EPA CEASE FIRE ORDER Part 3

[Aimee Houghton <aimeeh@igc.org>]

 SCOPE OF WORK
 MASSACHUSETTS MILITARY RESERVATION

 TRAINING RANGE AND IMPACT AREA

 Appendix A to EPA Region I Administrative Order
 SDWA I-97-1030
 RCRA I-97-1031

I. INTRODUCTION AND PURPOSE

 This Scope of Work (SOW) defines the response actions and 
obligations that Respondents are obligated to perform to implement the 
Work required under the Administrative Order, Docket Numbers SDWA 
I-97-1030, RCRA I-97-1031 (the "Order"), issued by the United States 
Environmental Protection Agency (EPA) regarding the Training Range and 
Impact Area at Massachusetts Military Reservation (MMR) on Cape Cod, 
Massachusetts.

II. RESPONSE ACTIVITIES

 Respondents shall perform the following Work:

 A. Respondents shall implement the following pollution 
prevention measures at or near the Training Range and Impact Area:
 1. During the performance of the study of the Training 
Range and Impact Area being performed by the National Guard Bureau 
pursuant to the February 27, 1997 Order, and following completion of 
such study until EPA approves in writing the resumption of activities, 
except as provided in Section XXXIV of the Order, Modification of the 
SOW, Respondents shall suspend the following activities: 
 a. All firing of lead ammunition or other 
"live" ammunition at small arms ranges at or near the Training Range and 
Impact Area;
 b. All artillery firing using high explosives 
at or near the Training Range and Impact Area;
 c. All mortar firing using high explosives at 
or near the Training Range and Impact Area;
 d. All planned demolition of ordnance or 
explosives at or near the Training Range and Impact Area, except for 
unexploded ordnance (UXO) clearance activities;
 e. All use of artillery and mortar propellants 
in non-live firing of munitions at or near the Training Range and Impact 
Area; 
 f. All use of pyrotechnics at or near the 
Training Range and Impact Area;
 g. All burning of propellant or propellant bags 
at or near the Training Range and Impact Area.

 B. Within 30 days of the effective date of this Order, 
Respondents shall cover all berms in and near the Training Range and 
Impact Area in which expended small arms munitions have come to be 
located with flexible membrane liners of water-impermeable material 
approved by EPA. Such flexible membrane liners shall remain in place 
until Respondents remove lead from the berms pursuant to this Order and 
SOW, and receive EPA approval of completion of the lead removal; 
however, Respondents may temporarily remove the flexible membrane liners 
while the small arms ranges are actively being used for the firing of 
non-live ammunition.

 C. Respondents shall remove lead munitions from all berms at 
all small arms ranges in the Training Range and Impact Area.
 1. Within 30 days of the effective date of this Order, 
Respondents shall provide to EPA's Technical Project Coordinator and 
make available to the public a schedule and work plan with specific 
dates for removing lead munitions from soils in the berms at all small 
arms ranges on or near the Training Range and Impact Area. Such 
schedule and work plan shall include the following:
 a. A project objective of removing the maximum 
amount of lead munitions from the soil;
 b. Any necessary bench or field testing;
 c. A schedule for initiation and completion of 
lead munitions removal activities;
 d. Recycling the removed lead munitions, as 
appropriate; 
 e. Use of soil modifiers to minimize 
prospective bullet corrosion and lead migration; and
 f. Coordination between lead munitions removal 
activities, and the installation and use of flexible membrane liners on 
all berms, as required above in Section II.B. of this SOW.

 2. Within 15 days of receiving EPA's approval or 
modification of the schedule and work plan described above in Section 
II.C.1. of this SOW, Respondent shall initiate performance of all 
activities in the work plan as approved or modified.

 D. Respondents shall initiate and complete periodic "sweeps" of 
portions of the Training Range and Impact Area with the objective of 
clearance of UXO to reduce the potential for UXO to deteriorate or leak 
into the environment.
 1. Within 30 days of the effective date of this Order, 
Respondents shall provide to EPA's Technical Project Coordinator and 
make available to the public a schedule and work plan with specific 
dates for periodic UXO clearance "sweeps".

 2. After receiving EPA's approval or modification of 
the schedule and work plan described above in Section II.D.1. of this 
SOW, Respondent shall initiate performance of periodic UXO clearance 
"sweeps".

 E. If, following completion of the study required by EPA's 
February 27, 1997 Order, and any actions resulting from that study, or 
pursuant to Section XXXIV of the Order, EPA approves resumption of 
Respondents' activities at the Training Range and Impact Area, 
Respondents shall ensure maximum feasible use at such time of pollution 
prevention technologies in any training activities. Specific measures 
to be evaluated by Respondents include the following:
 1. Use of non-toxic lead-free combat ammunition;
 2. Use of bullet traps at all small arms ranges;
 3. Use of munitions-capturing material, such as 
"Sacon"; 4. Use of non-exploding artillery and mortar rounds; and
 5. Development of guidances for the operation and 
maintenance of the ranges consistent with the pollution prevention 
strategies.

 F. If, following completion of the study required by EPA's 
February 27, 1997 Order, and any actions resulting from that study, or 
pursuant to Section XXXIV of the Order, EPA approves resumption of 
Respondents' activities at the Training Range and Impact Area, 
Respondents shall provide for monitoring of air emissions, as 
appropriate, from any activities undertaken in and near the Training 
Range and Impact Area.
 1. Prior to initiating any activities which may 
generate air emissions, Respondents shall provide to EPA's Technical 
Project Coordinator and make available to the public a schedule and work 
plan with specific dates for monitoring air emissions from Respondents' 
activities.

 2. After receiving EPA's approval or modification of 
the schedule and work plan described above in Section II.F.1. of this 
SOW, Respondent shall initiate performance of air emissions monitoring 
in the work plan as approved or modified.

 G. In addition to any other requirement of this Order and SOW, 
during the period in which Respondents are performing response 
activities pursuant to the Order, Respondents shall submit to EPA and 
make available to the public written monthly progress reports that: (1) 
describe the actions which have been taken toward achieving compliance 
with this Order during the previous month; (2) include a summary of all 
results of sampling and tests and all other data received or generated 
by Respondents or its contractors or agents in the previous month; (3) 
identify all work plans, reports and other deliverables required by the 
Order that were completed and submitted during the previous month; (4) 
describe all actions scheduled for the next six weeks and provide other 
information relating to the progress of Work under the Order; include 
information regarding percentage of completion, unresolved delays 
encountered or anticipated that may affect the future schedule for 
implementation of the Work, and a description of efforts made to 
mitigate those delays or anticipated delays. Respondents shall submit 
these progress reports to EPA by the tenth day of every month following 
the effective date of the Order. These progress reports will also 
include description of progress made in ensuring future use of pollution 
prevention technologies as specified in Section II.E above. If 
requested by EPA, Respondents shall also provide briefings for EPA to 
discuss the progress of the Work.

 H. For the activities described above in this SOW, Respondents 
shall provide EPA with a description of health and safety measures to be 
undertaken by Respondents in performance of the Work under this Order, 
including all plans, training and other health and safety measures 
necessary.

 I. Within 45 days after Respondents conclude that they have 
completed all response activities under the Order, Respondents shall 
submit to EPA and make available to the public a report (the "Completion 
of Work Report") describing in detail the Work undertaken under the 
Order and the results of the Work.

 J. EPA shall review the Completion of Work Report. If EPA 
determines that no further Work is necessary under the Order, EPA will 
so notify Respondents. If EPA determines that further Work is necessary 
under the Order, EPA will notify Respondents of such Work, and will 
either provide a schedule for completion of such Work, or will direct 
Respondents to submit within a specified time period a schedule for 
completion of such Work. 

III. SUBMISSIONS REQUIRING AGENCY APPROVAL

 Plans, reports, and other deliverables identified in this SOW, 
or identified in EPA's approval or modification of any schedule and work 
plan to be submitted pursuant to this SOW, shall be delivered to EPA in 
accordance with the Order and this SOW. 

IV. PUBLIC INVOLVEMENT

 Respondents shall ensure adequate public involvement in all the 
Work undertaken pursuant to the Order and SOW. Within 30 days after the 
effective date of this Order, Respondents shall submit to EPA and make 
available to the public a plan, or, at their option, submit an amendment 
to the plan required by the February 27, 1997 Order for ensuring 
adequate public involvement, including but not limited to the following:

 A. Making immediately available to the public all 
nonprivileged information obtained or compiled pursuant to this Order;

 B. Coordinating the Work under this Order and SOW with the 
citizens advisory committee to be established by EPA to oversee and 
monitor the Work, and providing resources for the effective functioning 
of the citizens advisory committee;

 C. Providing periodic oral and written updates to the 
public on the progress of the Work;

 D. Sharing immediately with the public all conclusions 
reached by Respondent or its representatives with respect to the effects 
of past and present activities at the Training Range and Impact Area; 
and

 E. Coordinating the Work under this Order and SOW with the 
response actions being undertaken at MMR by the Installation Restoration 
Program, and with the study of the Training Range and Impact Area being 
conducted pursuant to the February 27, 1997 order.