Impact Area Review Team

River River Drops of rain on a leaf

Impact Area Review Team
Bourne Bridge Best Western
Bourne, Massachusetts
April 5, 2000
6:00 p.m.

Meeting Minutes





Ben Gregson



LTC Joe Knott



LTC Bill Fitzpatrick



CPT William Myer



Bill Walsh-Rogalski



Margery Adams



Todd Borci



Jane Dolan



Len Pinaud



Jan Drake



Marty Aker



Kent Gonser



Marc Grant

Ogden Environmental


Joel Feigenbaum



Richard Hugus


Peter Schlesinger



Paul Zanis



Bob Burt

102nd FW-CE/SWSG


James Kinney



Patricia Culligan



Phil Gschwend



Jim Stahl








Austine Frawley







Jan Larkin



COL Bruce Ruscio



Doug Shattuck



Mark Forest

Rep. Delahunt


Kristin Keske



Agenda Item #1. Welcome, Introductions, Review Action Items and Draft Agenda

Ms. Frawley convened the meeting at 6:10 PM and asked the new members to introduce themselves.

CPT Myer of the National Guard Bureau (NGB) introduced himself.

Mr. Leo Montroy of TetraTech introduced himself.

Mr. Jim Stahl introduced himself as Technical Outreach Services to the Community (TOSC) adviser and stated that his expertise was in munitions fate and transport.

Mr. Phil Gschwend introduced himself as a TOSC adviser and stated that his expertise was in the area of fate of organic chemicals in the environment.

Ms. Frawley noted that the handouts in front of the Impact Area Review Team (IART) members included the Textron submittal to the information request, the slides and maps for Ogden's Investigation Update, TetraTech's slides for the Munitions Update, the Rapid Response Action (RRA) slides, a form for written comments on the RRA plan, and copies of slides for the detonation chamber update.

Ms. Frawley then reviewed the Action Items.

Review of Action Items

  1. MAARNG agreed to provide and share with the IART a written inventory of the number and types of items remaining in the Ammunition Supply Point (ASP).

    LTC Fitzpatrick stated that he had agreed to look into it and stated that the Massachusetts Army National Guard (MAARNG) position was that they would not re-release a revised inventory. He stated that they would not release it due to security reasons. LTC Fitzpatrick added that items that could not be shot at the Massachusetts Military Reservation (MMR), such as artillery mortar rounds, had been shipped out and were no longer at the site. He reported that the items remaining in the ASP were small arms and pyrotechnics

    Mr. Hugus commented that a complete inventory had previously been provided at the EPA's request. LTC Fitzpatrick agreed that one had been released at that time, but that MAARNG had changed their position, and were not going to re-release the revised inventory. Mr. Hugus noted that if security were the reason, then security would have already been breached with the release of the first inventory. LTC Fitzpatrick agreed and said that it was. Mr. Hugus stated that there was a conflict here between the military's need for security and the Impact Area Review Team's (IART's) and the publics need to know what is at the ASP in terms of potential contaminants. LTC Fitzpatrick commented that right now MAARNG's position was that they would not re-release it.

    Mr. Hugus asked what the Unites States Environmental Protection Agency's (EPA) position was on this issue. Mr. Schlesinger asked if someone at EPA had security clearance to deal with this issue, so the MAARNG could report to EPA and solve it for the citizens.

    Mr. Walsh-Rogalski asked if there were some way to break the information down so that the MAARNG could release the information without causing problems. He explained that he meant rather than releasing numbers of munitions, possibly releasing types of munitions. Mr. Walsh-Rogalski asked if the inventory could be released to the EPA on the condition that it not be re-released. He stated that the last time the inventory was released, the EPA did not understand that it was sensitive and had re-released it, which caused concerns on the MAARNG's part. LTC Fitzpatrick suggested that the EPA submit a request in writing. He stated that the MAARNG could then look at what EPA was physically asking for and make a determination from that point. LTC Fitzpatrick stated that he could not specifically answer the questions, other than what was in there right now was pyrotechnics and small arms ammunition.

    Ms. Adams noted that since pyrotechnics were not allowed to be used at the Ranges, that causes her a little concern. LTC Fitzpatrick stated that some of the pyrotechnics were smoke, to be used in case of an emergency if someone needs to be evacuated by air. He explained that the helicopters are pulled into the site by the "popped smoke" so they know where to land. He added that the pyrotechnics are with the unit in case of an emergency situation.

    Mr. Walsh-Rogalski asked if that were the only type of pyrotechnic currently being stored in the ASP. LTC Fitzpatrick replied that there were smoke and flare pyrotechnics, and that he did not think there was anything else.

    Mr. Walsh-Rogalski asked the IART if the information LTC Fitzpatrick provided was adequate. He stated that, if not, the EPA would submit a formal written request and then sort through how to keep the information confidential.

    Mr. Hugus, for the sake of the audience, explained that the issue is that there is a place out at the Training Range part of Camp Edwards called the Ammunition Supply Point, and at the last IART meeting the team asked to know what the inventory at that ASP was. Mr. Hugus reported that last Fall there was an incident at the ASP, where some munitions were found to be leaking and had to be taken out and blown up. Mr. Hugus urged EPA to submit a written request for the inventory, as he would like to have some understanding of the contents of the ASP. He added that he did not understand why security is a problem.

    Dr. Feigenbaum asked who made the ruling that releasing the inventory would be a breach of security. LTC Fitzpatrick replied that it was the MAARNG leadership. Dr. Feigenbaum asked whom specifically. LTC Fitzpatrick asked why. Dr. Feigenbaum stated he was asking a straight question, if LTC Fitzpatrick did not want to answer the question, then do not answer it. LTC Fitzpatrick said he did not specifically talk to the Adjutant General (TAG), but that he had sent the information forward and that was the reply he received. Dr. Feigenbaum asked who the TAG was. LTC Fitzpatrick replied that it was General Keefe. Dr. Feigenbaum asked if it were in the TAG's purview to make decisions about classified information. LTC Fitzpatrick stated he could not specifically answer that. Dr. Feigenbaum commented that if it is not in the TAG's purview, it is not a legal order, and said that LTC Fitzpatrick was transmitting an order that LTC Fitzpatrick did not know was legal. Dr. Feigenbaum noted that this did not make sense to him. LTC Fitzpatrick replied that he did not have enough information to discuss what Dr. Feigenbaum was asking and would try to clarify that. Dr. Feigenbaum requested that LTC Fitzpatrick get a clarification of where the authority stems from to declare things classified information. LTC Fitzpatrick replied that when the EPA sends him the request for what they want, he will respond to that. Dr. Feigenbaum commented that, in the past, there have been times when information has been withheld under the rubric of national security, and he wanted to make sure that this was not happening at this point. LTC Fitzpatrick said they would do the best they can.

    Dr. Feigenbaum stated that there was an issue that the ASP had taken material on loan from the Connecticut operation and that material was being stored at Camp Edwards. LTC Fitzpatrick stated that the Connecticut ASP was being refurbished and that some of the materials and munitions were sent to Camp Edwards as it was a nearby ASP within the Guard community. Dr. Feigenbaum asked if these materials had been sent back. LTC Fitzpatrick replied that he did not specifically know what was sent, that the artillery and mortar rounds and items that could no longer be fired at Camp Edwards were gone. He said if those had been sent here, they have left and were no longer in the ASP. He noted that there may be some pyrotechnics left. Dr. Feigenbaum asked if those pyrotechnics would eventually be sent back to the Connecticut ASP. LTC Fitzpatrick replied not necessarily. Mr. Borci stated that if he remembered correctly the Connecticut materials were all high explosive (HE) rounds and some 155-millimeter (mm)-training rounds. He said that he believed that as of the update a month ago, all had been shipped out. Mr. Borci said the EPA would send the letter. Dr. Feigenbaum asked that the EPA send the letter, both for the substantive reasons that the IART would like to know what is still stored at the ASP, and because he thinks the procedures for classifying or restricting information needs to be clarified.

    LTC Fitzpatrick noted that as a point of clarification on the artillery simulators, they were not leaking but the packaging around them had been swelling.

    LTC Knott asked that the EPA request be sent to the MAARNG, as this was not a National Guard Bureau (NGB) issue.

    Mr. Pinaud asked if it would still be necessary for the entire IART to know exactly what is in the ASP if the MAARNG could provide the information to the EPA. He further questioned that if it is necessary, could someone tell him why. Mr. Hugus replied that, in general, the IART is claiming the right to know because this is our town and our land; Camp Edwards has caused a lot of damage to the environment, the soil and groundwater, and the munitions that have been stored there have had to be blown up because they were stored too long -- that is the short answer. Mr. Gschwend said that as a brand new person at the table he was amazed at the discussion. He commented that the right to know is a clear-cut legal argument, but, on the other side of the argument, if we are really going to try to protect water resources of the area, one has to know the range of chemicals we are talking about; you cannot just assume a hazardous substance list. Mr. Gschwend said we couldn't start from that point of view. He added that, since we obviously cannot study everything, we must make as a first cut some decisions based on what we know to have been in the surroundings. Mr. Gschwend said that this would be a smart way to start. Mr. Hugus said that one other point is that there is such a thing as a community right-to-know, as in a toxic release inventory; because we live nearby, the public has the right know what kinds of toxins are stored in factories and large institutions in a community. Mr. Zanis said he would like to comment about the history; in the beginning of the Impact Area Study, he asked the MAARNG why they used such large quantities of white phosphorus. He reported that the MAARNG replied that they did not shoot white phosphorus. Mr. Zanis said that it was eventually determined that MAARNG had more white phosphorus stored than they were allowed to without reporting it to the state. Mr. Zanis explained that this is why he thinks the IART needs to know what is being stored at the ASP.

    Ms. Frawley commented that it is then agreed that the EPA will submit a written request to MAARNG.

  2. It was agreed to discuss, at the next technical meeting, inclusion of a Greenway Road high-use/frequent-use range in the Small Arms Sampling Plan.

    Mr. Gregson reported that this had been discussed at the technical meeting. He stated that it was decided that, because the ranges on Greenway Road have not been used recently (within the last couple of years), there were other ranges better suited for the purpose of this study, which was to test soil at ranges that had been used recently.

  3. NGB/MAARNG agreed to provide a written response, for inclusion in the weekly technical report, to Mr. Zanis' request that the active ranges on Greenway Road be moved away from nearby residential areas. They will also identify who was using the range near the Forestdale School the weekend of February 27-28, 2000

    LTC Knott asked Mr. Guido to respond to this item. Mr. Guido reported that he had talked to COL Bailey about the ranges, although he did not know about the February 27-28, 2000 time-frame - he did not have an answer on that one yet, but MAARNG did not use them. Mr. Guido said that there are three ranges there -- a rifle range, a pistol range and a shotgun range. He stated that they are used maybe once or twice for emergency overflow, and were not regularly scheduled ranges. He added that alternate ranges are utilized first; typically, sometimes in October when there is heavy training, other than that, they are not scheduled for use.

    Mr. Hugus commented that the request that went in about the ranges on Greenway Road was not that they only be used for overflow, but that they be decommissioned because of proximity to Greenway Road residents. Mr. Hugus stated that the IART had made this request out of concern for these residents. Mr. Hugus noted that Mr. Guido had said those ranges would only be used for overflow. Mr. Hugus said we would like to see those ranges shut down. LTC Fitzpatrick replied that, currently, MAARNG was not planning to shut the ranges down, but to save them for use for overflow. He added that he was not sure what the mechanism would be for the team members to use to request the ranges be closed. Mr. Hugus commented that the request had already been submitted. LTC Fitzpatrick asked for details on the submitted request. Mr. Hugus replied that on the list of action items, it stated that Mr. Zanis sent a letter. Ms. Frawley clarified that Mr. Zanis had made a verbal request at the last IART meeting, and that Mr. Zanis had asked for a written response to his request. Mr. Zanis said he had sent a letter to LTC Knott. LTC Knott said he has not seen it. Mr. Zanis added that he had sent it by e-mail to LTC Knott. LTC Knott said he would try to find it and, if he could not, he would ask Mr. Zanis to send it to him again. LTC Knott said he would try to help with crafting the letter, but needed to make it clear that this was an MAARNG issue not an NGB issue. He stated that, if the IART feels strongly that the ranges be closed, there must be a formal letter from the IART which he could help take forward to the MAARNG; but, again, it is a MAARNG issue and they would expect an EPA or IART heading on the letter that requests closure of the ranges because of these concerns. LTC Knott said he could help get that formal letter to the correct people, but that it is a MAARNG training site. Mr. Hugus commented that, again, this is something we are asking MAARNG to do out of consideration for the health, safety and peace of mind of nearby residents.

    Dr. Feigenbaum asked if LTC Knott was saying that the overflow was not caused by NGB usage but by police usage. LTC Knott replied no, that what had been said was that the police also use these ranges, so if there is an overflow on a weekend it could be MAARNG or police, or a number of people. Dr. Feigenbaum asked where the police came from, and if they were local forces. LTC Fitzpatrick replied that both state and local police use the ranges. Dr. Feigenbaum commented that he was sure that if the police were told there was a problem and that they are inconveniencing the local community, they might find another place to train. LTC Knott suggested having that community write the letter. Dr. Feigenbaum replied that the IART was speaking, as best it could, for the community. He said that he heard the noise himself when he was at the Forestdale School, and as far as going to the community, he asked LTC Knott to remember that he was not paid to do this. He stated that there were a lot of community outreach people employed here by many different agencies and many different private companies, and perhaps LTC Knott would like to send some of them out into the neighborhood to find out what the residents think. LTC Knott said to clear that up, at last month's meeting Dr. Feigenbaum stated that he heard firing going on; NGB had checked, and MAARNG had not been firing that weekend, and had not been using the ranges at the Massachusetts Military Reservation (MMR).

    Mr. Gonser commented that shutting down ranges and managing the training areas probably is not as much an Impact Area Groundwater issue as it is a master planning issue. He added that this is a very real master planning issue that has been brought up in a number of different forums, such as the Community Working Group (CWG). He said that what Dr. Feigenbaum was telling the IART was not something that had not been heard before in the master planning area; in fact, the Joint Program Office (JPO) had had a discussion with some folks about that exact MAARNG issue that day. Mr. Gonser said that the best way to get that input in is in the MAARNG's draft master plan of how they will use the entire installation. Mr. Gonser stated that those types of comments need to come into the master planning process and into the effort so that the resulting Environmental Impact Report (EIR) can be shaped to include this. Mr. Gonser said that he can bring in those concerns and make sure Dr. Feigenbaum's concerns are reiterated, although it is already known as they have talked to the Forestdale residents and understand there are some concerns. He said that is why those ranges are very rarely used. He added that if Dr. Feigenbaum wanted to put in some information, a way to do it might be to go through the EIR process and formally add the information as part of that process.

    Ms. Frawley stated that Mr. Gonser's suggestion sounded like a good idea and asked Mr. Zanis if he wanted her to forward the letter to Mr. Gonser under the EIR process of if he wanted to re-draft it and send it again. Mr. Zanis said he would send it to Mr. Gonser.

    Mr. Camberari asked what the timing of the EIR process was as he was not sure what activities have occurred since the last certificate came out. He noted that it could be years before another supplemental comes out. Mr. Gonser replied that Mr. Camberari was right, the process has slowed down considerably. He explained that COL Jenner, who was the main focal point, retired and took another job, and the contractor finished their work and ran out of money, so now the contract is being renewed. Mr. Gonser said he would hope that pretty soon the folks would be back on board whom could start putting together the final EIR. He added that, either way; he can get the input into the leadership who is making the management decisions on the master plan.

    Mr. Camberari commented that it seems as if ranges are controlled by Range Control so, if there is a decision to close the range due to community concerns, it should be a pretty simple thing to implement.

  4. Mr. Hugus requested that NGB check its maintenance records and report to the IART on all munitions clean-up activities that have occurred outside of the official Impact Area Study.

    Mr. Gregson reported that NGB has been looking into this. He stated that one incident that had been reviewed with EPA at the last technical meeting had been at the J-2 Range, where Environmental and Facilities Engineering personnel removed a couple of drums and a 150-gallon fuel oil tank that were discovered at the end of the range. He added that in that effort there was something on the order of ten dummy rounds identified and taken out of that area and brought into the Impact Area. Mr. Gregson said other than that incident; NGB has not come up with any other activities of that type.

    Mr. Walsh-Rogalski asked if the activity has been an MAARNG activity or an NGB activity. Mr. Gregson replied that it had been conducted by the Environmental Office of the MAARNG and Facilities Engineering at Camp Edwards.

    Mr. Walsh-Rogalski stated that this had been an issue some time ago, dirt having been moved around without EPA's being aware of it. He explained that the issue came up at the February 1998 IART meeting. He said that COL Murphy agreed that the EPA would be notified before dirt got moved around, and Mr. Walsh-Rogalski requested that the EPA be notified before moving any dirt around. He explained that this would serve two goals: if the EPA has environmental concerns about the sampling that needs to be done, they would have a leg up on that, and also it avoids creating any suspicions about what kinds of activities are occurring. LTC Knott stated that NGB would coordinate with Ms. Drake and Mr. Borci at the technical meetings. He said that there are meetings every Friday with personnel from all the different areas at Camp Edwards on what their activities are for the coming week. He stated that if there is anything of this nature that falls into this category, the Guard would tell Mr. Borci at the technical meetings, before the work happened. That way if there are any concerns, Mr. Borci can visit the site. Mr. Walsh-Rogalski agreed and added that the work EPA was interested in is moving either dirt or other things around that raise these sampling issues.

    Ms. Adams suggested the Guard look at an additional source of information, the Range Control and Explosive Ordnance Disposal (EOD) reports. She explained that she knew from the archive search about a cleanup of the KD Range, and the Guard needs to be in coordination with the EPA, because some of their people may be undertaking actions without informing the Impact Area Groundwater Survey (IAGS) office.

    Mr. Gonser commented that, for the group's information, JPO would not be doing any cleanup, but, as part of the water supply project, there will be some earth movement at some of the well sites. He said the JPO would keep people informed at the meetings.

    Mr. Hugus asked if Mr. Gregson had said that there was excavation at the J-2 Range and asked what had been excavated. Mr. Gregson replied that there was no excavation, there was removal of a couple of rusted drums and an empty fuel oil tank, a 275-gallon home heating oil tank. Mr. Hugus asked if the fuel oil tank had been underground, and Mr. Gregson replied that it had been lying on the ground surface.

    Mr. Hugus commented that the reason he originally asked was that he expected to hear that there had been details sent out to do pickup all over the 15,000 acres. He said that, going out there himself, he has seen before and after conditions, and he knows a lot of stuff has been picked up. Mr. Hugus added that the IART knows about the re-grading of Demolition Area 2 (Demo Area 2) and stated that he just does not find it credible that, in the three years the IAGS has been going on, there has not been anyone going out there to pick stuff up, like C-4 at Demolition Area 1 (Demo Area 1). LTC Knott stated that this was a good point and noted that he had forgotten to mention that. Mr. Hugus said that what he wanted to know was if the Guard has been out there picking things up and not reporting it.

    Mr. Zanis stated that, to clarify, he went out there with COL Murphy and CPT Boggess, and they walked the J-2 Range and stood on the mound of drums that were buried. He stated you could jump on the hill and the hill would vibrate -- those drums are gone. He stated that there were not two drums lying on the surface, animals were living in the drums that he was talking about. He added that after the backhoe went through there, after the Guard cut the trees down and removed the drums, dummy ordnance was uncovered by accident and that there are heat rounds lying on the ground, where the bulldozer ran over them, and the Guard did not pick those up. Mr. Zanis commented that to say that there are just two drums lying on the surface is incorrect.

    Mr. Borci stated that he would like to put some perspective on this. He said that EPA has talked to Mr. Gregson about this issue and had received a report from Mr. Gregson containing analytical data that was prepared after the removal of the drums, and EPA is reviewing it. Mr. Borci said it does look like some hummocks got knocked down, and EPA is keeping it all in perspective. He reported that work that is coming up is work that TetraTech is going to be doing as part of the munitions survey. He added that this area has been chosen to be investigated further. He said if there is anything out there currently, it will be addressed, and if there is stuff that has gone on in the past, EPA is looking into that, too.

    Mr. Schlesinger noted that Mr. Gregson had said a number of dummy rounds were found and brought into the Impact Area. He asked Mr. Gregson what he meant by that and where the rounds were brought and what the Guard does with them. Mr. Gregson replied that, according to the report, they were brought into an area along Turpentine Road. He said that they may have ended up on the pile at the Armored Personnel Carrier (APC) that has subsequently been removed, but, since he was not personally involved in putting them in there, he was not sure exactly where they went.

  5. It was requested that the technical team revisit the number of Demo Area 1 response wells located near the southern part of the plume, based on the recent profile sampling results from MW-75, MW-76 and MW-77.

    Mr. Gregson reported that they were awaiting actual groundwater data, rather than profiling data, from the wells at Demo Area 1. He said that the technical team is looking at that information. He added that as part of the upcoming work at Demo Area 1, it is likely that a well will be required along the southern boundary to define the extent of contamination in that area. He said that the Guard would do that if it needs to be done.

  6. It was requested that MAARNG conduct a record review of the history of use for Mortar Target 9 and report its findings to the IART

    LTC Fitzpatrick referred the team to the map (Figure 1) of the Impact Area in Ogden's slide notes. He reported that this map showed the various targets and noted that the target numbering was arbitrary and had been done for ease of the study. He explained that when units are out there firing, whether it is from a mortar or gun point, each unit labels its targets accordingly, not necessarily what is on the map. He said that there was no way to recreate the files on which units were firing at a particular target or how many rounds were fired. He said that, for example, Target 9 as shown on the map would not have necessarily been Target 9 for one of the infantry or armored companies or an artillery battery. Each had their different numbering systems based on the organization for a wartime mission. He said he could not say, for example, "this unit fired 22 rounds at that particular target," and he could not recreate those files.

    Mr. Walsh-Rogalski asked if that also meant that if it were called a mortar target on this map, it would not necessarily be a mortar target, but could be an artillery target. LTC Fitzpatrick replied that was correct. He added that the distance where the target is located, in relation to mortar position (MP)-7 or MP-8, may more than likely have been a mortar target. He added that if he had been sitting at gun position 9 (GP-9), at the southern part of the range, he still could have used it as a target. LTC Fitzpatrick said that right now, the rounds showing up seem to be more mortar targets.

    Mr. Walsh-Rogalski asked that for the purposes of the IAGS these targets not be called mortar targets, but rather mortar/artillery targets or just targets, so that we do not try to draw conclusions based on thinking that they are just mortar targets.

    Ms. Adams asked if there were a way to figure out when a target at that location was first used. LTC Fitzpatrick replied he did not think so. He said that if a target had been placed back in 1945 or 1957, those records no longer exist. He said the ranges move targets around, which has been his experience at other impact areas.

    Mr. Zanis stated that a lot of the targets had been placed in the 1980s. He said that over by Succonsette Pond, the buoys were placed there, and the small aluminum APCs -- that was in the range expansion of the early 1980s, 1982 or 1983. He said that some other targets could be found by the "valley of death" five corners, up on the hill. He added that those had been placed a little later on during that period.

    Mr. Schlesinger asked why it would be relevant that the IART know what was fired and how much was fired if we are using the same analyte list when testing. Mr. Grant said that we always hope we can somehow track the findings to the actual munitions that were used -- it does not always happen that way, but that is the goal, to try to relate it somehow. Mr. Walsh-Rogalski stated that there was also an issue with respect to time, in that artillery firing stopped at a certain date, and mortar target practice continued so that, if you could tell if it were a mortar or artillery target, it might also give you information on the timeframe.

    Mr. Hugus commented that one of the reasons this was put on the action item list was that at the last IART meeting, the team learned that soil sampling at Target 9 showed Royal Dutch Explosive (RDX) in concentrations of 39,000 parts per billion (ppb), Her Majesty's Explosive (HMX) at 3,600 ppb, and trinitrotoluene (TNT) at 3,600 ppb, so this is, outside of the KD Range, one of the worst soil sample sites we have found. Mr. Hugus said it was logical for the IART to want to know how "high use" this target was and what was fired there. He said he was surprised that the Guard is not able to give the IART any information whatsoever on time of use, frequency of use, and type of use at that target. He commented that this information would help the IART with their study. He stated that there is a need to quantify here.

    Mr. Schlesinger stated that if the sampling scheme does not change and what we ask of the technical folks in the field is not changing, regardless of the use, he does not get it. He asked if this was sampled differently, or set up in different grid schemes to look for different analytes if some place is more heavily used than another. Mr. Borci replied that these were all pieces to the puzzle. He said that every bit of information helps.

    Mr. Zanis commented that, previously, all that had been looked at were the old targets, no one ever mentioned the most recently used target. He said he was concerned that we were not getting the detections at the old targets, maybe from photo-degradation or something, so that is when he brought in the photos of the most recently used targets and asked the question of why they hadn't been looked at -- and that is when the sampling plans went forward and we found out there is something there.

  7. Dr. Feigenbaum requested that the technical team discuss the adequacy of the characterization of the Mortar Targets area of contamination.

    Mr. Grant stated that this was the first stab at the mortar targets; as Mr. Borci mentioned, Ogden is installing wells, one that is about to be set in the next couple of days that is downgradient of the targets, and another one that will be going in amongst the targets. He said that the results of this investigation would be reported in a technical memorandum that would go to the agencies and the IART in May or June 2000. Mr. Grant added that, like any other area of investigation, usually based on initial results we have some follow-ups so it is a little early to fully analyze this. Mr. Grant said he thinks that the report will also take a look at lines of evidence; the Guard may not have clear written records of when targets were in place, but there is aerial photography, as Mr. Zanis mentioned; there is anecdotal evidence about when targets were in place, and we can look at all that stuff. Mr. Grant stated that the Archive Search Report (ASR) does have lists of targets from Range Control; they do not go back too far, but at least you can tell from the first list if it included.

    Dr. Feigenbaum commented that there have been a lot of meetings since the last IART meeting, but he thought what he was asking was, if you had a hit at a target, was the location of your tests optimal relative to the target in terms of the mean circular radius of impact, and so on. Mr. Borci replied that, at this stage, the sampling consisted of two rings a distance from each target. Mr. Grant added that the distances were usually 15 and 25 feet from the target. Mr. Borci said that 15 feet was the inner ring, and 25 feet was the outer ring. He asked for confirmation that contamination was detected in both rings. Mr. Grant concurred, and noted that the highest concentration had been at the inner ring, which is generally the pattern being seen. Mr. Grant reiterated that this information would be written up in a report. Mr. Borci said that this information would be evaluated and compared to what is seen throughout at the other mortar targets, where detections had typically been seen in the inner rings. Mr. Borci stated that one could assume that the tech memo would suggest that additional outward sampling and sampling at depth would be required at Mortar Targets 9 and 10.

  8. Dr. Feigenbaum noted that the unit of concentration and MCL for 1,2, -Dibromoethane was incorrect in the 2/28/00 VOC detection table (page2), Well Number ECMWSNP02. A written discussion of the MCL/HA exceedence at this IAGS well in the Snake Pond area will be included in a weekly report.

    LTC Knott reported that this had been sent out.

    Dr. Feigenbaum stated that he would like to thank Mr. Grant for putting that together.

Review of Agenda
(See Attachment #1)

Mr. Hugus asked to add an item to the agenda. He requested some discussion and update on the small arms range soil testing. He added that he would also like to request five to ten minutes for open discussion on a few items he would like to raise. He suggested these be addressed after the Textron Update.

LTC Knott said that he would like to request that, again, the team try to get to the most important things first and there is a full agenda, he had no problem discussing these issues, but he would like to hear the Ogden Update first. Mr. Hugus said that was fine. Ms. Frawley stated that the small arms issue would become the first issue under Other Issues.

Ms. Frawley then ran through the Agenda Items. She noted that the Textron information request was put on when Textron's information was still considered confidential business information. She added that since then, the confidential business information claim has been removed and the team members now have copies of the report. She suggested he discussion could be put off until May after everyone has had a chance to read the report. She asked if that was agreeable to the team, and the team concurred. Ms. Adams added that the Textron materials did not include attachments. She said that EPA and NGB had discussed putting the original response into the Information Repositories so that people could look at the attachments or, alternatively, copy them and get them to the IART. She said that the relevant attachments were the maps. LTC Knott stated that NGB would like to go with the manifests, things like that that are not of "relative interest," and put those in the repository, then go ahead and provide copies of the report, including the maps, to the team members.

Dr. Feigenbaum asked if the team could have at least one map. LTC Knott said that the team would be provided with all the maps, but not all of the attachments.

Mr. Zanis asked if the team would get information on Avco. Ms. Adams said that the Textron report contains information on Avco.

Mr. Feigenbaum said he had an action item and requested more microphones for the meetings. Ms. Cenedella replied that the equipment was borrowed from the AFCEE program, and that there were no more ports on the system to support additional microphones. She added that OpTech would be very happy to work with the team if they wished to purchase a new system.

Mr. Hugus asked if Ms. Frawley had stated that the Textron discussion would be skipped because the team has not read the report. Ms. Frawley said that was correct, it would be tabled until next month if that were agreeable to the team. Mr. Hugus said he had one short question to ask, namely why Textron claimed that this report was confidential information -- he knows the claim has been withdrawn, but he wanted to know what their original reason was. Ms. Adams said that, per a telephone conversation she had with Textron's attorney, they had prepared the information response and focused on getting the information together and put on the claim of confidentiality as a precautionary measure in case there were any trade secrets or national security issues in there. Ms. Adams added that once Textron had finished the data collection and sent it out, they looked at it again and realized that there were no such issues -- it did take some purging to have them remove the claim of confidentiality.

Approval of the Minutes

Ms. Frawley reported that last month's minutes were not available tonight, but would be mailed next week, and comments and corrections on them could be made at next month's meeting.

Ms. Frawley then asked the team if they wanted to move the Public Comment Period up to the first item. LTC Knott replied yes. Ms. Frawley said that would be done, and noted that there was a court reporter present who would record verbatim the comments submitted on it. She thought that NGB and EPA would have a few words to say on this.

Agenda Item #2. Rapid Response Plan and Public Comment Period
(See Attachments #2, #3 and #4)

Rapid Response Plan
Mr. Borci commented that, keeping in mind the short timeframe available tonight, EPA's comments had been sent out by e-mail to the IART and are available for anyone else. He added that MA DEP's comments are available tonight. Mr. Borci said if folks have additional areas or want to re-emphasize an issue, they can just state a comment while the record is open, then we will close the record and discussion can occur in the meantime over e-mail or by telephone. He added that, comment sheets provided by the NGB are available at each seat at the IART table and at the back of the room; you can write down your comments and submit them to either himself or Mr. Jim Murphy, who is seated in the audience. He went on to say that the comments can be submitted or mailed, and as long as they were postmarked by tomorrow, they would be accepted. He noted that the comment period would officially close tomorrow. He noted that Mr. Veenstra of Ogden would give a brief overview of the Rapid Response Action (RRA), and after that the comment period would officially be opened.

Mr. Veenstra reported that Ogden wanted to give a brief re-run of the presentation made a month ago to the IART and at the SMB two weeks ago. He explained that this would give people who had not been here before a chance to hear an overview of the approach for the RRA. Mr. Veenstra explained that Administrative Order #3 (AO#3) required the NGB to conduct a RRA at six areas of concern (AOCs). He stated that those areas had initially been identified and reported under the Massachusetts Contingency Plan (MCP).

Mr. Veenstra stated that the primary objectives of the RRA were to remove soils that are potential sources of contaminants to the aquifer, clean up those soils to an agreed-upon performance standard, restore those areas disturbed as a result of soil removal, and then treat or dispose of contaminated materials. He noted that the AOCs were indicated on the project map, which was also attached to the handout (Figure 1). He said the six AOCs included: (1) the steel-lined pit; (2) Study Area 2, which is a designation from the IAGS; (3) the firing and target areas of the KD Range; (4) the edge of the J-3 wetland; (5) Gun Positions 7 and 16 (GP-7 and GP-16); and (6) an armored personnel carrier (APC) which had been a target within the Impact Area.

Mr. Veenstra reported a slight change in the contractor lineup. He stated that Ogden was the lead contractor, being supported by USA Environmental, Sevenson Environmental, Brice Environmental and Envirogen. He explained that Environmental Technology Center's (EnviroTech) role had been refined, and that EnviroTech would be working in a third-party capacity to review or evaluate some of the technology associated with the implementation of the RRA program. He noted that the community involvement role that was previously discussed - i.e., the community involvement component of the RRA being performed under the Public Involvement Plan will be led by the Army National Guard, and supported by the JPO with technical support from Ogden.

Mr. Veenstra went on to say that this presentation was an update of where Ogden is today. He reported that a draft Work Plan was submitted by the required date, March 1, 2000. He added that EPA provided some comments to NGB on March 28 and 29, 2000, and that comments from MADEP were either provided or would be provided this evening. Mr. Veenstra noted that, as Mr. Borci indicated, the public comment period closes tomorrow, April 6, 2000. Mr. Veenstra reiterated that comment sheets were available and that input was welcome.

Mr. Veenstra reported that, in the area of upcoming activities, Ogden will begin the unexploded ordnance (UXO) survey for avoidance within the next couple of weeks to support additional soil sampling to delineate or define how much soil must be removed from each AOC.

Mr. Veenstra stated that part of the Notice of Intent (NOI) requirement was that NGB define the boundaries of the wetland. He reported that Ogden would undertake that activity starting April 17, 2000.

Mr. Veenstra said that revisions to the Work Plan would get underway at the close of the public comment period. He explained that the Plan was the format for NGB to address agency and public comments, and the comments would be taken into consideration to update the document that will guide the implementation of the contaminated soil removal.

Mr. Veenstra reported that there was a new Field Sampling Plan (FSP). He explained that this was something that was routinely put together for the technical team to review, which governs how Ogden collects samples and which analytes they would test for. He reported that the FSP would be prepared before Ogden begins testing approximately 94 additional grids to locate the AOC.

Mr. Veenstra then reviewed information on the Work Plan. He stated that, regarding the proposed cleanup standards, at this point there was agreement on 60-65% of the contaminants concerned with respect to their cleanup standard. He added that there were a few others that Ogden was considering for an appropriate or maybe a more appropriate method to develop a standard protective of groundwater. He noted that also included in the draft Work Plan were additional soil sampling efforts, a treatability study which helps Ogden optimize the process for treatment of soil after it has been removed. He said that soil removal methods and innovative treatment methods have been discussed. He noted that there had been a posterboard session on the RRA preceding the IART meeting, a few posterboards were still up, and technical representatives from Brice Environmental and Envirogen were in attendance to answer process-specific questions. Mr. Veenstra said that site restoration methods and the project schedule were discussed in the Work Plan. He stated that going final on that means addressing public, agency and team comments on the draft document.

Mr. Veenstra said that Ogden was proposing to begin additional data collection. He said the first issue to address was UXO avoidance, in order to protect field workers while they collect soil samples. He reported that the work will be governed by a FSP and that the additional soil samples would be used to develop an excavation profile -- in other words, how many feet left or right, forward or back, and to what depth material should be removed in order to meet the agreed-upon cleanup standards.

Mr. Veenstra reported that soil removal would take place later this summer, after the extent of the contamination had been defined and a treatability study, which indicates how the process needs to be conducted, is in place. He stated that soil removal will include UXO removal prior to digging and that, if UXO was encountered during the course of the project, it would be moved and stored if safe to do so. He said that the UXO may be stored until such time as the controlled detonation chamber (CDC) is on-line and ready to run. He noted that there would be discussion on the CDC later in the evening. Mr. Veenstra stated that if the CDC were not available, the UXO would be handled in the same manner as it has been managed throughout the investigation program.

Mr. Veenstra went on to say that the soil would then be excavated, brought back to a central area and run through a treatment process. He added that once excavation had been completed in an area, additional clearance samples would be collected to confirm that cleanup goals have been met. He said that, in the worst case, they would get a sample that said the cleanup goals had not been met. He added that Ogden would then have to remove more soil from that area.

Mr. Veenstra reported that once confirmation was received and the cleanup goal was met, the area would be backfilled, topsoil laid, and the area reseeded. He noted that in the case of the J-3 wetland, there was a slightly different procedure. He said that J-3 wetland activities would be coordinated with the local conservation commission and the MMR Natural Resource Management Office.

Mr. Veenstra reported that the innovative technology in this case would be two proven technologies linked together for the first time. He noted that the treatability study was to design the process or optimize material processing, and it would confirm that treatment would be successful before it was launched full-scale in the field. Mr. Veenstra stated that the two different technologies were soil washing coupled with bio-treatment. He explained that the bio-treatment consisted of bugs that eat explosives to decontaminate the soil. He added that upon completion of the treatment, confirmation samples would be taken to confirm the agreed-upon cleanup standards.

Mr. Veenstra concluded the overview and stated that what Ogden wanted to do tonight is to make sure they have the opportunity to hear any additional questions or comments concerning the RRA activity, spoken or written. He explained that this gives the contractors the opportunity to address those in the Work Plan revisions.

Public Comment Period
Ms. Frawley noted it was 7:11 PM and that the record would be officially opened for public comment. She requested that everyone who speaks give his or her name and affiliation for the court reporter.

Mr. Gordy introduced himself as the chairman of PACERS and stated he had watched the RRA presentation at the SMB. He commented that there had been some things he did not understand and he had spoken to some of the technical people. Mr. Gordy said his understanding was that the biological process to be used mimics a naturally occurring process that would take place anyway. He said that after removing explosive contaminants by the washing process, the contaminants go into a tank where whatever could not be removed in an aerobic fashion is then transported to another section where the materials undergo an anaerobic process. Mr. Gordy stated that, additionally, nutrients were added to encourage the growth of microbes. He commented that these microbes were essentially the same as were present in the earth. He stated that the IART studies to date have shown that within 1,500 to 1,600 feet of water movement along the tracks the contaminants are removed. Mr. Gordy stated that it was a big waste of money to excavate when natural processes would take care of the contamination, and have been taking care of the contamination for over 65 years. He added that he thinks studies should be done to determine if it would be worth it to proceed with excavation; that the disturbance of and intrusion into the ecological systems may cause increases in water and contaminant flow to downstream wells in surrounding towns. Mr. Gordy noted that the contaminants have been at the MMR for a long period and have not affected the public supply wells. He stated that he thinks what needs to be done is a little cleaning up.

Mr. Gordy commented that safety needs to be put in terms of risk. He noted that the possibility existed that there may be 10,000 pieces of unexploded ammunition to be handled, which he considered a risk. He stated that he found it hard to understand how someone could simply look at it and determine whether it was dangerous or not.

Mr. Gordy stated that natural attenuation needs to be paid attention to, which the EPA has avoided in the past. He said that this avoidance has cost this country billions of dollars, in terms of all the gasoline tanks excavated, and it was later found out that all of the pump-and-treat methods EPA implemented were not necessary, that it could have been taken care of by a natural method. Mr. Gordy said spending a great deal of money was not necessary, all that needs to be done is to stop the previous deployed activities and let nature take its course.

Mr. Zanis introduced himself as a Forestdale resident who had grown up in Bourne. He noted he had spoken to Mr. Veenstra before. Mr. Zanis said that citizens he has spoken to tell him that their biggest and first concern is dust control from the cleanup. He explained that the citizens did not want to see clouds of dust coming from the ranges and floating through downwind neighborhoods in Forestdale. He stated that this was what he was here to say and he would pass in the paperwork.

Mr. Dow introduced himself as a member of the Cape Cod Group of the Sierra Club. He commented that one of the concerns he had was about thallium, a contaminant of concern that was not on the list of analytes. He stated that in the past, thallium detections had been reported in the groundwater in the Impact Area and had been found at the Installation Restoration Program (IRP). He noted that the Air Force Center for Environmental Excellence (AFCEE) had prepared a report which stated that because thallium co-appears in groundwater with manganese and iron under reducing conditions, it must be from a natural source. Mr. Dow said this was faulty logic, which he had pointed out to AFCEE. He explained that using that point of view, when AFCEE looked at the phosphorus in the Ashumet Valley (AV) Plume which came from the AFCEE sewage treatment plant, the phosphorus co-appeared with iron and manganese under reducing conditions as well, and is obviously not from a natural source. Mr. Dow commented that given that the thallium levels are greatly in excess of EPA's standard, he did not think it was of a natural origin. Mr. Dow said that he thinks the thallium levels in the soils in the Impact Area need to be studied in order to determine if it is a potential source area for underlying groundwater. He added that if so, a plan needs to be developed to remove the thallium other than what had just been discussed, since natural attenuation or biodegradation would not deal it with. He explained that thallium attaches fairly tightly to soil and would not likely be removed by soil washing. Mr. Dow stated that more attention needs to be given to thallium to determine soil concentrations and to devise an appropriate treatment method.

Dr. Feigenbaum introduced himself as a Sandwich resident. Dr. Feigenbaum stated that he was pleased that the IART would see some fairly innovative technology. He commented that this technology is one of the things that has been missing in not only the Impact Area but the IRP as well. He added that there has been a commitment to use just old-fashioned technology, and he was glad to see the use of this innovative technology.

Dr. Feigenbaum asked for more detail on how microorganisms work on explosive materials. He asked if the microorganisms used explosives as an oxidizing agent. He asked if someone from Biogen could answer. He asked what kind of bacteria had been produced, and if they were natural or a genetically engineered product. Dr. Feigenbaum asked where these have been used before and what assurances could be given that there were no harmful by-products.

Ms. Frawley explained to Dr. Feigenbaum that questions would be addressed at the close of the public comment period, in order that everyone got a chance to get their comments recorded accurately. She requested that Dr. Feigenbaum's questions be answered after all comments had been received. Dr. Feigenbaum replied that his comments would be based on the answers to those questions. Mr. Borci said that Dr. Feigenbaum's questions could be answered and his comments entered in the next public comment period.

Mr. Hugus introduced himself as a Falmouth citizen and member of the IART. He said his first comment was that he is in favor of the proposed RRA Work Plan put out by the NGB pursuant to AO#3. Mr. Hugus stated that he does not believe that natural processes take care of explosives-contaminated soil. He commented that the contaminated soils need aggressive treatment and explained that the IAGS shows that contaminated soil in many other places in the Impact Area resulted in groundwater contamination. Mr. Hugus noted that there would be additional contaminated soil sites to be addressed.

Mr. Hugus commented that page 26 of the Work Plan cites alternative cleanup standards to be used by NGB in which site-specific fate and transport information will be used. He stated that he believes AO#3 calls for cleanup to background levels. Mr. Hugus said he supports the EPA standard as a cleanup standard, rather than site-specific fate and transport modeling.

Mr. Hugus stated that the dieldrin detections in the J-3 Wetlands need to be addressed, and that the NGB Work Plan did not address dieldrin. He commented that the dieldrin should be cleaned up.

Ms. Frawley asked if there was anyone else in the audience who would like to make a public comment. (There was no response).

Mr. Stahl then introduced himself as a TOSC member. Mr. Stahl commented that he thinks the RRA Plan was pretty good as is. He added that he thinks it is very important to remove contaminant source material, especially HMX and RDX. He explained that as long as a source was present, there would be continual leaching through the soil into the water table.

Mr. Stahl said his second comment was on the biodegradation process. He stated that the biodegradation process was, first, an anaerobic process for nitrated compounds. Mr. Stahl stated that, according to the literature review, it is best to segregate TNT away from HMX and RDX, as better degradation results from this separation of components.

Mr. Stahl commented that his biggest concern in the degradation process was dieldrin. He explained that he knows of no data showing that this process will degrade dieldrin. He added that an effort should be made to ensure dieldrin is degradable and that, before the process begins, a cleanup standard for dieldrin should be determined. He said that he does not want to go through the whole process, degrading HMX, RDX and TNT, and at the end of the process find that dieldrin has not been degraded and therefore cleanup goals have not been obtained.

Mr. Kinney introduced himself as a member of the IART and a resident of West Barnstable. Mr. Kinney stated that precautions should be taken during implementation of the RRA to keep dust levels down. He noted that Mr. Zanis had brought up this concern and that he agreed. He explained that something similar had occurred with the IRP, when AFCEE decided to incinerate 16,000 cubic yards of soil. He stated that despite what AFCEE had stated in their plan, they had covered huge piles of soil with plastic, the piles had been rained on, and lots of dust blew off of them. He said he would not want to see that happen at the Impact Area.

Mr. Kinney commented that he thought it was important to minimize damage to wetlands flora and fauna and the structure of the wetlands. He explained that otherwise the NGB would be cleaning up something that could well become a sterile zone, and there would not be much point to that. He stated that this was a major concern of his. He said the cleanup in the wetlands should occur as quickly and lightly as possible.

Mr. Kinney said that there has to be a solid agreement beforehand to clean up all contaminants to background levels, without deviation. He said that this point has been gone over again and again, and that there must be a strong commitment to get back as close to pristine conditions as possible in all cases. He added that he thought Mr. Stahl's comments on dieldrin were also a critical piece of the cleanup.

Dr. Feigenbaum commented that he supported the action. He stated that in addition to contaminants migrating into groundwater, another reason to be concerned was that the contaminants could be airborne, blown around by the wind, and soil particles could be carried as dust, which is also a threat to the community. He added that this reason would also fall under the Safe Drinking Water Act (SDWA), as it would expand the area of potential effect to groundwater. Dr. Feigenbaum stated he supported the action for this reason and the reasons that had previously been stated.

Mr. Schlesinger introduced himself as a Sandwich resident and member of the IART. He stated that he concurs with some of the others. He said he supports the RRA but thinks that whoever is reviewing the Plan should review the use of the MCP to exclude dieldrin. He commented that he thinks dieldrin should be removed to background levels. Mr. Schlesinger explained that over the last couple of years of the IAGS, he has watched a real attempt by the NGB to exclude items from the Study when given the opportunity. He stated that it was not known if pesticides were applied in a manner consistent with their labeling and asked how the IART could use the definition of a release in Massachusetts law to exclude pesticides from further study.

Ms. Frawley asked if anyone else in the audience would like to make a comment or statement. There was no response. She then asked if anyone else at the IART table would like to make a comment or statement. There was no response. Ms. Frawley closed the public comment period at 7:31 PM.

Ms. Frawley stated that Dr. Feigenbaum's questions would now be answered and the public comment period reopened if necessary. She asked if Dr. Feigenbaum's questions needed restatement. LTC Knott asked Mr. Veenstra and Envirogen if they could respond.

Ms. Keske from Envirogen noted that the senior technical person, Mr. Larson, could not be present today. She requested that the questions be repeated. Mr. Borci stated that Dr. Feigenbaum wanted to know how the microorganisms degrade the material, have they been used before, and what the by-products were. Dr. Feigenbaum added that he also wanted to know if they were bioengineered. Ms. Keske replied that the microorganisms were completely natural and would be taken right from the soil. She stated that the actual breakdown starts off as an aerobic process, and Envirogen would add molasses; and that it was actually a co-metabolic process, so molasses is the substrate, which eats the contaminants on the side. However, it needs the energy source, the carbon source, and that is why the molasses is added. She stated that it will actually reduce; like for TNT, it will reduce the nitro components of TNT to amino components, and then it will continue to break it down under anaerobic conditions. Envirogen is hoping for complete mineralization of the products, which is breaking it all the way down to the carbon backbone, carbon dioxide and its elemental components. She stated that Envirogen has shown at another site that this process happens; one of the microbiologists on the project has worked on it at the Joliet site and has shown that it does achieve complete mineralization of TNT. Ms. Keske said that the work at the Joliet site showed that you will get some ammonia and nitrate formation from the biological processes occurring. She stated that at the end of the process Envirogen would test for these things to make sure and will determine how they will be disposed of at that time. Ms. Keske said a lot will come out of the treatability study, like how the material was going to break down, because it is different with different microorganisms. She explained that a wide range of microorganisms can break down the material, but the actual organism(s) will be determined in the treatability study.

Dr. Feigenbaum commented that Ms. Keske had stated that the contaminants are broken down to the carbon backbone. He noted that these are ring compounds, RDX and HMX, so the carbon backbone would be benzene rings. Ms. Keske said that Envirogen has seen ring cleavage at the Joliet site. She added that this is what Envirogen would try to achieve here, which would come out of the treatability study.

Mr. Schlesinger asked when the treatability study would happen. Ms. Keske replied that she did not know the schedule. Mr. Veenstra replied that, as discussed, the treatability study is designed to replicate the full-scale field process in a laboratory setting. He said this would give Ogden the ability to look at all the breakdown products and the success of meeting cleanup criteria for each one of those products. Mr. Veenstra stated the treatablity study is proposed to take place before we go into the field, however, before beginning the treatability study, we need to first identify all that material that will be subject to the treatment process. He said that Ogden's proposal was to go out and do the additional delineation to define the extent of contamination, and once that laboratory data is back in hand, we will then go out and collect treatability studies, which would put us into the July 2000 timeframe, targeting August, 2000 to start soil removal.

Dr. Feigenbaum asked if treatability was sort of a pilot study. Mr. Veenstra replied that a treatability study is based on getting a representative sample of the materials to be treated, taking that back to a laboratory that Envirogen runs, and replicating the treatment in the laboratory. He said that this would be two different stages of treatability, one is the physical soil characteristics, as that is part of the process, and the second is the biodegradation of the contaminants of concern. He went on to say that the point of doing the treatability study is to: (1) confirm we can take it down to the rather low cleanup standards agreed to; and (2) optimize the process so we know we can do it in the field, size the equipment properly, determine retention times, etc.

Dr. Feigenbaum asked if there would be a deliverable sometime next summer in which Ogden will report on the efficacy of this process. Mr. Veenstra replied that part of the RRA program involves a treatability study report, in which we then compare the results of the treatability study to the established cleanup criteria and say "yes, we can take this full scale" or "we cannot quite get there," in which case we would have to look at another option.

Mr. Stahl asked if the molasses to be used for the process was a characterized material. He commented that he knows that some molasses comes as waste product in the sugar production industry, and could be laced with heavy metals and contaminants. He asked if there were any effort to ensure that heavy metals were not introduced into the process. Ms. Keske said that, first of all, the substrate Envirogen would add is not set in stone right now, and they would be trying different substrates. She said that Envirogen would try to make sure they did not introduce any other contaminants into the stream.

Mr. Cambareri stated that at the Senior Management Board (SMB) meeting the response to a comment on the soil washing aspect of the process indicated the soil would be power-washed to separate out the different sizes. He asked if this action would kill microorganisms in the soil. He asked how much Envirogen is relying on microorganisms in the potential substrate as opposed to those in the soil. Mr. Veenstra replied that the soil washing consisted of the physical particle size separation, trying to get down to the fine-grained material to be subject to the biotreatment. He said the power washing is done at ambient temperature and the water is recirculated in order to conserve it, so part of the treatability study is to evaluate potential impact of the water treatment chemicals used to precipitate out solids from the recirculation loop to make sure they do not impact or adversely affect the biotreatment portion of the process.

Mr. Camberari asked if this was to maintain a closed loop system. Mr. Veenstra said that was correct, the water would be recirculated, and then that water could be used as makeup water for the biotreatment process, adding water back to the soils.

Mr. Camberari noted that in the presentations it has been indicated that it is an innovative technology, combining soil washing and the biological aspect. He asked if the project got any funding from EPA for using innovative technology. Mr. Veenstra said EPA has not offered to help pay for this cleanup. LTC Knott commented that the NGB has told the contractors that, for NGB, it is unacceptable to landfill; NGB wants to take care of it, not put the contaminated soils someplace else. He added that the innovative technology was an approach that allowed NGB to take care of the problem, even though this approach would cost more money.

Mr. Schlesinger commented that Ms. Keske had stated that Envirogen had been able to break the benzene rings at the Joliet facility. He asked if that project included the great volume of soil that would be moved at the Impact Area and if Envirogen had real experience with moving this volume of soil through their technology. Ms. Keske replied that she believed that Joliet was a larger facility and had treated a greater volume of soil. Mr. Schlesinger asked if the Joliet treatment had been a test. Ms. Keske replied that Joliet had been done through Argonne National Laboratories, but that an Envirogen microbiologist had worked on the project. Mr. Gonser added that Joliet is an Army ammunition plant that has extensive contamination at significantly higher levels than the Impact Area.

Mr. Gschwend commented that Ms. Keske had stated that this process had been shown to work on the TNT at the Joliet facility. He asked if the process had also been shown to work on the HMX and RDX. Ms. Keske replied that it was hard to tell, they did a carbon C-14 trace on the TNT, so were able to see where that was all going. She said she did not believe Argonne had performed that testing with the RDX or HMX, so was not sure that had been achieved. Ms. Keske stated that, to her knowledge, the mechanism for that is not known. Mr. Gschwend said he assumed that all relevant explosive compounds will be simultaneously monitored before and after processing. He commented that he thinks it is a little premature to call this a "proven" technology.

Mr. Gschwend stated that his second point was that there is a likelihood of other inorganic or metal constituents in the soil, such as thallium and antimony, some of the other things that people see in the system. He said that sometimes the process where the redaction has been changed allows the metal to be converted from one oxidation state to another, it does not get rid of the metal, but in some ways sometimes could make the metal more problematic. Mr. Gschwend added that he presumes that this process will be watching for such metals, to ensure that the end result will not be inappropriate chromium conversion or something equivalent. Ms. Keske replied that Envirogen would be doing a full scan and would not just be looking at the explosives.

Ms. Frawley asked Dr. Feigenbaum if he would like the public comment period reopened, based on the answers he received to his questions. Dr. Feigenbaum replied no.

Agenda Item #3. Third Party Facilitator

LTC Knott noted that this had been on the agenda for last month's meeting, but, as the meeting ran long, it had not been discussed. He reported that the NGB has talked to the EPA, who will provide NGB with a list of professional organizations that can provide trained, professional facilitators that the team can consider. LTC Knott stated that the key point is that the IART members will decide who will work for the team. He asked if any members of the team, through their participation in other forums, knew of an appropriate trained facilitator or organization and could give him a recommendation. He stated that the bottom line is that NGB is paying for it, but the trained facilitator would be whomever the IART selects.

Dr. Feigenbaum commented that he has been going to meetings like the IART in other venues like the Agency for Toxic Substances & Diseases Registry Community Assistance Panel (ATSDR CAP). He said professional facilitators have facilitated a lot of meetings he attends, and just because they are professional facilitators does not mean the meetings run any better. Dr. Feigenbaum explained that one of the problems is that these folks are not familiar with the substance of what is going on, so they do not know how to evaluate a discussion as to whether it is productive, whether more points should be brought out, or whether time ought to be called and the discussion shut down. He commented that he would say Ms. Frawley runs meetings better than anybody else he has seen. Dr. Feigenbaum commented that if there is a problem, LTC Knott should get it on the table, and if LTC Knott felt there was something unfair about the way the IART meetings are run, then he could raise it on a case-by-case basis. Dr. Feigenbaum stated that there were whole cottage industries of consultants and public affairs people developing around these projects. He stated that the facilitator would not be a disinterested party, but another interest group at the table in the business of building their business. Dr. Feigenbaum commented that, as one person among a few others here who have no financial interest in this process, he was interested in keeping the IART as lean and mean as possible. Dr. Feigenbaum said he thinks Ms. Frawley is terrific, she never expresses an opinion and he has never seen her get involved in the substance of the conversation, she keeps the meetings moving as well as possible and has his vote to continue. Dr. Feigenbaum reiterated that if LTC Knott had an issue with that, he should raise it. He noted that LTC Knott stated that NGB would be looking at professional facilitators as if that were a fait accompli, and as if the assumption had been made that a professional facilitator would be better than keeping things the way they are.

Mr. Zanis commented that he would tell the NGB that "if it isn't broken, don't fix it". He stated that the NGB should save their money for the cleanup. Mr. Zanis said that Ms. Frawley was doing a fine job and he did not see a problem. He suggested, as an alternative, that NGB act as facilitator at every other meeting. Mr. Zanis commented that it should be left the way it is, and that Ms. Frawley lets the public and team members speak as much as they want.

Mr. Hugus commented that he thinks some criticism about the push to provide a professional facilitator for the IART is better directed not at the NGB, but the two selectmen on the SMB who felt that it was necessary. He stated that the SMB could really use a facilitator. Mr. Hugus said Ms. Frawley has done a good job and that her follow-up is good on action items and every other aspect of the IART's work. Mr. Hugus asked why the IART needed a professional facilitator. He commented that the Consensus Building Institute (CBI) has been the facilitator at other meetings he attends. Mr. Hugus stated that CBI had a monopoly on that business at the MMR, and had become too involved with representing the proponents of activities. He gave as an example the Air Force Space Command (AFSPC) Precision Acquisition Vehicle Entry - Phase Array Warning System (PAVE PAWS) issue. Mr. Hugus stated that he thinks the IART already has as neutral a facilitator as they could hope for.

Mr. Schlesinger concurred with Mr. Hugus' comments and stated he was astonished at the job Ms. Frawley does. He explained that he has heard comments at the SMB meeting by others who were in the audience earlier tonight. Mr. Schlesinger said that everyone at the IART meetings has been allowed to speak, all views are heard. He questioned the reason for change.

LTC Knott said he would like to answer a couple of comments first. He said that in answer to Mr. Hugus' and Dr. Feigenbaum's comments on CBI, they know better than him, and he thought that they were saying that they would not recommend CBI as an option. Mr. Hugus replied that was right.

LTC Knott then addressed the issue of why NGB feels the IART needs a professional facilitator. He said that the need was two-fold. First, based on the AO#3, based on the "workload" of what the group is trying to get done here, a trained facilitator is needed for time management, to make the meeting run on time, and handle the diverse and increased work load. He explained that this would effectively use the minimum amount of time the team had as efficiently as possible. Secondly, AO#3 has brought to light that the perception of people who do not sit at the table is that it is an EPA-run IART and EPA-run team, with Ms. Frawley of the EPA as facilitator. LTC Knott explained that it pertains to the comments that we are trying to bring in more people to come to the IART meetings. He stated that the current audience makeup was probably 95% contractors, so the IART needs to do whatever it can to increase our forum. For the community involvement we are bringing out now through AO#3, NGB feels that it is definitely an issue if people feel comfortable that the facilitator is neutral, not an EPA employee, and they feel more comfortable that if we "characters" get out of hand sometimes, it will be controlled by the professional facilitator. LTC Knott summarized that the two-fold reasons were (1) increased work load and time management, which a trained professional is supposed to be able to handle, and (2) in an effort to open up the IART forum to more people, the public would feel comfortable with a neutral party so that some people's views will not be attacked in this forum when they give a response, and a trained professional will be able to control that.

Dr. Feigenbaum commented that the proposal comes from the NGB, and he stated that LTC Knott was saying that there are unnamed people who feel that if Ms. Frawley runs the meeting they are going to be attacked. Dr. Feigenbaum said this has not happened, we have had people speak for half an hour about the Bourne town dump and no one attacked that person, the team waited for that person to make that comment germane to the IART's discussions. He said that he thinks that people have been treated with courtesy, and does not think team members have gotten out of hand. Dr. Feigenbaum stated that LTC Knott has gotten hot under the collar once in a while, and recalled the meeting late last spring when the team negotiated out the document to go to the legislature about the study. He said that that meeting had been three hours of hard bargaining, was productive and everyone left feeling that they had given something. Dr. Feigenbaum added that bringing in a facilitator simply brings in another set of interests, and that person is going to come in and make work for themselves to justify their operation. He said that the first thing a professional facilitator would do is conduct a survey and find out what everybody thinks because they do not know. He said that the facilitator would not know any of the players or any of the issues. Dr. Feigenbaum commented that he did not have the time to go through a survey process again and it was a waste of time. He stated if NGB had a concrete, substantive reason to show the team why the process is not working, LTC Knott should lay it out. Dr. Feigenbaum commented that just to say that there are some unnamed people who think the IART is an EPA-dominated show was not an argument. He added that if the NGB looked at their side of the table, a majority of the team was made up of military folks. He noted that the rest of the team was made of Ms. Frawley, three EPA personnel, and a handful of citizens. Dr. Feigenbaum commented that if there was need for more citizens, the team should get them, but that having a professional facilitator would not make that happen.

Mr. Kinney commented that this type of discussion was the type of thing to avoid if the team wanted to better manage time and get more accomplished at the meeting. He said that he did not see a problem with the way the meetings are run, and that of all the meetings he has gone to this is probably one of the best run meetings. He stated that some of the professional facilitators he has seen at other meetings did not get things to flow or give people a chance to speak. He said he did not see that a professional facilitator would make a big difference in how the IART operates. Mr. Kinney said he did not want to go through the process of interviewing and hiring a facilitator. He suggested that to improve the flow of the IART meetings, instead of having the contractors read the slide presentations, the information be encapsulated so that they just touched on important points. Mr. Kinney said that in terms of conversational flow he did not see a problem. He added that in terms of a political problem NGB may have with EPA having the chair, he did not see that affecting the process of getting to agreement on the issues.

LTC Knott commented that he thinks it is clear that the citizen members of the IART are opposed to NGB's and MAARNG's position that the IART needs a neutral third party facilitator. He stated that he would like to hear if EPA and MA DEP are also opposed.

Mr. Walsh-Rogalski stated that this request for a third party facilitator grew out of a perception that the IART meetings were hostile to people who did not agree with the sentiments of the activists, that it was not a meeting that people could come to and safely express opposing views, and that the meeting was dominated by EPA. He commented that he does not personally feel that way, in his personal experiences the only meeting he has been attacked at was one run by the SMB. Mr. Walsh-Rogalski stated that the perception exists, however, and in order to avoid even the perception that the IART meetings are an unfriendly place, EPA does not oppose the idea of a third party facilitator although EPA does not necessarily support it. Mr. Walsh- Rogalski said that if it would bring more people in and do away with the perception of the IART as a hostile place where one cannot be heard, then EPA would say let's do away with that perception, at the cost of creating a little more process.

Mr. Pinaud stated that MA DEP likes Ms. Frawley and that she does a great job, but that the meetings go long many times and sometimes they get a little out of control. Mr. Pinaud said MA DEP was not opposed to Ms. Frawley acting as facilitator and was not opposed to another facilitator coming in. He added that he would say that if Ms. Frawley remains the facilitator, ground rules should be developed on how meetings would be run to make sure they are kept on time in order to get the information and feedback needed to get the work done as a team.

Mr. Gonser commented that he would like to add that last week he was out at a conference in California, where all the Department of Defense (DoD) organizations got together to talk about their environmental programs. He said that there were a number of different seminars and briefings presented by Navy folks who had gone through a similar discussion, who were generally very positive about a professional facilitator running their meeting. He stated that they felt it moved the process a bit better and the facilitator generally gained consensus on some tough issues a little faster. He said that the Navy was pitching that as something DoD should do. Mr. Gonser said he knows of a number of cases where people were pleased with professional facilitators; however, it was indicated that the facilitator needs to be aware of the issues involved, do a lot of homework to get up to speed, and also needs to be a professional team builder, always looking for ways to bring the team together to work more cooperatively.

Mr. Dow commented that as a citizen who attends a lot of these meetings, his personal opinion that the reason the IART meetings were not well attended was that most of the meetings were held on the Base. He added that another problem was that the meetings are not well advertised and most citizens do not know when they occur. Mr. Dow said that a third reason was that there is a lot of techno-babble that goes on that is way beyond many of the citizens. Mr. Dow commented that if the IART addressed those three problems, rather than worrying about the facilitator, the IART would get greater citizen involvement.

Ms. Crocker commented that she was speaking tonight as a citizen advocate and a representative of the community. Mrs. Crocker recommended that the IART have a neutral facilitator and also more representative community citizens on the IART. She said that she sees no problems having the meetings held on the Base.

Ms. Crocker stated she had a further request to enter a prepared statement into the record. Ms. Frawley asked if the statement was for this part of the meeting or for the public comment period on the RRA. Ms. Crocker replied that it was not on the RRA. Ms. Frawley said Ms. Crocker might do so.

Ms. Crocker commented that, regarding the process the IART goes through, in her opinion the IART has not, to date, reached the broad community with the full breadth of truth, nor have they carried a proper representation of public opinion. She said that the IART's citizen representation on this matter has been narrow-minded, does not represent the motivations, needs, wishes and desires of the body politic, the majority of knowledgeable people on Cape Cod, many of whom are moderate and do not do activist work. Ms. Crocker stated she had her prepared statement and that part of it involves a statement from Mr. Ahmed Mustafa. She explained that Mr. Mustafa was a retiree from the U.S. military and the Massachusetts State Police, was a graduate of the Explosive Ordnance Disposal School of Indian Head, MD and also the Federal Bureau of Investigation (FBI) School for Explosives of Huntsville, AL. She said she did not have it in hand now, and asked if she could fax it to someone. Ms. Frawley replied that Mrs. Crocker could forward the materials to Ms. Cenedella at Operational Technologies Corporation. Ms. Cenedella gave the fax number and stated that she would forward the documentation to whoever else requested it. Ms. Frawley added that the documentation would be included in the minutes.

LTC Knott said, to summarize, the key point was the perception of the IART as a hostile venue. He added that we were all talking about community involvement and that although everyone at the table felt the IART worked successfully, there is a problem outside this room. He said that to address that issue, NGB had looked for a third party neutral facilitator to get rid of that perception.

Mr. Kinney commented that if there really is a perception that is preventing people from joining the IART, this issue needs to be addressed. He said that somehow he hopes the IART can figure out a way to get this neutral facilitator in a way that does not take up two or three IART meetings. He explained that the process becomes a real waste of time, instead of getting to the business at hand. Mr. Kinney stated that everyone was free to be a part of the IART meetings and that he thought Mr. Dow hit on some important points: (1) there is a lot of technical talk that some people cannot deal with; and (2) the meetings go on too long. He added that if the perception keeps people from coming, it had to be addressed and he guessed that a neutral facilitator would do that. He requested that if the IART took that approach they do it in some way to reduce the lengthy process.

Dr. Feigenbaum commented that he was wary of any argument based on some ill-defined concept of people's perception. He stated that he did not know who the NGB was talking about, as he spends a lot more time in the community than LTC Knott does, and the people that he meets in his day-to-day activities were not complaining about the fact that they are not treated hospitably at the IART meetings. Dr. Feigenbaum noted that the ATSDR CAP was a highly facilitated meeting and goes on much longer than the IART meetings, gets practically nothing done, and the community generally does not come because they are bored to death. He explained that the community was bored because of all the process that goes on between the facilitator and the various agencies. Dr. Feigenbaum asked that people come to a highly facilitated meeting before making a decision about whether a new facilitator would improve matters. Dr. Feigenbaum stated that he takes exception to any inference that anybody has ever come to an IART meeting and been treated unkindly.

Mr. Schlesinger asked the EPA if they had received letters from members of the public who asked to be on the IART and were denied access or their application not considered for any reason. Mr. Walsh-Rogalski replied no, but in the context of discussion of how this group functions, there has been some discussion about what happens if someone else wants to join. He stated that EPA's general thought has been to follow the model used when Mr. Schlesinger joined. He explained that when Mr. Schlesinger joined, he gave the EPA a letter of interest and a resume and a discussion ensued about what added value Mr. Schlesinger would bring to the IART, then there was a vote. Mr. Walsh-Rogalski said he has talked to Mr. Pinaud about getting someone from the Executive Office of Environmental Affairs (EOEA) as a member of the IART or the new landlord agencies as they clearly have an interest and are not represented. He added that the IART should think about a process for expanding because there are expanding interests.

Mr. Zanis asked if, when Mr. Walsh-Rogalski referred to the vote, he meant the whole IART. Mr. Walsh-Rogalski replied that was correct.

LTC Knott stated that, to reiterate, there are all kinds of things that can be done to deal with the perception but the bottom line is to get more people at the IART table and more input from the community, and fill the audience up with people NGB does not pay. He stated that this was one small piece of it, but it is a piece of it. He added that although he agreed with Mr. Kinney's statement regarding wasting time, he warned against speeding up the process of hiring a neutral facilitator too fast, as the key was to find someone the entire team was happy with. LTC Knott stated that the money was available to hire a neutral facilitator, and as quickly as the IART could find an acceptable candidate, he would sign a contract.

Dr. Feigenbaum said that he has not heard anything negative and he would love to have a lot more citizens in the audience. He asked if all the public affairs people in the audience could have a meeting to figure out how to get more people to attend. LTC Knott commented that next Friday morning the EPA, MA DEP and NGB were meeting as part of the Community Involvement Plan to try to do that. He stated that again, what was key was that no matter what the politics are or what we feel, we have to get more people attending the IART. He explained that the IART has to get more people from the communities in here to resolve the issues, especially regarding AO#3. Dr. Feigenbaum said all were in agreement on that. He said that the only thing is, he has been trying very hard to understand LTC Knott and usually is able to get some basic level of understanding , but he still does not understand how the compilation of arguments LTC Knott made relates to having a third party facilitator. Dr. Feigenbaum stated that he had the experience and LTC Knott did not and that it would not help. LTC Knott replied that he would have an argument with Dr. Feigenbaum saying it would not help before it is done. He reiterated that this was one of the many pieces of the pie that would have to be added to make the RRA work. LTC Knott stated that a neutral third party facilitator would go a long way towards changing the perception that this group is a little hostile to other people in getting here, or not as conducive to those people coming. Dr. Feigenbaum stated that he has only heard that perception articulated by LTC Knott, and indirectly by a couple of selectman on the SMB, which included three people on the whole Upper Cape who hold that perception that somehow Ms. Frawley's facilitating creates a perception of hostility. He said that it did not make sense. Dr. Feigenbaum asked the NGB to reconsider, and that he sees the EPA wants to accommodate the NGB, but the citizen members have a strong interest in how the IART meetings are run and have lived with some bad meetings run by professional facilitators. Dr. Feigenbaum stated that was his last statement unless LTC Knott again accused the citizen members of creating hostility.

Mr. Schlesinger suggested that one of the local cable companies video the IART proceedings and put in on the local cable channels, thereby extending the meeting to others. He explained that there were lots of people who watch the local broadcast channels. LTC Knott commented that this option and also access through the Internet were being discussed, to give the public as many avenues as possible to hear and respond to the IART.

Agenda Item #4. Investigations Update
(See Attachment #5)

Mr. Grant referred to the handout at the IART table dated April 5, 2000 and stated he had extras for anyone who wanted one. He noted that the last update had been March 8, 2000. He said that Ogden has been going through the areas they investigated in the last month, and he would present an update on the new wells installed and the results received.

Mr. Grant reported that Ogden installed seven new borings in the Impact Area. He said that the wells Ogden has been installing were in reply to the RDX Response Plan, which came out in January 2000. He noted that in that Plan, the wells had been shown in red, and reported that Ogden has been coloring them in green as the wells are completed, and has been changing them from the "P" designation in the Plan and giving them monitoring well names. Mr. Grant reported that the wells installed in the last month include monitoring well (MW)-88 on the outer transect, MW-89, MW-90 and MW-91 on the inner transect, MW-92 just south of five corners, MW-93 on the inner transect, and, as complete data would be available on MW-94 tomorrow, that was also shown as installed.

Mr. Grant reported that Ogden was also working on wells at the Mortar Target (MT) locations. He referred the IART to Figure 1 in the handout, which was a close-up of the southwest side of the Impact Area. He explained that two wells had been proposed for that area, and noted that PMT-2 was located in the vicinity of MT-9 and MT-10. He stated that MT-9 was of primary interest because of the high RDX levels detected there. He reported that PMT-1 was installed downgradient of MT-5, MT-6 and MT-4. Mr. Grant added that MT-5 and MT-6 had detections of RDX contamination. He stated that Ogden was profiling at about 100 feet, so even though it was some distance from the targets, they would be profiling through the portion of the aquifer where the water enters the water table and passes through on its way out of the Impact Area.

Mr. Grant reported on the well sampling. He explained that there are different categories of wells and that the oldest installations have had three rounds of sampling completed. He noted that the sampling plans always specified at least three rounds of sampling. He went on to say that more recent installations, like Far Field Group 2 wells, the Gun and Mortar wells, or the Demo Area 1 wells, which had all been installed since October 1999, have had either one or two rounds of data completed. Mr. Grant said Ogden was continuing on to get the third round of data for those wells.

Mr. Grant stated that after three rounds of data had been completed, Ogden would be collecting additional sampling from most of these wells. He explained that the plan governing that work was the Draft Interim Long-Term Monitoring Plan, issued March 2000, which was under review at the agencies. He added that the Plan had been discussed at one of the technical meetings, EPA had offered some verbal comments, and written comments were due shortly. Mr. Grant said that the Plan runs through all the wells that have three rounds of data, describes what Ogden thinks are important constituents of interest and which wells should be monitored because they are near zones of contamination and proposes sampling frequencies for those wells. Mr. Grant said that the Plan had been distributed to the IART and that he assumes the comment period is still open to the public.

Mr. Grant moved on to detections of explosives in groundwater. He invited Mr. Zanis to present his photograph on the overhead projector when appropriate. Mr. Grant then referred to Figure 6 in the handout. He stated that, in the word slide, the first bullet referenced results in the inner transect, while the second bullet referenced results in the outer transect. Mr. Grant explained that what Ogden was doing here was a series of response wells based on the Phase 1 results where RDX contamination was detected in several areas. He noted that the colored lines on Figure 6 represent the groundwater flow path that RDX would take if it moved from well to well. Mr. Grant reported that in the case of MW-1 there were RDX detections at the water table and somewhat below the water table, so the figure shows the paths the RDX would take and where the detection below the water table would originate. Mr. Grant said that, based on the Phase 1 results, Ogden decided to install a series of wells along two transects, one along the western boundary of the Impact Area and one along the center of the Impact Area. He stated that the purpose of the installation was to delineate the extent of RDX in this area. He added that he would say that Ogden is not surprised to be getting RDX in these wells.

Mr. Grant reported that Ogden was finding similar levels of contamination in MW-91 and MW-85. He stated that the detections have been found somewhat below the water table, suggesting that the source of the contamination resides off to the east a little bit. He added that somewhat lower levels of contamination had been found in MW-90 and MW-92. Mr. Grant reported that the levels in MW-90 and MW-92 are close to or below the health advisory (HA). He report that the levels in MW-85, MW-91 and MW-93 were above the HA, the detection being in the range of 7-20 parts per billion (ppb). He added that the detections in MW-90 and MW-92 had been in the range of 1-3 ppb.

Mr. Grant said that Ogden was starting to get a sense of possibly different zones of contamination in the Impact Area, and that it may not be a single continuous area of contamination. He added that Ogden was also getting the sense that much of the contamination seems to originate from a location back towards Tank Alley, either north or south of Tank Alley. Mr. Zanis asked Mr. Grant to indicate the area where the wells were located on the photograph, which he did. Mr. Grant reported that the levels of contamination are the highest at a level of between 20-70 feet below the water table and that there is sort of a broad range within the depth of the aquifer. Mr. Grant stated that based on Ogden's understanding of how groundwater moves, the source of the contaminant could be as far back as Tank Alley.

Mr. Schlesinger asked if, as the IART gained knowledge about the width of the material traveling along that general line, the boundaries could be drawn wider, and suggested a dotted line to indicate a particular track. He explained that the current map asks that anyone looking remember all of the various hits and their locations, which is quite difficult. Mr. Grant said that Mr. Schlesinger's suggestion could be taken back to the technical meetings for discussion. Mr. Grant stated that he would say it is not evident to him what the zone of contamination is at this point, it is rather confusing, and it appears to be in a general area but with possibly somewhat separate zones. Mr. Grant said that, similar to what had been done with Demo Area 1, the goal is to be able to define a plume.

Mr. Hugus commented that if a plume shell were drawn on the map it would be easier to understand. Mr. Grant said that a plume assumes that one has fairly homogeneous distribution within it and it is coming from a common source area. He added that it was not clear to him or the agencies yet that there is a sole common source area and that there could be multiple sources.

Dr. Feigenbaum asked where the top of the aquifer was located. Mr. Grant replied that the top of the mound was in the vicinity of the J Ranges. Mr. Grant replied that as one got closer to the top of the mound there is a stronger vertical gradient. He explained that the groundwater would move quickly down below land surface from the top of the mound and start to flatten out as it comes out to the west. Dr. Feigenbaum asked if the horizontal gradient was smaller. Mr. Grant replied that groundwater was moving deeper into the aquifer at the rate of between 1-100 feet and 1-60 feet and was moving deeper very slowly as it moves out to the west. Dr. Feigenbaum commented that it was moving deeper but it was not moving quickly to the west. Mr. Grant asked if Dr. Feigenbaum mean in terms of speed. Dr. Feigenbaum said yes. Mr. Grant said that he does not think the speed varies a lot over the area, but he thinks the range was a couple of feet per day.

Mr. Kinney asked if Mr. Grant would say at this point, considering the findings of contamination at various levels and depths in the aquifer and at a pretty wide expanse, that his hypothesis now would be that there are multiple source areas. For instance, there may be a plume from Chemical Spill (CS) 19, but the other ones are more scattered and are the result of using the artillery and mortar ranges and not the result of dumping activities, but the result of something much more widespread. Mr. Grant replied that Mr. Kinney's hypothesis was feasible and that there would have to be several dumping activities over a fairly large area to generate these levels.

Mr. Grant stated that in terms of the outer transect, Ogden was seeing the highest levels at MW-87, which had a detection of around 34 ppb. He added that MW-88 and MW-89 had fairly consistent levels, with detections of 8-9 ppb. Mr. Grant said that, again, the findings at depth at these locations were consistent with particle backtracks to a source area in the vicinity of Turpentine Road or possibly even Tank Alley. He stated that these results were very supportive of what Ogden had been seeing on the inner transect, in terms of contamination moving out to the west.

Mr. Grant reported that, based on these findings and considering the fact that no RDX had been detected at MW-39, Ogden has decided to relocate some of the proposed wells, and has already reached agreement with the agencies to relocate P-21 and move it up in the drilling schedule. He stated that P-21 will be located downgradient of MW-87 and will be one of the next wells drilled.

Mr. Zanis asked if Mr. Grant would finally agree with the Department of the Army's Environmental Assessment which states in the section on water that "contamination due to runoff into a body of water or leachate into the groundwater could occur as a result of residual high explosives (HE) left on the ground." Mr. Zanis said that the Assessment was talking about the 81mm HE left on the ground. Mr. Zanis continued and read, "However, as stated above, this would be caused by the cumulative impact rather than the functioning of the 81mm mortar, and the sites are responsible for controlling such contamination." Mr. Grant asked Mr. Zanis if the report was saying that there was cumulative residual accumulating over a long time. Mr. Zanis said yes, and that when the Report talks about the soil it pretty much says the same thing. Mr. Grant commented that, at this point, the data are probably equally supportive of an UXO contribution to the source. Mr. Zanis replied no, this was talking about the normal function of the HE. Mr. Grant said he knew what Mr. Zanis was saying and stated that he thought there were a couple of possible theories, one is that normal functioning spreads residue and the other is that a mis-function creating an UXO creates a point source. Mr. Zanis said that the Report states "Residuals resulting from the functioning of a standard HE ammunition are expected." Mr. Grant said he was not that familiar with that reference but he could take a look at it. Mr. Zanis added that the report also states "Sites are responsible for their cleanup."

Dr. Feigenbaum asked Mr. Grant to repeat what he had said on the data being consistent with the results of artillery practice, explosion of high-yield rounds or leaking from UXOs. He said that that would mean that we would want to get rid of such UXOs if they are the source. Mr. Grant said at this point, there is not enough data to tell between the two theories, and it could be both sources working at different levels. Mr. Grant stated that basically all the data is saying is that there is a source area where we know a lot of munitions were fired.

Mr. Schlesinger asked how much effort would be expended to locate the source area right now. He asked why Ogden was not trying to pinpoint the source and eliminate it. Mr. Grant replied that this had always been part of the Response Plan and that he thinks that one of the reasons for the interior well transect was to try to get closer to the source. He added that it was fairly difficult, when drilling way out to the west; it is easy to find the front edge of things if the drilling is concentrated out there, but it is hard to extend the model all the way back to the source. He explained that what you want to do is work on both ends, try to see how far the contamination has gotten and also work close to the source and try to see how exact you are. Mr. Grant added that in terms of additional work to be done, this was a follow-on to Phase 1. There will be follow-up work to this and a report will be developed when the work is completed, and there will probably be planning going on as that report is written.

Ms. Culligan asked Mr. Grant to repeat the upstream and downstream concentrations. Mr. Grant replied that for the downstream concentration the high was 34 ppb; and noted that these are profile samples collected during drilling. He reported that MW-88 and MW-89 were in the range of 8-9 ppb; the highest was MW-91 with 20 ppb, and MW-85 was similar with 17 ppb. Ms. Culligan noted that the concentrations downstream were higher than upstream and asked Mr. Grant to explain. Mr. Grant replied that it was probably movement of the contamination away from the source area, with a reduced source. Ms. Culligan asked if Ogden was hypothesizing that there is a source that is reducing contamination. Mr. Grant replied that it could be a source that is gradually being depleted. He added that he does not think those concentrations are a lot different in the real scheme of things. Considering that there is a lot of distance in between and there is distance between the wells, who is to say that there is not a higher concentration 50 feet away from MW-91. But, if Ms. Culligan were talking some order of magnitude, it is probably not too much different. Ms. Culligan commented that with that variability and concentration, which she agreed was very small, it should be possible to put boundaries on where the contamination is. She added that she did not think much could be inferred by the fact that there is a lower contamination in the middle well section downstream. Mr. Grant replied that the difficulty at this point was that Ogden was not finding continuous levels of contamination through the area, so it was not clear that there is a continuous source in the area creating a fairly large plume, it could be several separate zones of contamination. Ms. Culligan said she would agree but that she did not think that should stop Ogden from bounding the area. Mr. Grant asked if Ms. Culligan meant putting an envelope around the whole thing -- he said that this could be discussed.

Mr. Borci commented that this issue has been discussed in the technical meetings. He stated that part of the problem is that the data is profiling data. Mr. Borci said that he is more comfortable in using monitoring well data, providing solid numbers to base boundaries on. He added that the second issue comes in as to where and how you draw the boundaries. He said that ground rules need to be developed on how to do that. Mr. Borci noted that the IART had been lucky with Demo Area 1 as it had pretty clear boundaries, but in this section of the Impact Area boundaries would be a bit of a problem. Mr. Borci suggested that how to define plumes in the future was something that should be discussed at a future IART meeting. Mr. Borci reiterated that EPA was waiting on monitoring well data before making any of those determinations.

Ms. Culligan said that the suggestion is not because we are going to be drawing conclusions from this, it is just that there is a lot of time and effort that goes into trying to interpret points put on maps, and she thought we could all come to a better understanding if we had some boundaries.

Mr. Cambareri asked if Mr. Grant had stated there was a detection at MW-92. Mr. Grant replied that the detection at MW-92 was about 1 ppb. Mr. Camberari asked what the detection had been at MW-2. Mr. Grant replied that the detection at MW-2 had been 13 ppb. He added that the detections at MW-26 and MW-59 were closer to the water table and were very low, about 1 ppb.

Mr. Cambareri commented that, when discussing plumes, he would be concerned about interpretation when there are low contaminant concentrations, such as that at MW-92, where it may be at the end of an area of contamination, and just may be one of those sporadically low ones. Mr. Cambareri said that he continues to agree with Mr. Hugus that the upper northwest quadrant is sparse with wells and thinks that, at some point, the investigation needs to be expanded through that northwest quadrant, given the sporadic nature of concentrations.

Mr. Cambareri asked if Mr. Grant had stated that there had been a hit at MW-85 and MW-37, the upgradient well to CS-19. Mr. Grant said yes. Dr. Feigenbaum asked what the detection had been at MW-37. Mr. Grant replied 2-4 ppb, backtracking somewhere south of the Tank Alley area. Dr. Feigenbaum asked what the detection had been at MW-85. Mr. Grant replied that MW-85 had a detection of 17 ppb.

Mr. Cambareri stated that it looks like good data, confirming a hypothesis of a major non-point source of contamination in that whole Impact Area. He said he was excited about the results of the wells.

Mr. Grant then illustrated the points made in the conversation on Mr. Zanis' photograph.

Mr. Hugus stated that he wanted to make a comment for the record. He said that Mr. Zanis' first photograph showed the Impact Area and you can see that it is just chock full of craters from bombardment with artillery, mortar and everything else. He added that from his point of view, what we are looking at is many, many point sources, which add up to one large source area. Mr. Hugus stated that he thinks that this is the explanation for all the variations among different points. Mr. Hugus commented that the Impact Area is a large source area made up of a multitude of different points and stated that he agrees with Ms. Culligan's comment that it is time to put boundaries on these detections. He said that it was impossible for anyone but Mr. Grant to tell you what the levels are at all these different sites. He added that he read a comment that maybe these plumes could be delineated by using shading so that the IART understands that the darker shades are higher concentrations. Mr. Hugus stated that the IART has been asking to have the plumes delineated for a long time. Mr. Hugus stated he was making a request to have this done.

Mr. Schlesinger said he also thinks it is important to start delineating something; the point is that the public will believe there are no plumes in the Impact Area if the plumes are not delineated.

Mr. Borci said he would take that back for discussion at a technical meeting. He stated that the comment Mr. Hugus was referring to was from two previous technical meetings where there was discussion about the possibility of defining plume boundaries by three gradations of color. Mr. Borci added that because of the scarcity of wells, the definition would consist of the first, lighter shade being a detection up to the HA. Mr. Borci, citing RDX as an example, explained that the first shading would be any detection up to 2 ppb; the second shading would be any detection of 2-10 ppb; and the third shading would be any detection above 10 ppb. Mr. Borci said he chose those levels based on what was seen from the data, as anything above 10 ppb is not seen often and it would be important to note where that is on a map and plan view. He added that this was being discussed.

Mr. Gschwend commented that he agrees with Mr. Grant's general comments. He said that he was not so sure that 10 ppb and 30 ppb are even that different at this level of what is understood. Mr. Gschwend stated that working to boundaries like that would be premature, and said that he would vote to say that you have hits and you have the absence of hits, which is about all you can do at this point, unless Mr. Grant thinks there is more precision than that. Mr. Grant said no. Mr. Borci said that what EPA was discussing was further down the road, when more sampling data was available, and Mr. Gschwend agreed. Mr. Gschwend said that at this point, Mr. Grant is indicating the places for further study, which he would hope everyone would understand.

Mr. Hugus commented that there were other places like Demo Area 1which are a lot better understood. Mr. Gschwend replied that he was not looking at Demo Area 1, he was looking at the presentation right now and was hearing Mr. Hugus say that he wanted a plume boundary. Mr. Gschwend said he was agreeing with what Mr. Grant was saying; i.e., "it is roughly like this, and I do not know much more than that." Mr. Hugus stated that we could get a plume boundary at Demo Area 1.

Mr. Kinney asked if, when Mr. Grant was talking about the hits, he was speaking strictly about RDX. Mr. Grant replied yes, but there had been HMX detections below the HA, and TNT and TNT breakdown products generally below HAs. Mr. Kinney asked if Mr. Grant was saying that RDX appears to be the one contaminant of concern. Mr. Grant replied that RDX appears to be the primary threat to drinking water. Mr. Kinney said that he was bringing this up because it was important in terms of future water sources for the Upper Cape. The IART has to be concerned not just about a single element. In the discussions we have had with the IRP over the years, even if we got to the point of drawing a plume map, they would base it on 5 ppb of tricholoroethylene (TCE), draw a map and everybody walked away from the meeting thinking that is the contaminant, when there were other analytes of concern. Mr. Kinney said that in talking about future water sources we do need to be concerned about the combination of all contaminants, even if they are at real low levels. He asked if there were any conversations among the regulators and Ogden on how to address this concern. Mr. Grant said that if there is, he has not heard it. Mr. Grant said he thinks it is recognized that the constituents generally move together but that there are some that are faster, HMX and RDX being faster than TNT. He added that there has not been a lot of discussion about remediation scenarios, as the study is still in the early stages of trying to figure out where the contamination is. Mr. Borci said, to follow up on what he had said earlier about how the shades would be drawn; for example, a hit of HMX below the HA would still appear on a map and would not be lost.

Mr. Gordy commented that Mr. Grant had not mentioned anything about the wells farther to the west. He said that if the IART were going to delineate plumes, it would be more important to get out of the bull's eye where all the impact has been made; Ogden would have to go farther west to identify a plume of any sort or consequence.

Mr. Gordy said that, as far as public supply wells on the Base are concerned, PACERS has maintained for a long time that they are unnecessary, because if you examine the data in the EarthTech report you will find that the criteria was unnecessarily constrained. He said that there really is not going to be any water shortage by the year 2020 because that report cut below the maximums by 60%. He said that PACERS has asked many times for a peer evaluation of the report, and has not gotten any satisfactory answers. A full presentation was given in January 2000 before the JPO and the group has not gotten a satisfactory answer on that. The group enumerated a vast number of deficiencies in that report, and he thinks that the public should be informed that there is not any such water shortage facing the Upper Cape, especially towns like Bourne, Sandwich and Mashpee. He noted that Falmouth does have a problem, but the problem is that all the well sites in Falmouth have been judged to be threatened by Falmouth itself, without any real justification or any kind of particle tracking or testing done to show that those well sites are actually threatened. Mr. Gordy stated two points: first, there is no water shortage and he dared anyone to debate him on that, and, secondly, as you go farther to the west, less contamination would be found. Mr. Gordy stated that he thinks there should be some more wells out there if the IART is really looking for plumes.

Dr. Feigenbaum commented that it would be good to have plume boundaries delineated but, if it is not intellectually the correct thing to do, the team could live without it for a little while. He stated that he was really concerned with getting more wells in the ground, as Mr. Cambareri said, up in the north. Dr. Feigenbaum asked if MW-87 had a detection of 37 ppb. Mr. Grant said yes. Dr. Feigenbaum asked if it would be advisable to place wells upgradient and downgradient of MW-87, because we know that at these points the results are suggestive but sporadic, but we need something in between MW-90 and MW-87. Mr. Grant said that his opinion would be that the IART would be better off continuing to work on the two ends than working in the middle. Dr. Feigenbaum stated that Mr. Grant hears from team members and the advisors an urgent request for something that resembles a plume outline there so that the team can look at it, and the only way to do that is to install more wells. He asked what the distance was between the two fences. Mr. Borci said it was just under 4,000 feet. Dr. Feigenbaum commented that by IRP standards this was hardly a response action. Mr. Borci replied that Dr. Feigenbaum had to keep this in perspective, this was the first cut at trying to delineate what is out there. He stated that for a first cut, we have done pretty well, we have two fences fairly far apart, and it is very disconcerting for the regulators to see higher concentrations as we go out. Mr. Borci said he wished there were wells farther west, because it is a concern. Mr. Borci explained that 21 wells were budgeted and that EPA was trying to use those as best they can, but there will be follow-up action. Dr. Feigenbaum said that he wanted to urge the installation of more wells. He added that the principal role of public representatives was to say that obviously we need more wells, so let's get to it.

Mr. Grant said that the IART would shortly be receiving the draft FS Work Plan that includes the central Impact Area as the location where feasibility study activities will occur according to AO#3. He explained that Ogden was proposing that this not be the sole basis of the siting of screening technologies and other remedies for this area. Mr. Grant said that the Work Plan proposes development of additional response wells, which would start in May 2000. Dr. Feigenbaum asked if this was finishing Phase 1 or Phase 2. Mr. Grant said he did not keep track, but it could be Phase 2. Dr. Feigenbaum asked if we were moving to Phase 3. Mr. Borci replied that it was Phase 2A.

Mr. Zanis asked if Mr. Grant could point out the well farthest downgradient from the bull's eye where there had been an RDX detection. Mr. Grant did so and noted that some of them were the Far Field Group 1 wells. Mr. Zanis asked how far the contamination had traveled. Mr. Grant replied that it had traveled approximately 6,000-8,000 feet.

Mr. Schlesinger commented that Mr. Grant could not rule out the fact that there were many sources in the Impact Area, and said that Mr. Grant had answered Ms. Culligan's question with the fact that the larger downgradient concentration meant perhaps something had moved past. Mr. Grant said there was not much that could be ruled out at this point.

Mr. Grant moved on to the soil data. He said that was not a lot to report since last month, but that there had been a couple of new soil detections. He reported that one was from a series of four composite samples taken near mortar targets. He explained that the purpose of these was to the place them under the target with the idea that different levels may be seen than when we are sampling around the target, since there would be less precipitation and filtration in those areas. Mr. Grant said he was not sure the levels were a whole lot different from what had been seen around the targets, but that the results would be part of a technical memorandum Ogden would be preparing in the next couple of months.

Mr. Grant reported that Ogden found that MT-8 had an RDX detection of 170 ppb. He reported that there had been no detections at the three other targets Ogden looked at.

Mr. Grant reported that there had also been an explosives detection at one of the craters, as the result of a detonation event. He explained that two detonations occurred on March 3, 2000 and that RDX, TNT and TNT breakdown products were detected at a crater where a 37mm round was exploded. He added that a 3.5-inch rocket was exploded the same day, but there were no detections there.

Mr. Grant stated that later in the month there were three more open detonations, consisting of two 3.5-inch rockets and a 4.2-inch mortar. He reported that none of those detonations had detections.

Mr. Grant said that Ogden has taken the precaution of placing plastic over the crater to prevent rain infiltration until delineation is completed and any removal of soil occurs.

Mr. Grant stated that he would next give a quick summary on the steel-lined pit, as had been requested. He reported that the steel-lined pit was located at the southeast corner of the Impact Area, where Tank Alley enters the Impact Area and along the J-1 Range, which was an area used by Textron and other contractors. He stated that this pit had been full of soil and munitions debris when it was discovered. He described it as a three-sided steel structure with a steel bottom, with a 10-inch-square hole cut in the bottom. He said it appears that it had been used for detonation or burning off of munitions and was located adjacent to 150-meter and 1,000-meter ranges so may have been taking UXO from those berms.

Mr. Grant reported that, in Phase 1, samples had been taken from the soils around the surface of the outside of the pit, which is level with the top of the steel walls. He said that those samples had been non-detect for explosives. Mr. Grant said that soil samples taken from beneath the hole in the center were non-detect for explosives. He reported that the soil sample commingled with the munitions had a high RDX detection of 24,000 ppb, which was the highest detection for Phase 1 at that time. Mr. Grant said that the material had been put into drums and is also the subject of an RRA, as Mr. Veenstra had mentioned.

Mr. Grant said that subsequently, under Phase 2, the groundwater was investigated. He reported that a water table well had been installed nearby and that Ogden installed several borings along the open edge of the pit. He stated that a composite sample was taken from along the lip of the pit in between Phase 1 and Phase 2, and then Ogden did the borings, which were sampled at 1-foot intervals below the bottom of the pit. The intervals were composited across the borings to create a depth-wise composite, adjacent to the lip and then 3 feet away. He stated that these soil samples were non-detect for explosives.

Mr. Grant reported that the water table well had an RDX detection of 3.7 ppb. He added that there were other activities going on in the area which could contribute to that, but that it seems fairly likely that the detection was somewhat related to the steel-lined pit, considering the RDX level found in the soil.

Mr. Grant went on to say that Ogden is proposing to continue investigations in this area under the J Range Work Plan, unless the agencies say otherwise, as this area is inside the J-1 Range. He stated that the soil in the drums would be taken care of under the RRA.

Mr. Schlesinger asked if the facility had been covered to prevent infiltration. Mr. Grant replied that the steel structure had been relocated a short distance away and at this point is clean, there is no soil in the structure.

Mr. Zanis asked Mr. Grant if the sampling taken below the hole in the steel-lined pit, which had no detections in the soil, told him something. Mr. Grant replied that it could be that the RDX that was in this material took another route, possibly off the open side although it has not been seen over there. He added that another possibility could be that the soil detection limit is not low enough to catch any residual material that may stay in the pour water. He explained that if RDX leaches down to the water table, it may not leave much of a trace. Mr. Zanis stated that was his thought, the RDX passed through the hole and moved on to the water table. Mr. Grant said that could be what has happened but that Ogden was not seeing RDX at depth anywhere except at Demo Area 1, where it has been 16-30 feet deep.

Mr. Zanis asked what would be done about the popper kettle across the street from the steel-lined pit. Mr. Grant asked Mr. Zanis to tell him what he would like done. Mr. Zanis replied that he would like to have it removed and the soil taken away too. He added that he had a picture if the people would like to see it. Mr. Gregson commented that the popper kettle will be removed within the next few weeks. He said that he had gone out there with Ms. Drake and Mr. Borci and some folks from Ogden. He added that it was decided to drum the contents, move the structure out and do some additional sampling beneath it. Mr. Gregson stated that any follow-up work that needs to be done to address deeper or groundwater contamination at that location would be part of the J Range Work Plan. Mr. Zanis asked if the mound of debris the kettle sits on would be removed. Mr. Gregson replied that to the extent that it is debris versus clean soil, MAARNG would remove the materials that look like fragments and debris and leave the clean soil.

Mr. Schlesinger asked if Mr. Grant fully expected that materials that leached into the ground from the steel-lined pit have fully traveled to the groundwater so that there is no more to be pushed down to groundwater level. Mr. Grant replied that the typical behavior of RDX in solution was that it does not adhere to soil, so it would not be unusual for the RDX to pass through the unsaturated zone and reach the water table without leaving much of a trace to find.

Agenda Item #5. Munitions Survey Update
(See Attachment #6)

Mr. Montroy introduced himself and stated he was with TetraTech who is under contract to the NGB, working with LTC Fitzpatrick and LTC Knott. He said he would give an overview of the munitions survey project and the various tasks TetraTech has been asked to do, and give an update of what was presently being done and what TetraTech's workload would be like over the next couple of months.

Mr. Montroy stated that the Munitions Survey Project had been put together as a result of a modification to AO#1, which directed the NGB to investigate places within the training ranges and the Impact Area where there might be buried munitions that could be contributing to contamination. He added that TetraTech was focused on identifying areas where munitions may have been improperly disposed of. He said that the Plan had been developed in concert with the regulators and Ogden, so the studies were complementary and were not overlapping.

Mr. Montroy reported that TetraTech was focusing on performing detailed geophysical examinations of certain sites they wanted to characterize. He stated that he would define what he meant by "characterize a site." He explained that TetraTech was looking at discrete locations; for example, individual gun and mortar positions, and were not looking at the land surface between the positions. Mr. Montroy said that TetraTech had performed a preliminary site evaluation, gone in with the regulators and selected sites of interest and performed a surface sweep to remove any surface UXO or safety hazards. He added that, where necessary, TetraTech has had to remove vegetation which consists of primarily scrub oak and pitch pine, in order to facilitate the geophysical contractor's assessment. Mr. Montroy said that TetraTech was collecting digital data on subsurface anomalies and would perform limited excavations of anomalies in order to understand what is in the ground.

Mr. Montroy stated that there were some benefits to this iterative approach. He stated that TetraTech had started with the gun and mortar positions and learned some information about the geophysical characteristics of the area, which they had used to modify their approaches in Demo Area 1. He reported that TetraTech was now working in Demo Area 1 and was about to start in the J Ranges. He added that the new information from Demo Area 1 would help TetraTech refine their approach in the J Ranges. Mr. Montroy stated that this iterative approach's ultimate use, which he said he would call a sound scientific approach, would be to come back to the stakeholders and help them make critical decisions over the next couple of years at the MMR.

Mr. Montroy said TetraTech had a number of tasks they would be working on. He reported that TetraTech is establishing and has constructed a prove-out area, investigated gun and mortar positions, Demo Area 1, the J-Ranges, a number of ponds and water bodies, and the slit trench. Mr. Montroy stated that eventually TetraTech would fold this information into a much more aggressive study to look at potential sources of contamination in the high-use target areas.

Mr. Montroy stated that the key to what is being done in the prove-out area is geophysical examination. He explained that TetraTech was running over the ground to determine what is there and try to find anomalies. He went on to say the way TetraTech would be assured the instruments are working well is to bury some known items in the ground, know their exact locations, and then run the instruments over them to see if the instruments can detect them. Mr. Montroy said that TetraTech put together a list of items that they were likely to encounter and placed 52 items into the ground at various depths and orientations, and then took exact land survey coordinates. He added that these were all single inert items, simulated munitions caches and debris. Mr. Montroy said that TetraTech knew from the preliminary site surveys that there was a lot of metallic trash at these sites and the instruments would pick up that trash, so they felt they needed samples of this trash in the prove-out area.

Mr. Montroy said that a year ago TetraTech put together an evaluation for the NGB and EPA in which they evaluated the operational characteristics of a number of commercially available geophysical techniques. He stated that there were two or three types of technology that were probably more suited to the geology at MMR. He reported that TetraTech put out a Request for Proposal (RFP), a number of companies responded, and one was selected. He added that this company came to the TetraTech prove-out area, which is a big open field measuring 100 feet by 100 feet. Mr. Montroy said that the company was requested to survey the area and report back to TetraTech what they thought they found, and TetraTech then scored them on what they found.

Mr. Montroy went on to say that TetraTech originally thought the Cesium Vapor Magnetometer (CVM) would be highly successful at MMR, which it was. Mr. Montroy added that the EM-61 was added after running the tests, as the two technologies complemented each other. He reported that TetraTech then met with NGB and the regulators and suggested using the two technologies, at least at the gun and mortar positions and Demo Area 1, as a double-check. Mr. Montroy said he would give a summary of the two technologies and noted that the geophysical subcontractors were present to supply additional information.

Mr. Montroy explained that the CVM measures anything in the ground that has a different orientation from the north-south magnetic flux orientation of the earth. He said that a piece of metal buried in the ground is different from the magnetic field orientation of north and south, and the CVM would detect it.

Mr. Montroy stated that the EM-61 generates its own localized magnetic field and induces a current into the ground, and metals in the ground acquire the signal and report it back up to a sensor.

Mr. Montroy commented that these were two similar approaches that did different things. He reported that the CVM detects ferrous metals, whereas the EM-61 will detect all metals including brass, aluminum and some other metals. Dr. Feigenbaum asked why that was. Mr. Montroy replied that the EM-61 was inducing its own field into the ground, and aluminum and brass will pick up that field and bounce the signal back up to the sensor. Dr. Feigenbaum commented that it was an electric field. Mr. Montroy replied yes, it was generating a transient electromagnetic field that goes into the ground. Mr. Montroy said the point he was trying to make was that one uses the earth's natural magnetic field and the second one generates its own transient field and then it is released -- passive versus active.

Mr. Montroy went on to say that the CVM is sensitive too naturally occurring magnetic minerals whereas the EM-61 does not pick that up. He stated that TetraTech has some concerns that there are naturally occurring magnetic minerals in the ground at MMR. Dr. Feigenbaum noted that Mr. Montroy has stated that the EM-61 does not pick up the naturally occurring magnetic minerals. Mr. Montroy concurred, which is why TetraTech is using both technologies. He commented that TetraTech feels that if they use both technologies they will detect a greater percentage of what is there.

Dr. Feigenbaum asked if Mr. Montroy has some literature on the two technologies which includes the basics of each. Mr. Montroy replied that he could certainly get that to Dr. Feigenbaum. LTC Knott asked Mr. Montroy to get the information to Ogden so it could be put in the Weekly Report.

Mr. Montroy said that now that they are out in the field daily and are doing the geophysical survey, the prove-out area now becomes the standardization area. He explained that every day before they go out, they go out to the site, turn their instruments on and walk the same path every day. He stated that this procedure was implemented to ensure that the instrument is working correctly, the same way as it worked the day before, which becomes a very important part of the quality assurance record. He reported that TetraTech also has a black box out there so that, should there be any fluctuations in the natural magnetic field, they can be factored into the data analysis.

Mr. Montroy reported that the regulators chose 16 sites at the gun and mortar positions. He noted that the gun and mortar positions are located on the periphery of the base and that there was one site located in Camp Good News. He said that TetraTech was looking at the firing positions and their support areas and additionally, through the EPA, they realized that there are a number of paths going into the back woods. He explained that TetraTech identified and flagged those paths, went in and took out the vegetation and ran the instruments down the paths, the reasoning being that, if munitions were improperly disposed of, they might have been disposed of by troops running down the paths, digging holes, dumping the mortars into the holes and covering them up.

Mr. Montroy then displayed a photograph of a mortar position and noted that the mortar positions tend to be a smaller size because the instruments used at a mortar position were smaller than a self-propelled howitzer. He added that over the years, a clearing developed simply because of vehicles coming in and setting up. Mr. Montroy displayed a photograph of a firing position path and noted that some of the paths had been out of use for 25 years, but TetraTech was able to identify them from aerial photographs. Mr. Montroy displayed a photograph of a gun position and stated that it was typically a larger area with a lot of disruption from tracked vehicles. He noted that the vegetation shown in the photographs was of the type TetraTech had to remove to allow the geophysicists access to the area.

Mr. Montroy reported that once the gun positions had been selected, TetraTech went in with Schonstedt detectors, which are nothing more than metal detectors. He displayed a photograph of a UXO technician. He stated that the UXO technicians walked the whole area to make sure that it was safe for the geophysicists.

Mr. Montroy displayed a photograph of the EM-61 and pointed out the working parts. He stated that the EM-61 was a meter wide and the technician was walking a meter grid. He added that it would be looking fairly tightly down the one-meter-wide swath.

Mr. Montroy displayed a photograph of the CVM and stated it was handheld and the technician was also walking meter intervals. He added that they were very careful about walking a grid.

Mr. Montroy reported on the tasks that TetraTech had completed. He said that TetraTech had cleared vegetation where necessary, and had performed a significant amount of land survey control in order to put this data back into the MMR Geographic Information System (GIS) database. He added that TetraTech wanted to be able to preserve this in a digital format but also wanted to make sure they could be located in space. Mr. Montroy reported that all-16 gun and mortar position land survey control points, including the Camp Good News locations, were in place. He said that right now, TetraTech was evaluating the anomalies and preparing a work plan to help determine what becomes a target. He added that, as anomalies were simply something in the ground, a target is something that should be dug up or looked at, and the criteria is what makes the difference. Mr. Montroy reported that the TetraTech Phase 1 field work is finished, a briefing was given to the regulators a couple of weeks ago, and a draft report is scheduled for October 30, 2000.

Mr. Montroy said he wanted to talk about targets. He said that he wanted to assure the IART that the digital data being collected by the geophysicists was everything from background and above, so even after the analysis is done and we decide to raise the threshold of analysis, we still have all the data and can go back. He added that all the data is geodetically located, so TetraTech will have the latitudes and longitudes. Mr. Montroy said that TetraTech could go back to any target site probably within plus or minus a quarter of a meter.

Mr. Montroy said that TetraTech was putting together a work plan and proposing to the NGB that TetraTech would go into a couple of these sites and dig up the anomalies. He stated that the criteria were that TetraTech wants to find a site that has anomalies that were picked up only by the CVM, but not by the EM-61. He said that at that same site they want to find anomalies that were found by the EM-61 but not by the CVM, and some anomalies that were found by both. He explained that TetraTech wants to see if they can understand whether the signals received by these various geophysical instruments are characteristic of an anomaly. He said that maybe TetraTech will find that the metals here have a very characteristic signal that can be used to develop criteria for what will be dug up later on. Mr. Montroy said that each anomaly would be treated as UXO, the UXO specialist would go out to the site and dig these things up, treating each as potentially dangerous, and therefore it would be a tedious process.

Mr. Montroy displayed samples of the grids TetraTech uses. He explained that the geophysicist would walk the grids, take the data and plot it out; the triangles shown on the grids are anomalies found that are above the natural background noise. He stated that the plotting software ranks the anomalies based on the signal, from highest to lowest. Mr. Montroy added that TetraTech had buried items at 42 sites on this grid and that two inert items were buried at each site. He said this was used as a test to ensure good quality assurance. Mr. Montroy noted that the CVM had identified many more sites than the EM-61, but in either case TetraTech would not know what the items were until the items were dug up.

Dr. Feigenbaum asked if there were any overlaps found. Mr. Montroy said yes and that TetraTech was interested in this data because, if something were found by both technologies, perhaps it could be criteria for further selection.

Mr. Cambareri asked about quality control of the findings. Mr. Montroy replied that they are finding the data are about 97-98% accurate.

Dr. Feigenbaum asked if the items were found with both technologies or only one. Mr. Montroy replied that they should find them with both and that they did most of the time.

Mr. Walsh-Rogalski asked how they did in the original prove-out test. Mr. Montroy said that they did well and that TetraTech would be putting out a report detailing the calculations. Mr. Montroy stated that what Mr. Walsh-Rogalski was asking was did they find everything, and the answer was that generally they did. He added that what was more important is how many items were pointed out that they say are there but are not -- the false positives. He stated that TetraTech was working on that.

Mr. Montroy said the question had been asked of what kind of false positives was TetraTech finding. He gave the example of a metal object buried in the ground, there are only two possible answers, the instrument finds it or does not find it. If it finds it, that is great, if it does not find it that is bad, it is left in the ground. Mr. Montroy said that the real problem is the instrument tells you there is something there, but there is not, which causes a problem because now we have to dig, even though there is nothing there. Dr. Feigenbaum stated that this was TetraTech's problem. Mr. Montroy said that what TetraTech was trying to do was understand the ratio of false positives and items left in the ground.

Mr. Dow asked if there was enough dynamic range between the two instruments to use pattern recognition to combine the two and try to classify what the anomalies are. Mr. Montroy replied that there is so much natural variability -- in very controlled situations, they have worked with a company that can reliably predict what the items are, but this is not a controlled situation. He stated there was variability from gun and mortar site to gun and mortar site, because some of them are moraine sites, some of them are glacial outwash sites -- huge differences in geological variation.

Mr. Schlesinger commented that since TetraTech had some false positives, did they not have an equal amount of false negatives. Mr. Montroy replied that that was not necessarily true, and that TetraTech was working on the mathematics of that. He said TetraTech would not know that until they went out and dug up some of the anomalies.

Dr. Feigenbaum commented that Mr. Montroy had stated that TetraTech had gotten 97% accuracy. Mr. Montroy replied that TetraTech got 97% of the known items that they had put in, but that is not enough for them.

Mr. Montroy said the second task TetraTech was working on was the demolition area in concert with Ogden, and that the task was to find buried munitions. He added that TetraTech was working on 12 acres within the perimeter roads, which were heavily vegetated and contained lots of scrap. He reported that TetraTech has done a preliminary UXO sweep, removed drums of fragmented metal and removed vegetation down to about 6 inches tall. Mr. Montroy indicated on the slide where TetraTech was working in Demo Area 1. Mr. Montroy commented that TetraTech was only removing vegetation that would impede safety, and showed several photographs of the area before and after clearance. He added that the chunks of debris were being removed because they would interfere with the instruments.

Mr. Montroy displayed a bar graph on the status of tasks. He reported that the gun and mortar positions were done and TetraTech was currently working in Demo Area 1. He noted that the last three tasks, the water bodies, J-Ranges and slit trench, had not had much work done yet.

Mr. Montroy reported that the J Ranges were a work in progress. He stated that TetraTech would survey an area of approximately 100 acres, as agreed upon with the NGB and the regulators. He noted that TetraTech would work with Ogden in the J-2 Range to return that range to the dimensions of a 1971 aerial photograph, to remove the vegetation and return to a state of open ground, as it was in 1971, in order to do a geophysical survey. He added that the current proposal is not to do the entire 100 acres yet, but do 28 acres in the first phase. Mr. Montroy reported that the J-Ranges have vegetation ranging from mature pines to acres of very dense pitch pine. He explained that in order for TetraTech to safely navigate the J-Range, a lot of the vegetation must be removed.

Mr. Montroy explained that the water body investigation would take place because troops on their way back may have tossed excess ammunition after completing a training exercise into the ponds. He said TetraTech would investigate the near-shore area and do underwater geophysical surveying out as far as someone could throw something, which might be 100 feet. He reported that six ponds were currently being investigated. Mr. Montroy stated that no wetland vegetation would be removed. Mr. Montroy displayed some photographs of the ponds.

Mr. Montroy said TetraTech had visited the J-3 wetlands with the regulators. He reported that TetraTech would investigate the area with Schonstedt detectors in an arc pattern, and that no vegetation would be touched. He said the geophysicists would simply look for a Schonstedt hit. He added that if there was a detection, it would be flagged.

Mr. Montroy stated that the slit trench was located inside the Impact Area along Turpentine Road. He said that the slit trench appears to be a "borrow pit," which is an engineering term. He said that at some point in the 1940s sand was probably needed to construct roads, so they went in and excavated this pit. Mr. Montroy added that from photographs and aerial observation, they could see there was a lot of metal debris in the slit trench. He stated that TetraTech's task would be to remove the metal debris and see if there are buried munitions in the slit trench. Mr. Montroy then displayed a 1943 photograph of the slit trench and described it being approximately 250 feet long and 50 feet wide with tapered sides, and 10 feet deep.

Mr. Montroy stated that he had been discussing tasks in discrete areas, the objectives of which were not only to look at where there might be buried munitions, but also to look for characteristics of munitions that can be applied to the Impact Area. He explained that part of the whole process was determining what was in the Impact Area. Mr. Montroy said that things were buried at the gun and mortar positions and Demo Area 1. He stated that TetraTech was making the assumption that holes were dug and the materials placed there. He went on to say that, at the Impact Area, the UXO in the ground was the result of ballistic firing. Mr. Montroy explained that TetraTech expected the UXO to be distributed differently, and be concentrated around targets. He said that he thinks there is a perception that the entire Impact Area is uniformly pockmarked with UXO, which he stated was probably not likely. He reported that there are targeted areas where there would be more UXO because that is what was being fired at.

Mr. Montroy said the idea of the High-Use Target Plan was to characterize one high-use target in the Impact Area. He added that currently TetraTech has no idea of how UXO is distributed in the Impact Area, so they are taking a small subset of the Impact Area and will analyze it. He noted that LTC Knott had called it an archeological dig, and that is what TetraTech would do. He explained that TetraTech wanted to characterize how the iron is distributed and find out what happens to ordnance in the area. Mr. Montroy said the literature was spotty concerning what happens to a ballistic trajectory ordnance item that fails to detonate. He said the goal was to develop a scientific approach to determining if there was a link between contamination and presence of UXO and UXO-related material. He described the UXO-related material as detonated ordnance that may be contaminated with residual explosives. Mr. Montroy displayed a 1955 photograph of a high-use target area near MW-1 and said that TetraTech would be investigating that 4-acre area. Mr. Montroy noted that the benefits of this approach would be that it is a scientific approach, which TetraTech hoped they could use to characterize not only this site but also other high-use target areas in the Impact Area. He stated that the objective was to come up with source term, which he described as the mass of constituents in this area being excavated and where the constituents are contained. Mr. Montroy said the data would be fed into a model that Ogden will be running, and that the model will characterize the fate of the constituents as they move through the unsaturated zone and the soil column. He said TetraTech wanted to determine if the source term varies from high-use to lower-use target areas. Mr. Montroy commented that there were 22,000 acres in the Impact Area and that the goal of this work was to assist the NGB in characterizing the entire area.

Mr. Montroy stated that TetraTech had been told to find a site around MW-1 to work at. They found an area that they believe fits that criteria, which would be sited with assistance from the Ogden data. He reported that TetraTech would first map the surface UXO and remove it. They would then perform a geophysical survey to determine the density of iron underneath the 4 acres. Mr. Montroy said that the next step would be to site three 10,000-square-foot areas above high-density iron and three above lower-density iron. The UXO would be removed in 3-foot lifts, the materials would be sifted, sorted and the soil would be characterized. He noted the locations of the sites to be sampled on the map.

Mr. Montroy reported that TetraTech is currently working on a detailed work plan and working with the NGB to put together an explosives safety submission. He emphasized that this was very dangerous work, and they were operating under DoD requirements to ensure that everyone works safely. Mr. Montroy commented that this had never been done before, so the ability to ensure safety was paramount. Mr. Montroy also reported that the road would need improving and that TetraTech would need to be concerned about training radius. He stated that this was a very large engineering process. Mr. Montroy stated that excavation was expected to start in summer 2000, and a draft report would be made available to Ogden for their work in December 2000. He stated that TetraTech planned to then take the data and work with the NGB to do a second high-use target area someplace else in the next year.

Mr. Montroy said that, in summary, he had provided an overview of the project, and that TetraTech was focused on identifying buried munitions. He said that TetraTech would not be digging up everything, only anomalies in order to characterize what is there. He said he has given the IART an overview of what has been done to date and where TetraTech would go in the next six months.

Mr. Gschwend commented that when Mr. Montroy spoke of the archeological dig activities, it sounded like there was an emphasis on characterizing the presence of metals. He asked if TetraTech would simultaneously characterize the presence of RDX. Mr. Montroy replied that TetraTech would be performing chemical analysis of soil matrix. Mr. Gschwend asked if that would be for RDX. Mr. Montroy replied for the whole set. He added that it will drive the Ogden model, so whatever Ogden is doing, TetraTech will be doing. Mr. Montroy asked if Mr. Gschwend meant would TetraTech look for chunks of RDX. Mr. Gschwend replied that in some sense yes, as the Ogden model will ultimately require some sense of the source function, and chunks are one attribute of the source. Mr. Montroy stated that if it were possible for TetraTech to clearly identify the RDX, they would.

Mr. Gschwend noted that Mr. Montroy had mentioned there might be a potential problem with magnetic minerals at the MMR. He asked what the evidence was for that. Mr. Montroy replied that he did not have any but there is a possibility, which is why TetraTech needs to excavate and do an examination of some of the sites of CVM anomalies that are not picked up by the EM-61. He added that it may be metal anomalies that are deeper than the EM-61 can find.

Mr. Gschwend asked how deep TetraTech would be looking. Mr. Montroy said he had asked the geophysicists the same question, which was difficult to answer. He added that TetraTech was really interested in the horizon for the gun and mortar positions and Demo Area 1, where a soldier would dig a hole and dump stuff in. He theorized if a soldier would be likely to dig a 6-foot hole -- probably not. He stated that TetraTech was looking at a horizon at 6 feet, which is why they are using both the CVM and the EM-61. Mr. Montroy said that the confluence of the two offered the best opportunity of recovering all the anomalies.

Mr. Gschwend commented that Mr. Montroy had stated that TetraTech had been directed not to look between gun positions, and that Mr. Montroy had then stated that TetraTech would be looking at paths. Mr. Montroy replied that his point was that TetraTech was not looking at the entire 14,000-acre training area, they were looking at discrete gun and mortar positions and looking at paths radiating from there. Mr. Gschwend asked if Mr. Montroy was saying TetraTech was looking at places they imagined people would bury things. Mr. Montroy concurred.

Mr. Schlesinger asked if TetraTech would be look on or off the paths. Mr. Montroy replied that the CVM detected a fairly broad swath, so if there was something within 6 feet with a strong signal it would be detected. Mr. Schlesinger asked if that would be 6 feet on both sides of the path, as he did not know that people bury stuff on paths. Mr. Montroy replied that they would have to go out and interrogate some of the anomalies they found to determine if that were a good hypothesis. He stated that TetraTech thought it was pretty good, but to keep in mind that these were paths, not roads, which were 3 to 4 feet wide, so the CVM would see enough to either side.

Ms. Frawley noted that it was 10:00 PM and asked if the IART wanted to postpone the other issues, including the small arms range testing, until the next meeting. She noted that there was a fact sheet available for the CS-19, so perhaps there was no need for further discussion on that.

Dr. Feigenbaum asked if the technical meetings were planning the small arms range study. Mr. Borci said that it had been discussed at the technical meetings and that he was waiting to get final comments back. Mr. Borci asked if Dr. Feigenbaum had a comment he wanted to include. Dr. Feigenbaum replied that he had commented to Mr. Borci that there be a before-and-after-use sampling. Mr. Borci said that had been discussed at last Thursday's meeting.

Dr. Feigenbaum requested that there be a report on the small arms at the next IART meeting.

Mr. Schlesinger asked if there would be any restoration after the munitions survey. Mr. Borci replied that, since TetraTech would not be pulling vegetation out at the gun and mortar positions, they were just cutting it, most of it would grow back. He added that for the high-use target area excavations, this was an impact area that is full of craters and there is not much vegetation out there anyway. Mr. Schlesinger asked if where TetraTech cut down vegetation they would re-seed or just allow it to grow back naturally. Mr. Borci replied that it would probably be allowed to grow back naturally. Mr. Borci said that the NGB has been in contact with Mr. Ciaranca from the Natural Resources Office.

Mr. Hugus commented that, for the record, a letter has been circulated by the chairmen of the PACERS and the Friends of the MMR which claims that CPT Boggess talked to them and gave them a report saying that when Mr. Hugus brought a can of aircraft grease to a meeting a couple of years ago, he was perpetrating a hoax. Mr. Hugus stated that, for the record, this was not a hoax, the aircraft grease did come from the Impact Area; Mr. Zanis found it there and gave it him. Mr. Hugus added that Mr. Zanis has the remains of the entire case he picked up out there to deliver to whoever wants to take responsibility for it. Mr. Zanis added that he had two cases, which have the address on it. He explained that part of the hoax says that there is no address supplied and that I never wanted to give the address. Mr. Zanis stated that he thinks there were 9 or 10 cases he removed from the Impact Area, which he found at the APC. He said he did not want to give an address because the address is to an aviation building where the troops work. Mr. Zanis commented that he guessed the Friends of the MMR would rather have him reveal the address and the personnel who put it out there. He stated that he would like to give it back to the NGB so that it can go where it was supposed to go, not the Impact Area.

Mr. Cambareri commented that he believes that we need to be very conservative about Cape Cod's water supplies on the Upper Cape and to let everyone know that there will be an interesting session on April 29, 2000. He said that the Association for the Preservation of Cape Cod (APCC) would be putting on an event called "Unanswered Questions" and that he was looking forward to having a lively debate on water supply issues there. LTC Knott added that he and Mr. Hugus would be on the panel for safe drinking water.

Agenda Item # 6

Wrap Up, Schedule Next Meeting

Ms. Frawley stated the next meeting date would be May 17, 2000 and stated that she would, in the interest of time, e-mail the action items to the team members.

Action Items:

  1. EPA-NE to send MAARNG a letter requesting a written inventory of the number and types of items remaining in the ASP.

  2. Paul Zanis will forward a copy of his letter requesting that MAARNG move the active ranges on Greenway Road away from nearby residential areas to Kent Gonser, MMR/JPO. Mr. Gonser will ensure that the letter is included in the public comments of the MMR Master Plan EIR.

  3. Any future munitions, soil or other cleanup activities that may occur outside of the official Impact Area cleanup will be discussed with the regulators at the weekly technical meeting, prior to any cleanup activities being implemented.

  4. NGB will distribute to the IART members copies of all maps submitted by Textron Systems Corp. in their 2/25/2000 response to the CERCLA Section 104 information request.

  5. It was requested that more microphones be available for use at the IART meetings.

  6. It was requested that literature on the two metal detectors being used by Tetra Tech (Cesium Vapor Magnetometer and EM-61) be distributed to the IART in the weekly technical notes mailing.

  7. It was requested that the plotting of plumes, zones of contribution (ZOCs), and sources of contamination on Impact Area maps be further discussed at a technical meeting.

  8. It was agreed that the mortar target areas identified on the IAGS Update map Figure 1 were used historically as mortar targets and/or artillery targets. EPA requested that a more appropriate term to define the target areas be used on future maps.

  9. The following agenda items will be discussed at the May 17 IART meeting:
    - Textron information request submittal - NGB/EPA
    - Small Arms Range testing discussion - requested by Mr. Hugus
    - Report on the Small Arms Range sampling decisions - EPA/NGB requested by Dr. Feigenbaum
    - Blast Chamber update - EPA/NGB
    - Public Information Team services - PIT


Ms. Frawley adjourned the meeting at 10:15 PM.

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