratory, Building 16 at Natick Laboratories, was used by the Food Engineering Laboratory for research and development of processes for the preservation of food by use of ionizing radiation. The radiation sources, a 1.2 megacurie Co-60 source and a 24 Mev electron linear accelerator, were housed behind heavy concrete enclosures to the north of the main building.

Cobalt 60 is a gamma radiation source that has a 5 year half life. Because high activity gamma radiation sources require specially designed storage facilities, it is unlikely that this amount of Co-60 was ever stored in a bunker on STA (93). As part of the remedial investigation, an inventory, inspection and radiological survey of STA bunkers was done (94)(4). A Co-60 source was not found.

All radiological items used by NARADCOM are under Department of the Army license or permits. Radiological wastes are disposed of by approved contractors (91, 104). Moreover, any objects that might have been irradiated with Co-60, such as food, would not contain any residual radiologic contamination.

7. The citizens expressed concern that the Boon Pond area has more children receiving special education than the other areas in the towns or the state.

The information provided on the towns around STA does not suggest an increase over other areas of the state. Please see the Health Outcome Data Evaluation section for more discussion.

8. Community members around the Boon Pond area report a variety of physical symptoms such as frequent nosebleeds, rashes, allergies, and possible seizures (episodes with a loss of motor control and amnesia for the event).

There is no information at present that indicates exposure to contamination from STA in the Boons Pond area. There are no health databases with good information on these types of problems with which to compare the occurrence in the Boon Pond area. It is difficult to evaluate the cause of the rashes described. Community members did not describe the blistering commonly associated with contact dermatitis or the features of chloracne (comedones, cysts). Without an exposure or a definitive description it is not possible to link these symptoms to contamination from the installation. The community-specific health outcome data do not support the conclusion that this site has had an adverse impact on human health at this time.

Additional community concerns received in response to the public comment period for the December 1993 Public Health Assessment are presented in Appendix 11.


CONCLUSIONS

  1. Fort Devens Sudbury Training Annex (STA) is classified as ATSDR's category of no apparent public health hazard. Few exposures have been identified, and those do not exceed health comparison values. Available environmental data are adequate for evaluating possible exposures.
  2. STA study areas A9/P12 and P31/P58 are classified as indeterminate public health hazards because limited groundwater data are currently available. Groundwater is contaminated at those study areas and additional sampling is underway to determine if site contaminants could affect downgradient private wells.

  3. On-post surface soil contamination is generally limited to areas where localized spills occurred or drums leaked. Because trespassers on STA would be exposed only intermittently to contaminated surface soil, if at all, exposures are not likely to result in adverse health effects. Physical hazards, however, are of public health concern. The Army has attempted to restrict access to STA. The installation is patrolled, a guard controls access through the main gate, and fencing has been improved along portions of the post boundary and in study areas where entry by trespassers has occurred. The Army also blocked entrances to buildings T104 and T106 where school-aged children have chronically trespassed. Community members have the responsibility of refraining from trespassing on STA.
  4. Little surface soil contamination has been detected in off-post study areas where public access is unrestricted. Environmental contamination screening has been appropriate considering the types of historical activities that occurred in those areas. The off-post areas are used intermittently by the public. Any exposure to the few areas with localized surface soil contamination that have been identified would be limited to short term skin contact or incidental ingestion. Such exposures are not likely to cause illness. Additional sampling to delineate the extent of surface soil contamination around the specific points of contamination previously identified is planned.

  5. Data are limited regarding potential contamination of edible fish species in Puffer Pond. The posting of the pond as catch and release fishing only is appropriate because:

    • mercury levels in edible portions of a chain pickerel exceed FDA's action level,
    • metals and pesticides were also detected in other fish species (i.e., black crappie and brown bullheads), although at levels below health concern, and
    • not all edible fish species were sampled.

    To address data gaps identified in previous fish studies, additional sediment, surface water and fish sampling is planned for Puffer Pond and Minister's Pond (an off-site pond to be used for comparison purposes).

    Generally, previous sampling has not demonstrated that contaminants from STA study areas have migrated to other surface waters surrounding the post. The only exception is Marlboro Brook, where further investigation is planned to identify possible site-related sources of contamination. The few contaminants detected in off-site surface water bodies are not necessarily attributed to past disposal practices at STA. Those contaminants that were detected are not expected to biomagnify in the food chain.

  6. Health outcome data for communities around STA do not indicate any significant elevation in selected adverse outcomes that may be linked to an environmental exposure. Further, environmental data suggests little likelihood of people contacting site contaminants.

RECOMMENDATIONS

The Army either has implemented or is addressing all previous ATSDR recommendations. Those recommendations were made in the initial release public health assessment, in the health consultation for STA, discussed during installation site visits or in correspondence requesting additional sampling.

  1. Sample private drinking water wells on Dawes Road in Stow. The private wells are within 500 feet hydraulically downgradient of study areas P31/P58 where groundwater contains metals at concentrations above drinking water standards.
  2. Determine the need for future sampling of off-site private wells once results from proposed groundwater monitoring studies for study areas A9/P12 are available.

  3. Continue institutional controls restricting access to STA because some study areas contain localized surface soil contamination and physical hazards. Community members should refrain from trespassing on STA.

  4. Consider further measures to prevent access to abandoned buildings T104 and T106. The Army has blocked building entrances with welded bars or chain-linked fence; however, as the buildings deteriorate, access may again be possible. Trespassing chronically occurs around T104 and T106; the buildings are less than one-half mile from off-post residences.

  5. Continue the current posting of Puffer Pond as "catch and release" fishing only.

Health Activities Recommendation Panel (HARP) Recommendations

The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, as amended, requires ATSDR to perform public health actions needed at hazardous waste sites. To determine if public health actions are needed, ATSDR's Health Activities Recommendation Panel (HARP) has evaluated the data and information in the Fort Devens Sudbury Training Annex Public Health Assessment. Although the information available does not indicate that humans are being or have been exposed to levels of contamination that would be expected to cause illness or injury, there are many community health concerns. Therefore, the panel determined that education of health professionals was appropriate. An ATSDR staff member participated in the Massachusetts Department of Public Health Grand Rounds professional health education series. No additional health followup activities are indicated at this time.


PUBLIC HEALTH ACTION PLAN

The public health action plan for the Fort Devens Sudbury Training Annex (STA) National Priorities List site contains a description of actions to be taken by ATSDR and/or other government agencies at and in the vicinity of the site upon completion of this public health assessment. The purpose of the public health action plan is to ensure that this public health assessment not only identifies public health hazards, but provides a plan of action designed to mitigate and prevent adverse human health effects resulting form exposure to hazardous substances in the environment. The plan includes a commitment on the part of ATSDR to follow up to ensure that the plan is implemented. The public health actions to be implemented are as follows:

Actions Completed

An ATSDR staff member trained health professionals in the Massachusetts Department of Public Health Grand Rounds professional health education series on February 18, 1992.

ATSDR conducted a public availability session (PAS) in Sudbury, Massachusetts on October 6, 1992 to gather community health concerns regarding STA.

An ATSDR health consultation recommended that the Army restrict access to abandoned buildings T104 and T106 where school-aged children trespassed (see Appendix 8). The buildings contained asbestos and many physical hazards. The Army has blocked entrances to those buildings with welded bars or chain-linked fence.

ATSDR held a public meeting in Maynard, Massachusetts on January 20, 1994 to discuss the Fort Devens Sudbury Training Annex Public Health Assessment with interested community members.

ATSDR sent a letter to the Army on April 22, 1994 recommending private well sampling on Dawes Road in Stow (see Appendix 10).

Actions Planned

The Army is coordinating private well sampling on Dawes Road with EPA and the Massachusetts Department of Environmental Protection. ATSDR will review private well data and recommend followup public health actions as needed.

In coordination with EPA and Massachusetts Department of Environmental Protection, the Army is further evaluating the nature and extent of contamination at STA. Specific plans are described in the Phase II Investigation Reports and No Further Action Documents for STA study areas (5,6,40,97,102,103).

ATSDR will evaluate relevant new environmental, toxicologic, or health outcome data to determine the need for additional public health actions at Fort Devens Sudbury Training Annex.


PREPARERS OF REPORT

Lorna Bozeman, M.S.
Environmental Health Scientist
Federal Programs Branch
Division of Health Assessment and Consultation

Richard Collins, M.S.E.H., R.S.
Environmental Health Scientist
Federal Programs Branch
Division of Health Assessment and Consultation

Emilio Gonzalez, B.S.
Environmental Engineer
Federal Programs Branch
Division of Health Assessment and Consultation

Virginia Lee, M.D., M.P.H.
Medical Officer
Federal Programs Branch
Division of Health Assessment and Consultation

Reviewers of Report:

Gary Campbell, Ph.D.
Chief, Army Unit
Federal Programs Branch
Division of Health Assessment and Consultation

John E. Abraham, Ph.D., M.P.H.
Chief, Defense Facility Assessment Section
Federal Programs Branch
Division of Health Assessment and Consultation

Heather Tosteson, Ph.D.
Writer
Program Evaluation, Records & Information Services Branch
Division of Health Assessment and Consultation

ATSDR Regional Representative:

Louise A. House
Senior Regional Representative
ATSDR Region I, Lexington, MA


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  93. ATSDR. Personnel Communication: Lorna Bozeman, ATSDR, with Paul Charp, Health Physicist, ATSDR. March 18, 1993.

  94. OHM Corporation. Work Plan. Fort Devens Sudbury Training Annex, Massachusetts. April 1992.

  95. Smith, RL. EPA Region III - Risk-Based Concentration Spreadsheet. April 14, 1992.

  96. Fort Devens Sudbury Training Annex. Technical Review Committee Meeting Minutes. July 31, 1991.

  97. OHM Remediation Services Corporation. Draft Decision Documents, No Further Action Under Comprehensive Environmental Response, Compensation, and Liability Act for Study Areas P15, P29, P30, P44A and P44B, P46, P47, P53, and P55. October and December 1993.

  98. Maietta RJ. Assabet River Fish Toxics Screening Survey. 1986.

  99. Memorandum to Arthur Johnson, Biomonitoring Program Manager, DWPC/TSS, Grafton from Robert J. Maietta, Aquatic Biologist, DWPC/TSS, Grafton concerning Patch Reservoir Fish Toxics Monitoring. December 26, 1991.

  100. ATSDR. Personal communication: Lorna Bozeman, ATSDR, with Robert Lim, EPA. June 16, 1994.

  101. U.S. Army Quartermaster Research and Engineering Center, Natick, MA. Allocation of Igloos at Maynard Quartermaster Test Activity, Maynard, MA. August 6, 1958.

  102. OHM Remediation Services Corporation. Draft Decision Documents, No Further Action Under Comprehensive Environmental Response, Compensation, and Liability Act for Study Areas P14, P18, P21, P24, P32, P34 and P50. December 1993 and May 1994.

  103. Ecology and Environment, Inc. Draft No Further Action Discussion Documents for Study Areas A6, P26, P40, P42, P43A/B, P48, P56 and P57. June 1994.

  104. Ecology and Environment, Inc. Draft Master Environmental Plan Fort Devens Sudbury Training Annex Site. May 1994.


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