Impact Area Review Team

River River Drops of rain on a leaf

Impact Area Review Team
Bourne Bridge Best Western
Bourne, Massachusetts
June 28, 2000
6:00 PM

Meeting Summary







Jan Drake



Len Pinaud




Ellie Grillo




CPT William Myer




Ben Gregson




LTC Joe Knott




Marc Grant

Ogden Environmental



James Graham




Paul Zanis

"Anti-military" citizen



Marty Aker




Dick Prince

Bourne resident


Tom Cambareri




Joel Feigenbaum




Richard Hugus


Kent Gonser




LTC Donald Bailey




Jane Dolan



Todd Borci










Jim Murphy









Caroline Rozek


Darrell Deleppo




COL Osternderph




Jan Larkin




Mike Farinella




Patricia Culligan




Dave Guido




Jim Quin

Foothill Engineering



Kim Harper



Kevin Denehy




John Rice




Bill Gallagher




Kristin Smith




Dave Egan

IT Corp



Doug Larson



Jay Johnson



Ray Cottengaim




Rob Clemens




Lana Reilly



Doug Lam

Tetra Tech


Raye Lahti

Tetra Tech


Dave Williams

Tetra Tech


COL Freeman





Jan Larkin





Bill LiBrizzi




Mary Howell


Doug Shattuck




Jason Alves




Virginia Valiela

Falmouth Selectman



Karen Mochutt





Jim Fein




Kelly Rhodes



Jane Moran




Mary Meli



Agenda Item #1. Welcome, Introductions, and Approval of May 17, 2000 Meeting Minutes

Mr. Murphy convened the meeting at 6:04 p.m. and welcomed the attendees. He noted that Ms. Austine Frawley was on vacation and that he would be filling in as facilitator. The team members then introduced themselves. Mr. Murphy asked if there were any changes to be made to the May 17, 2000 meeting minutes. There were no changes and the minutes were approved as written.

Review of Agenda

Mr. Murphy asked if there were any comments on the agenda. Mr. Hugus said that he would like a few minutes to discuss a variety of issues. Mr. Murphy said that he will allot time under "Other Issues" for Mr. Hugus to address the team. He asked if there were any other comments on the agenda. There were none.

Review of Action Items

  1. The United States Environmental Protection Agency (EPA) will forward to Mr. Gonser and LTC Fitzpatrick a hard copy of Mr. Zanis’s e-mail, dated April 8, 2000, to the National Guard Bureau (NGB) that the Massachusetts Army National Guard (MAARNG) move the active ranges on Greenway Road away from nearby residential areas. Mr. Gonser and LTC Fitzpatrick will forward the letter to MAARNG for its consideration.
  2. LTC Knot said that he believes that a response letter was sent to Mr. Borci in June. Mr. Borci explained that he forwarded the letter from Mr. Zanis and that he received a response from LTC Bailey which stated that the ranges will not be closed because the range only gets a limited amount of use. Mr. Hugus asked to whom LTC Bailey sent the response letter. Mr. Borci replied that he and Ms. Drake received a copy of the letter. Mr. Hugus requested that the response letter be distributed to the Impact Area Review Team (IART). LTC Knott said that the letter will be included in Monday’s mailing.

    Mr. Hugus explained that there are small-arms ranges along Greenway Road in Sandwich, which are within a couple hundred feet of a residential area. He said that some of the IART citizen members do not feel that it is appropriate for the NGB to be firing that close to homes. He said that he thinks that the response from LTC Bailey is ungenerous, and he would like to register a protest. He said that he does not understand why LTC Bailey feels that he can not use some of the other 15,000 acres of Camp Edwards in order to relieve the residents in Forestdale of the nuisance and possible health risks associated with arms being fired so close to their homes.

  3. NGB will invite its hydrogeologist to the next IART meeting to discuss the west end of the Demolition Area 1 plume.
  4. Mr. Murphy noted that this is on the agenda for this evening.

  5. Mr. Hugus requested that the unexploded ordnance (UXO) detonation soil sampling results chart be revised to include the actual sample result data.
  6. Mr. Grant explained that the UXO detonation results table consists of two tables; one contains validated data and the other contains unvalidated data. He said that the concentration column is removed when unvalidated data is provided to the public or the IART because that number may change after the sample goes through the validation process. The two columns representing the reportable concentration under the Massachusetts Contingency Plan (MCP) and a comparison column depicting whether there is an exceedance of the reportable concentration remain. He stated that the data will be presented again when it becomes validated, at which point the concentration will be depicted on the table.

  7. Ogden Environmental will distribute to the IART the air emission sampling results from the open detonation sampling event.
  8. LTC Knott noted that this has been done.

  9. The United States Environmental Protection Agency (EPA) asked that the IART citizen members forward to Ms. Margery Adams any comments or additional questions regarding Textron Systems Corp.’s response to the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) 104E information.
  10. Mr. Murphy reported that this has been completed and comments have been received.

  11. The EPA will distribute to the IART a copy of the license agreement between Textron Systems Corp. and the United States Army Corps of Engineers (USACE).
  12. Mr. Murphy noted that this has been done.

  13. The NGB will report back to the IART the answer to the question, "Did AVCO use perchlorate as a rocket propellant at the Massachusetts Military Reservation (MMR)?"
  14. LTC Knott noted that the action item should read AVCO/Textron and said that the EPA is waiting for a response.

  15. Mr. Peter Schlesinger requested that the EPA ask the USACE to provide copies of all contracts it issued for the J Ranges at MMR, and share that information with the IART. He further requested that the IART be briefed on all of the parties that conducted work at the J-1 and J-3 ranges.
  16. LTC Knott said that Mr. Deleppo from the USACE is going to address this issue. He noted that the handout reflects parties that have so far been identified by the archive search report. (See attachment #1.)

    Mr. Deleppo stated that the USACE has researched its real estate records for the property at MMR for work that was done for the Guard. He reported that the USACE has not issued any contracts for work at the MMR. He said that the USACE issued a license or lease to Textron in 1978, and he is working with the Guard on a record search related to the Textron issue. He said that there may have been other contracts issued by other Army branches and he is hopeful that the supplemental ASR will help with their identification.

    Mr. Hugus remarked that the citizen members are not concerned about contracts issued by USACE. However, there is concern that USACE had given lease agreements to Textron, which creates two problems. He said that he thinks that there is a conflict of interest with USACE acting as landlord and conducting the ASR, which might involve its tenant. Mr. Hugus said there is also an issue of whether USACE paid any attention to whether Textron was keeping up with the terms of its lease, which must have contained some environmental protection clauses. He noted that the contractors at the J Ranges were not always environmentally well-behaved.

    Mr. Deleppo explained that typically the USACE acts as a real estate agent for the Army. He said that the leases and licenses usually do contain clauses requiring that environmental laws are followed. He also noted that usually the USACE would not go out and inspect the work, and there are no records of that happening. Mr. Hugus asked if the USACE inspected the J Ranges to see if its tenants were living up to the lease agreements. Mr. Deleppo replied that he is not aware of that occurring.

    Mr. Murphy asked if the handout chart represents all of the companies that received requests for information. LTC Knott replied yes, the chart lists known companies that did work at the J Ranges. He also noted, however, that there are data gaps regarding who held the contracts, and it is hoped that the supplemental ASR will identify those parties.

    Mr. Hugus stated that he thinks that the various contractors’ responses to EPA’s 104(e) request amount to a huge maze of corporate irresponsibility. He noted that the corporations have divided, sub-divided, and changed their structures to the point that it almost impossible to assign responsibility. He noted, for example, that Raytheon indicated that it is such a big corporation that it is a nuisance for it to determine which part of its operation may have used the J Ranges. Mr. Hugus remarked that he thinks this was an arrogant response, but one that he considers typical of a corporate attitude toward taking responsibility. He also noted that he was unable to understand the intricacies of the various branches of Atlantic Research, and it seems to him that the public is being stonewalled by these entities, which are not forthcoming about what they did at the J Ranges. Mr. Hugus said that he hopes that EPA has the time and the legal staff to look into this, and added that it will take a lot of time to untangle all the diversions and unclear answers provided by the contractors.

    Mr. Borci noted that in a way this issue is on tonight’s agenda. He explained that when LTC Knott discusses the scope of work for additional archive search activities, he also can discuss how this legal maze will be addressed. Mr. Borci also noted that currently EPA counsel is working on finding successors to many of the companies that worked at the J Ranges.

    Dr. Feigenbaum asked what is known about General Electric’s (GE’s) activities on the base. LTC Knott replied that not much is known. Dr. Feigenbaum said that something must be known about GE because it is listed on the matrix. Mr. Grant explained that Atlantic Research’s response to the 104(e) request indicated that GE may have been holding a contract with Susquehanna. Therefore, the Guard had the Air Force submit a 104(e) request to GE. Mr. Grant stated that he believes that GE has asked for and been granted an extension until August. At this time, however, all that is known is that another contractor said that GE hired Susquehanna to do some testing at the base. Dr. Feigenbaum asked for confirmation that GE had hired Susquehanna. Mr. Grant confirmed that it had.

    Dr. Feigenbaum remarked that it is a mystery to him how this might have worked. He questioned whether a company would just call someone at the base to request access. Mr. Grant replied that it is his understanding, from reading the responses, that Picatinny issued contracts periodically; every five years or so a contract would expire, and someone else would pick it up. He said that he is uncertain how GE became involved in that particular aspect. Dr. Feigenbaum asked again if GE was contracting Susquehanna. Mr. Grant replied that Atlantic Research’s response said that it was. Dr. Feigenbaum what is known about Susquehanna’s activities. Mr. Grant replied that so far the only things that are known are what other contractors have reported because Susquehanna has not had a chance to respond to the inquiry. He also mentioned that at the beginning of this week an inquiry was sent to its successor company.

    Mr. Hugus referred to his earlier comment regarding the request to decommission the ranges that are close to homes in Forestdale along Greenway Road. He noted that LTC Bailey had said that that request could not be honored because those ranges might be needed during high-use times. He then asked LTC Bailey how much use of the ranges near Greenway Road he anticipates, and at what time of year. LTC Bailey replied that those ranges were used four times over the past two and a half years. He noted that this was normal usage that occurred once or twice a year, usually in October during the high outdoor training season. He also mentioned that data in the report indicate that use of those ranges does not present any health risk to anyone. However, if future studies were to show the possibility of a health risk, the situation would be reevaluated. Right now, there appears to be no reason to close the ranges.

    Mr. Hugus asked LTC Bailey to identify the report to which he was referring. LTC Bailey replied that he was talking about the 1985 report that Mr. Zanis mentioned when he made the request. Mr. Hugus remarked that it seems obvious that LTC Bailey would not think there was a problem because the report did not say specifically what should be done in this particular case; he said that he thinks there was plenty of room for interpretation. Mr. Hugus also stated that he thinks that there is a problem; he noted that private homes are very close to the ranges and noise certainly is a problem. He said that he thinks that, as a courtesy to those residents, the Guard should find other ranges to use. He added that the Guard has plenty of other land it could use.

    Mr. Zanis stated that in addition to a health issue, the ranges present a safety issue because firearm accidents do occur and have occurred at the base. He said that he plans to take this to politicians, to the general, and to the governor. He explained that he does not think there is enough rank at this meeting, and he wants to take the issue "right to the top." Mr. Zanis then requested a hard copy of LTC Bailey’s letter, to submit to the politicians. LTC Knott stated that copies of that letter would be included in Monday’s mailing.

    Dr. Feigenbaum said that he finds it hard to believe that the Guard would not provide the community the courtesy of moving those ranges away from Greenway Road, given all of the available land. He noted that even at his own home, which is about two miles away, he hears noises from M-16’s that are loud enough to be annoying. Dr. Feigenbaum then asked if there will be a brief update on the status of the small arms study. LTC Knott referred to action item #11 and noted that the study will be discussed there.

  17. The NGB agreed to take under advisement air emission testing at the backside of the controlled detonation chamber to determine the need to install carbon filters on the chamber.
  18. Mr. Deleppo said that it seems appropriate at this time to do the emissions testing on the chamber. He noted that EPA has proposed a method of doing the testing. Contractors currently are looking at that method and over the next few days a meeting will be set up with Mr. Borci at EPA to discuss exactly how the emissions testing will be done.

  19. The NGB will include an IART facilitator proposal in the weekly notes for the IART review and comment.
  20. LTC Knott noted that that was a typographical error, which should have read assistant to the EPA’s facilitator. He stated that this Monday’s mailing will contain a proposal for the Guard to hire an individual to work with Ms. Frawley; that individual would help with the mechanics of the meeting and time management. LTC Knott mentioned that the Guard has heard "loud and clear" that Ms. Frawley does a good job. He noted that the proposal will include a list of people and their phone numbers. Also, Installation Restoration Program (IRP) team members will be asked whether they could suggest someone to help facilitate IART meetings.

    Mr. Hugus asked if it is correct that, rather than hire a new facilitator, the Guard plans to hire administrative support for the existing facilitator. LTC Knott mentioned that he discussed this with Ms. Frawley. He said that he thinks that the best way to describe the position, which will be filled by a trained facilitator, is as Ms. Frawley’s assistant. Mr. Hugus asked if Ms. Frawley still would be sitting at the table. LTC Knott replied that Ms. Frawley would sit at the table, with her assistant seated next to her. Mr. Hugus commented that the arrangement would be as he had thought – the new individual would provide administrative support. LTC Knott clarified that the individual would do whatever Ms. Frawley needs to help her to do her job at IART meetings. Mr. Hugus stated that he feels that this is a fair compromise. He noted that the citizen members of the IART who discussed this topic a couple of meetings ago think that Ms. Frawley of EPA is doing a good job chairing these meetings. The IART sees no reason to replace Ms. Frawley, and, in fact, believes that the team would be burdened by a new facilitator who would need to be brought up to speed on IART issues.

    Dr. Feigenbaum noted that he wonders about the DEP’s position on this. He said that "over the years they have been making noises about the need to change this or that." LTC Knott stated that he thinks that Dr. Feigenbaum was referring to comments when he said making noises. Dr. Feigenbaum explained that he used that term because DEP is not at the table, and its comments are just "rumored around." Mr. Pinaud stated that, based on what LTC Knott described, he sees no reason not to be supportive of Ms. Frawley having some help to facilitate the IART meetings. He also said that he thinks that any support that anyone can offer to the IART to better coordinate activities should be welcomed by the team.

  21. The NGB agreed to schedule a soil sampling event at a small arms range that will coincide with a heavy-use training event at the range.
  22. Mr. Grant reported that Ogden Environmental has been talking to range control about the training schedule, and right now it looks like there will be a number of different events occurring between July 17 and July 28, 2000. Those events will include some M-16 training, and the intent is to conduct air sampling during the training and soil sampling shortly after the training. Mr. Grant stated that this is what the schedule looks like right now, but it is possible that it could change.

    Mr. Hugus noted that the IART has been asking for small arms range training soil and air sampling for at least three months. Now, there will be another month-long delay before the sampling even is conducted. He questioned whether there has not been a heavy-use training day up until this point. Mr. Grant replied that there has been some training in the last couple of weeks; however, the process to finalize and document the final sampling plan has not been completed. He noted that responses to comments were submitted, and the memorandum of resolution (MOR) still has to be submitted to the agencies. It is hoped that that will be done today or tomorrow. Mr. Grant agreed with Mr. Hugus that the process has taken some time.

    Mr. Hugus remarked that the process is taking way too long. He said that it has been three or four months, and still a piece of dirt from the small arms ranges has not been picked up and sampled. He noted that the citizens who are dealing with contamination at Otis are accustomed to these kinds of delays, but they do not agree that they are necessary. Mr. Hugus stated that this is a source of frustration for which he faults the regulators as well. He said that he thinks the process is too cumbersome.

    Mr. Zanis asked if the plan is start with sampling a high-use range. Mr. Grant asked if Mr. Zanis was referring to air or soil sampling. Mr. Zanis replied that he was referring to soil sampling. Mr. Grant stated that the soil sampling will occur at what is classified as high-use ranges. Mr. Zanis asked if these means that sampling will occur after a firing event. Mr. Grant replied that it does. Mr. Zanis asked if any of the 50-caliber ranges would be sampled. Mr. Grant said that he cannot recall. He said that he does know, however, that an effort was made to choose ranges that had both heavy use and high caliber. Mr. Borci added that he is pretty sure that the answer to Mr. Zanis’s question is yes. Mr. Zanis commented that it seems to have taken a long time for Ogden, which usually moves quickly, to address this sampling.

    Dr. Feigenbaum asked for clarification that there is going to be a written protocol for the study, which will indicate how many sampling points there will be, the distance between the barrel and the guns, and so forth. Mr. Grant noted that the draft sampling plan was provided on April 27, 2000, and it will be finalized in accordance with the comments that were received. Dr. Feigenbaum said that he does not think that the IART has ever seen the written plan. Mr. Grant replied that the plan should have been submitted to the entire IART, as they typically are.

    Mr. Borci said that he believes that the draft plan was submitted to the team, and a short presentation on the plan was provided at a previous IART meeting. Dr. Feigenbaum agreed that there was a short presentation. Mr. Borci noted that is certain that EPA comments were submitted after that presentation. He also assured the IART that, to speed up the process, he tried to incorporate into those comments the concerns expressed by the team at the time of the presentation.

    Dr. Feigenbaum stated that he thinks that the IART has not seen the written plan, and he noted that the team has been assured that copies of the plan can be made available. Mr. Grant said that he thinks that Dr. Feigenbaum is right; it does appear that the IART was not on the distribution list for the plan. He noted that typically that would not be the case; however, it seems that the only thing the team saw was the January submittal. LTC Knott stated that copies of the plan would be included in Monday’s mailing.

    Dr. Feigenbaum questioned whether it would be too late to consider any ideas or comments from IART members. Mr. Borci said that he already has tried to incorporate the IART’s concerns. He explained that it may be taking a little longer to implement the plan because of the changes made that were based on IART input. He said that he would hope that the team will see what it expects to see. However, if IART members feel otherwise, he will discuss the matter with the appropriate parties.

    Dr. Feigenbaum inquired about the range of distances from the firing point that monitoring will be done. Mr. Grant replied that there was agreement to sample at each of three ranges, which were Alfa, Golf, and India. The plan was to have a series of soil sampling grids laid out across the firing points. The soil sampling grids would have several sampling points in front of the firing point, as well as several behind the firing line. Therefore, there basically would be three locations at each range along the firing line, and at each one of those three locations there would be sampling points in front of and behind the firing line. The samples will be analyzed for explosives, semi-volatiles, which sometime pick up propellant compounds, and metals.

    Mr. Pinaud noted that he is concerned that resolution on the plan is close to being reached, and the citizens have not really taken a look at it yet. He also said that he is uncertain whether the TOSC people have reviewed it. Mr. Pinaud then stated that because there is a training schedule for use of the ranges this summer, it seems to him that there could be some coordination between when the ranges are going to be used and when the investigation can be done.

    Mr. Grant said that he thinks the schedule is most critical with respect to air sampling, which has to happen during training. He noted that from Ogden’s standpoint, it does not make a lot of difference whether soil sampling occurs a day or a month after a training event because it is not expected that the compounds that would be released would go anywhere in that amount of time. Therefore, it is important to do air sampling soon, in July. However, the soil sampling could wait in order to allow time for additional comment on the plan.

    Dr. Feigenbaum agreed that soil sampling could be delayed, if necessary. He then asked for confirmation that soil sampling will be done at a variety of distances from the firing line. Mr. Grant replied that the proposal is to sample directly in front of the firing line; he explained that it would not be a sequence of distances, but would be about 10 feet in front of the firing line. Dr. Feigenbaum how he could know that this location would optimize the chances of finding material, if it is there. He questioned why a distance of 10 feet was chosen.

    Mr. Borci noted that all of this information was presented to the IART previously. Dr. Feigenbaum asked if he himself had attended the IART meeting when this information was presented. Mr. Borci said that he is sure that Dr. Feigenbaum attended that meeting because they spoke right afterward. He noted that he incorporated into EPA’s comments some of Dr. Feigenbaum’s specific comments regard sampling locations. Mr. Borci stated that he thinks the plan is ready to be approved. He then reiterated that he would receive any additional comments and pass them along to people at the technical meeting. He also explained that the approval of the MOR is just a formality, which has not prevented Ogden from moving forward with the plan.

    Dr. Feigenbaum stated that the only discussion he recalls in terms of any details occurred after the last IART meeting, when he spoke with Mr. Borci about the question of sampling before and after the training event. He said that he always had thought that IART members would be given a plan that would show the grid and help them understand how the material distributes itself in front of the guns. He added that he would guess that one sampling point 10 feet in front of the gun was chosen arbitrarily.

    Mr. Murphy reminded the group that the written plan would be sent out in Monday’s mailing, and additional comments could be forwarded to Mr. Borci.

    Dr. Feigenbaum inquired about the analytes, and mentioned the paper that Mr. Zanis had discovered, which detailed some of the specific breakdown products from the firing of propellant. Mr. Grant stated that he believes that the plan analytes include anything that is not a volatile compound or a gas which would disappear, and added, "I guess that would be a separate issue, it would not be in the soil sample."

    Mr. Zanis stated that he agrees with Mr. Borci in that he wants to get on with the sampling. He noted that he wants the sampling to be done as soon after an event as possible. Mr. Borci said that the sampling plan that EPA is ready to approve will indicate whether or not there is a problem. If there are detections, the next step will be to look more closely in order to determine exactly how the detections were distributed, the distance from the points, and so forth.

    Mr. Hugus disagreed with Mr. Grant’s comment that it would not matter too much if there were a delay in soil sampling after a training event. He explained that if the soil around the firing ranges is dusty, and there is no vegetation there to hold it in place, wind or rain could easily disrupt any residues. He said that he thinks that the time for sampling is definitely right after the event.

  23. The following agenda items will be discussed at the June 28, 2000 IART meeting:
  24. - Assistance to IART facilitator 
    - Discussion of the west end of the Demo Area 1 plume

    Mr. Murphy noted that both of these items are on the agenda. He also mentioned the time, 6:52 p.m., and that the team still was discussing the first agenda item.

  25. The EPA will send a follow up letter to the MAARNG on an inventory on the number and type of items currently stored in the ammunition supply point (ASP).
  26. LTC Knott said that he believes that the follow-up letter was sent and is included in the handout.

    Mr. Zanis referred to Mr. Murphy’s mention of the time, and said that the people who are not paid to attend these meetings never complain about staying late and keeping tracking of time. He said that he sees that the people who are paid to attend always look at their watches. He asked if it is not true that they can get and leave if they want to. Mr. Murphy replied that those people certainly could get up and leave. He also explained that he had thought that it was his job to mention the time. Mr. Zanis remarked that the paid participants who look at their watches every five minutes can get up and leave. Mr. Murphy stated that anyone can leave at any time, although he does not encourage it.

    Mr. Hugus said that he agrees with Mr. Zanis. He noted that the items that the team hopes to run through quickly are actually important and need to be discussed. He said that the team has a huge job, and it probably would have to meet two times a week in order to have time to cover everything.

    Mr. Hugus also said that he read EPA’s letter to Adjutant General Keefe regarding the request for an inventory of ammunition at the ASP. He said that the response to that request is a month overdue. He also noted that at the controlled detonation chamber demonstration, General Keefe spoke highly about the Guard’s environmental stewardship, saying that there is nobody like the Guard when it comes to taking care of the environment. Mr. Hugus remarked that he finds General Keefe guilty of hypocrisy when it comes to the ASP because he will not even disclose the inventory there after two months of requests. He added that it is his understanding that the request now is under review, which means to him that there simply will not be an answer. He further stated that he would like to deliver a rebuke to the Guard and to the Adjutant General for "wasting our time." He also asked that someone from the Guard tell him when this information will be delivered.

    LTC Bailey asked Mr. Hugus to understand that requests such as this are not taken lightly because of the security issues that are involved. He said that the legal staff from the Massachusetts Guard has been meeting with EPA about this issue, which still is ongoing. LTC Bailey assured Mr. Hugus that General Keefe is not ignoring anyone, but is looking at the issue and all of its legal aspects, and will reply to EPA.

    Mr. Hugus noted that last year, when the artillery simulators had to be taken out and detonated, the Guard handed EPA a full inventory of the ASP, and the elements of the inventory were printed in the press. Also, the IART received a copy of that inventory. Mr. Hugus stated that now, however, all of a sudden there is a security issue, and he does not understand why. He also said that he thinks that the IART has a right to know what is in the ASP because it is dealing with contaminants that are similar to what is contained there. Also, the IART is concerned that Camp Edwards is storing munitions that were prohibited by EPA’s order in the first place.

    LTC Bailey stated that the Guard probably will release some information. He also said that while the public’s right to know is understood, that does not include security issues. There is a limit, which is why the legal staff is looking at the request and giving it careful consideration. Mr. Hugus asked if the Guard would be able to provide EPA with the full list, even if it could not provide the full list to the public. LTC Bailey said that whatever is agreed upon between the Guard’s legal people and EPA will be provided. Mr. Hugus remarked that the Guard is supposed to be protecting the public, and he finds it offensive that the citizens are not entitled to know what is in the ASP.

    Dr. Feigenbaum asked that the regulators take the issue a little bit further because, in addition to the ammunition in the ASP, which, he said, will never be used on MMR, at the Unit Training Equipment Site (UTES) there is equipment to fire that ammunition. He said that that equipment is just rusting away, and it is a terrible eyesore for the people who live on Greenway Road. Dr. Feigenbaum stated that much of that equipment serves no function at the base, and he would like to see an inventory of it, and he would like to know how long it is expected to be "parked here in our backyard." He also said that the Guard will not listen to the citizens because they have no authority. However, the regulators do have that authority.

    LTC Bailey explained that Camp Edwards uses the artillery weapons systems for drills and activities that do not involve the firing of any projectiles. He also said that a request for an inventory of that equipment would be considered, and probably could be accommodated. The proper parties first would have to look at the request and then a reply would be given. Dr. Feigenbaum said that there are hundreds of artillery pieces just sitting "parked there."

    Agenda Item #2. Field Investigation Update

    Central Impact Area Monitoring Well Data

    Mr. Grant noted that handouts were provided to members of the IART. He said that the handout that contains the set of maps and tables shows the detections that have occurred at the groundwater monitoring wells in and around the Impact Area since the study began in 1997. He noted that the format of the maps has been changed, to an 11" x 17" format, which he believes is an improvement because they now show one big figure with a one inset, rather than one small figure with five insets. Mr. Grant said that he would take comments from IART members regarding their opinions on the new format. He also mentioned that the other handout contains the word slides that he will be presenting tonight, as well as some colored maps.

    Mr. Grant reported that over the past month several wells, numbered 102 to 107, were installed in response to the RDX detections in the central Impact Area. He noted that wells 102 and 103 are located on the far western portion, and he pointed out that the red line on the map indicates the Impact Area, and noted that groundwater generally is moving to the west. Mr. Grant stated that well 104 was installed near target 9, and wells 105, 106, and 107 all were installed last month in the central Impact Area. He also noted that only profile data from those wells are available at this time. He further noted that the another well, MW109, was installed down in the southeast side of the Impact Area at the KD Range.

    Mr. Grant reported that agreement with the agencies has been reached regarding six additional wells that would serve as a kind of stop-gap, to keep the investigation going before deciding on the next set of wells. Those wells P22, P23, P24, P25, P26, and P27, currently are being installed, and are shown as open circles on the map. The installation of wells P22 and P27 is nearly completed and installation activities will continue with wells in the Impact Area, north and south of the inner transect. Mr. Grant explained that a transect is a group of wells that forms a fence and allows for monitoring of groundwater quality as the water moves perpendicular to that fence. He also noted that in addition to the stop-gap wells P22 through P27, discussions are ongoing with the agencies regarding plans for additional monitoring wells.

    Mr. Grant stated that the next part of his update is to report on the status of groundwater sampling. He noted that the Phase I wells were installed in 1997/1998. The Phase 2A wells were the first set of wells installed in response to RDX detections in particular areas. Supplemental wells, installed by the IRP, were used for sampling to characterize various things, including parts of the training ranges. Mr. Grant explained that far-field wells, which are located farther out from the Impact Area, are designed to characterize groundwater quality as it approaches potential water supply points. He also noted that there a series of wells is installed at gun and mortar firing positions, and a set of wells, located around Demolition Area 1, was installed in response to RDX detections there. The most recently installed wells are the ones that he just discussed – the Impact Area response wells.

    Mr. Grant reported that the oldest categories of wells have been sampled four times. A sampling event completed in May covered most of these categories, and was the first of three sampling events scheduled for calendar year 2000. The next two events will occur in August and December; it is being determined, with the agencies, exactly which wells will be included in the those sampling rounds.

    Mr. Grant reported that since last month, the third round of sampling for the Phase 2A wells also has been completed. Also as of last month, three rounds of sampling at the gun and mortar wells also had been completed. Sampling of the Impact Area response wells has begun, and results for about half of those wells are available, even though most of them have been sampled. Mr. Grant explained that there a time lag between when the samples are taken and when results become available.

    Mr. Grant noted that the actual monitoring well results are depicted on a sort of modified detection map, which shows both validated and unvalidated explosives detections. Red dots indicate detections and green dots indicate non-detects. He pointed out that there are several general areas of detections, which are predominantly Demolition Area 1 down to the south of the Impact Area, the J Ranges to the southeast of the Impact Area, and the Impact Area itself. Mr. Grant pointed out the outer transect on the perimeter of the Impact Area and noted what is shaping up to be a western outer transect on Burboyne Road, farther west of the edge of the Impact Area.

    Mr. Grant stated that the map that he is showing the team depicts the big view. He referred team members to Figure 2 in the handouts, and noted that it contains zones of contribution (ZOCs), which are areas where a water supply well or a potential water supply well would draw water. He reported, for example, that if water supply well 4 (WS-4) were pumping, after a period of time contaminated water in that area could move into the well screen. Mr. Grant also explained that Inset A on the map is a close-up of the central Impact Area. He pointed out Five Corners, Tank Alley, Turpentine Road, and the area referred to as "Ground Zero." He noted that Spruce Swamp Road is the western boundary of the Impact Area, and Burboyne Road is well off from that.

    Mr. Grant stated that the picture has changed from what was seen last month, when there was a series of orange dots that indicated profile detections of explosives. He noted that that those tended to be good screening samples, which provided a pretty good idea of the contamination that would be found there. He also mentioned, however, that there sometimes is interference with profile groundwater samples because of the amount of soil that is contained within them. Mr. Grant explained that the red dots currently shown on the map depict detections in groundwater samples taken from screened wells. He noted that a cross-hair in the red dot indicated that the detection is unvalidated. For the most part, however, there is a high level of confidence that the unvalidated detections will be validated.

    Mr. Grant explained that the validation process involves checking the preliminary results reported by a laboratory to make sure that the correct results have been reported. He noted that the red dots, which are very similar to last month’s picture with the orange dots, show RDX extending from an area near Tank Alley and Turpentine Road in the center of the Impact Area up to an area just south of Five Corners. He said that red dots sort of span the ZOC for well 95-6, which at one time was considered a potential water supply well for the Town of Bourne. Mr. Grant also noted that the ZOC for well 95-15 appears to pass just slightly north of what has been found to be an area of RDX contamination.

    Mr. Grant also pointed out the ZOC for WS-4, one of the new water supply wells being considered by the Joint Program Office (JPO) to fulfill the three million gallons per day (mgd) pledge. He mentioned that other ZOCs are not seen on the map, and noted that WS-5 is farther to south, WS-3 is farther to east, and WS-2 and WS-1 are even farther east. He stated that WS-4 comes close to the area of interest in the central Impact Area.

    Mr. Cambareri reported that the Bourne Water Superintendent stated in a letter to him that the Town of Bourne no longer is considering 95-6 and 95-15 for future water supply wells because of contamination. He noted that the Town of Bourne has gone on record to say that it is not interested in those wells sites and is seeking other alternatives.

    Dr. Feigenbaum inquired about the possibility of putting a remedial system in place to intercept contamination, which has not reached those wells. He said that he thinks that thought should be given to installing remedial systems and restoring the aquifer.

    Mr. Grant referred to the RDX levels on the inner transect, and noted that the values in those monitoring wells range from about 1 ppb in the area just south of Five Corners, up to about 29 ppb "down here in 85." He noted that two labels indicate two different well screens, and explained that this means that water samples are drawn from various depths within a single monitoring well casing. This provides a concept of the thickness of the RDX contamination in the aquifer.

    Mr. Grant reported that at the western edge of the Impact Area, orange dots representing profile detections from last month now are red dots representing monitoring well detections. He noted that the concentrations are a little bit lower in this area, ranging from 1 ppb in the northern part of the transect to 8 ppb in the southern end. Also, those detections are a little bit deeper than the detections in the center of the Impact Area, which supports the concept that as the groundwater moves outward to the west, it dives deeper into the aquifer. Therefore, it there is a detection where the RDX hits the top of the water table, and it moves outward, clean water basically overlays that contamination. The contamination is expected to be deeper where it has migrated from the center of the Impact Area.

    Mr. Grant stated that another transect is shaping up at the far western area. He noted that there were no RDX detections in the profile samples from the two borings, and he mentioned that wells have been installed at those locations and sampling results are expected soon. He stated that there were detections for a few other compounds. At well 102, for example, there were detections of 2-6, DNT (dinitrotoluene), a compound that is particularly troublesome in profile samples because it often is not detected in subsequent monitoring wells installed at the same depth. Mr. Grant noted that this may be explained as an analytical interference issue. He also reported that a TNT (trinitrotoluene) breakdown product was detected at a very deep level at well 103. He said that it is uncertain whether this is interference, and noted that the depth probably would be consistent with migration from the Impact Area, although it would be very unusual to have a TNT breakdown product migrate that far. Monitoring results for well 103 are not yet available.

    Mr. Zanis inquired about 50 M1. Mr. Grant replied that nothing has changed about those monitoring well results. For every sampling round, detections have been the same in 50 M1 – a TNT breakdown product and some RDX. He also reported that there is some RDX in well 23 also. Mr. Zanis remarked that "we do have contamination that far out." Mr. Grant agreed, and noted that there certainly is contamination as far out as the Burboyne Road transect. Mr. Zanis asked Mr. Grant to identify how many thousands of feet that contamination is from the source. Mr. Grant replied that it appears to be 6000 to 8000 feet away.

    Mr. Hugus inquired about well 100, which he remembered as having a bunch of different contaminants. Mr. Grant replied that for the profile samples for that well, the shallower screen, M2, had an RDX detection, and the deeper screen, M1, had both RDX and HMX detections. Mr. Hugus asked if those detections were validated. Mr. Grant replied that they have not yet been validated, referred to the photo diode array, and noted that there is confidence that they will be validated.

    Mr. Grant continued his presentation by reporting that information at the various depths in the aquifer suggests that even for distant detections, there is a source area back toward the center of the Impact Area. He also noted that the USGS ran its model to project the groundwater flow path from some of the detections. He referred to the figure being shown and noted that the blue lines represent particle tracks. He also explained that the dashed lines depict where contamination will go over a period of time, and the solid lines depict from where the contamination is coming.

    Mr. Grant noted that in a few cases, like for well 23, the solid line goes all the way back toward the center of the Impact Area. He said that most of the recent detections have solid lines going to the same general area. However, a few of them end "somewhere in between," so it is possible that there are other source areas located just west of the front of the Impact Area. Mr. Grant stated that so far the particle track information points to a prime location for a source area to be just north of Tank Alley and just east of Turpentine Road.

    Mr. Grant then mentioned that the little diamonds on the figure represent high-use target areas (HUTA). He said that the focus of the munitions survey is to determine the effects of all the firing that occurred in the HUTA, whether there are UXO present, the condition of the UXO, and the chemistry of the soil if there have been leaches to it in that area. Mr. Grant noted that the HUTA investigation is happening in the middle of what is seen as a probable source area, based on the groundwater monitoring results. He also reported that as the sampling plan is being finalized, additional sampling will be conducted around the targets along Tank Alley. A draft field sampling plan for that location was submitted a couple of weeks ago and is now under review by the agencies and the IART.

    Mr. Zanis noted that Ogden’s older maps showed that three particle tracks were being used. He asked if Ogden took those particle tracks and "just kind of did a reconnaissance of where the source areas might be." Mr. Grant replied that Ogden has looked at aerial photographs to try to determine if there is anything in that area. Mr. Zanis reported that he recently flew the route of the southern particle track and observed a mound of something where the track ended. Mr. Grant acknowledged that Mr. Zanis had reported seeing some apparent debris in an area just upgradient of the MW-1 particle track. Mr. Grant also noted that it seems that the debris is located close enough to the drilling path to be checked out pretty easily.

    Mr. Hugus stated for the record that it has been his observation at the last IART meeting, and all previous IART meetings, that Ogden Environmental and the Guard would not say that the effect of artillery bombardment in this area was the cause of contamination; rather, they maintained that the contamination was the result of some kind of improper disposal. He asked if it is correct that the area by Tank Alley can now be discussed as a source of contamination because it is a HUTA. Mr. Grant replied that that area is a HUTA, and it is part of the equation. However, he also noted that the thinks that what really is forcing a conclusion that there are impacts from training areas is the widely distributed apparent source area. If it were narrowly confined to a couple of isolated spots, it would be more in keeping with the theory that there was disposal at certain locations. With such a large area, however, that theory would only hold true it there had been disposal over the entire area. Mr. Hugus agreed and noted that that was obvious to the IART at least two years ago. He said that he is sorry that it took so long for the Guard to say that training was implicated in the contamination being found.

    Mr. Pinaud stated that in looking at Figures 2 and 3, he notices that are a lot of validated detections of RDX in groundwater. He asked at what point the Guard would feel comfortable drawing plumes for some of those tracks. Mr. Gregson replied that the data are being studied continuously, and work at technical meetings is beginning with respect to the well data available thus far. He noted that interpreting and mapping the data is difficult because there are contaminants at different levels, both shallow and deep, in the same well. He also stated that an effort will be made to map out the extent of the contamination based on the available data, and to determine where additional data are needed in order to map the contamination more thoroughly.

    Mr. Borci said that at the last several IART meetings he has asked the team to be patient until actual groundwater data were available, and now those data are available. He noted that Mr. Gregson has said that work will be done at the upcoming technical meetings. Mr. Borci stated that the point finally has been reached where some plan view indication can be applied to the detections.

    Mr. Grant added that mapping here is not as easy to do as it was at Demolition Area 1. He noted that this is a very complicated area because of its size and the depths of contamination being seen. He also reported that the Guard expects that next week it will be submitting to the agencies and the IART a "Supplemental Response Plan for the Central Impact Area." The plan will show sectioned views of what has been observed at the technical team meetings, which is that all the RDX detections, as well as detections of a few other compounds in profile samples, have occurred over a variety of different depths. There is a general idea that all the inner transect detections are at the shallow water table, to 70 feet, with others at 30 to 100 feet, which indicates that the contamination is moving down as it moves out. However, there are a lot of little changes from profile to profile. Mr. Grant pointed out detections that are about 200 to 300 feet apart and stated that there a lot of changes between the chemistry at adjacent locations, therefore it will take a bit of ciphering to piece that information together and draw plumes for that area. He reiterated that drawing a plume at Demolition Area 1 was a much simpler task.

    Ms. Culligan asked if any trends in concentration levels have been seen at the wells that have undergone several sampling rounds. Mr. Grant replied that the wells that have gone through several sampling rounds tend to be pretty stable, with concentrations varying by only 1 or 2 ppb. Ms. Culligan asked if the "tracks," or contaminant pathways, are just effective transport lines, which do not involve factors such as diffusion or oxidation. Mr. Grant clarified that a particle track is basically just a groundwater particle that is put in at a particular elevation, and the model runs it forward to see where it will go.

    Mr. Hugus stated that he is glad to hear that DEP supports the IART’s request that plumes actually be drawn in plan view on the map. He then asked about the possibility of having a "Ground Zero" plume sketched out by the next IART meeting. Mr. Gregson replied that an effort would be made to do so. Mr. Hugus then asked if it would be easier to draw a plume at CS-19, or at the J Range. Mr. Gregson said that he thinks that the IRP has drawn something for CS-19. Mr. Aker noted that he has the cross-section and plan view of the CS-19 plume. Mr. Gregson noted that the Guard will be mapping out the central Impact Area wells.

    Mr. Hugus then asked if Ogden Environmental will be presenting information on CS-19 to the IART, as it is his understanding that CS-19 is an Air Force issue. Mr. Grant stated that the CS-19 location is sort of between the southern end of the inner and outer transects. He pointed out the location where there appears to have been a source area, and noted that it is somewhat distinguishable from other sources because the contamination there is going to be moving downward so that it "basically gets under a new source area in CS-19." Mr. Grant also said that, as Mr. Aker mentioned, new wells have been installed on the western perimeter of CS-19 in order to understand the extent of the contamination, and that is being handled by IRP right now. Mr. Hugus asked Mr. Aker to present that information to the IART at the next meeting. Mr. Aker agreed to do so.

    Mr. Cambareri said that it appears to him that there are not a lot of wells in the ZOC for well 95-15 to determine the quality of the water in that zone. Mr. Grant noted that the ZOCs and the proposed wells are shown on two separate graphics. He referred to Figure 3 and pointed out some proposed monitoring well locations, and noted that the results look good in terms of defining the northern extent of the contamination at one location. Mr. Cambareri noted that Mr. Grant had said that there may be a decrease in concentrations going out that way. Mr. Grant stated that a couple of non-detects and some pretty low numbers of 1 ppb or less, are being seen there. Mr. Cambareri remarked, "So it is kind of patchy, but with a detect on the outside." Mr. Grant agreed and said that he wishes he knew what that detection was.

    Mr. Cambareri stated that the IART often has expressed concern about lack of resolution up in the northwest quadrant. Mr. Grant noted that 96 M2 had an RDX detection of 0.4 ppb. He pointed out two locations where there were non-detects, and said that he is unsure of those well numbers. He also reported that well 86 had detections of 2.5 ppb at two screens. Mr. Cambareri asked Mr. Grant to identify the highest concentration in the interior wells. Mr. Grant replied that that the highest concentration, 85 ppb, actually is down at the southern end. Mr. Cambareri clarified that he was referring to the area along the outside transect. Mr. Grant stated that the highest concentration along the outer transect is 8 ppb, in well 89.

    Mr. Grant stated again that response plan is about to go out for review. In addition to the P22 to P27 locations, there are a couple of additional proposed well locations "up here." Locations P28 to P37 also are being proposed. The purpose of P28 and P29 will be to help define what, if anything, is coming off of the J Ranges down to the southeast. Mr. Grant said that it is very difficult to make this determination because the top of the water table now is pretty much right on top of the J-3 Range; from that direction things could go into the Impact Area, or could go pretty much any way. He also pointed out wells along the southern part of the western transect and some additional wells that he said are shaping up to be the Burboyne Road transect, or westernmost transect.

    Mr. Zanis remarked that he finds it troubling that a plume has been drawn, but is not depicted on the map being shown. He said that he does not want that to happen again, as it has happened before with the lower 5000 acres of the base. He asked if there is any way to keep the maps updated so that all the plumes can be seen at once. Mr. Grant replied that this could be done, and asked if Mr. Zanis was referring to the Demolition Area 1 plume. Mr. Zanis clarified that he was referring to the CS-19 plume. Mr. Grant stated that the CS-19 plume would be added to the map, and he mentioned that he thinks that the technical memo on that just came out today. Mr. Zanis said he would like all plumes to be on all maps.

    Dr. Feigenbaum asked if there still are explosive materials in the soil at the "source" of that plume, in the central Impact Area. Mr. Grant asked if Dr. Feigenbaum was referring to the area along the inner transect. Dr. Feigenbaum replied that he was referring to whatever area is believed to be the source area. Mr. Grant said that Ogden does not really have soil samples from areas to which most of the particle tracks are pointing. He also noted, however, that some of the particle tracks wind up in the HUTA, which is going to be sampled intensively, both in terms of soil chemistry and in terms of UXO characterization. He said that he thinks this provide a pretty good idea of what is happening in that area. Mr. Grant also noted that he would guess that the soil sampling conducted along the other targets will be out sometime in late August or September.

    Mr. Grant then stated that if comments on the plan come back soon, the plan could be finalized in August and field work could begin a couple weeks after that. He said that the HUTA samples have not been taken yet. Phase I samples taken from "Area 3," which is near Turpentine Road and Tank Alley, but not close to the targets, came back non-detect for explosives. This sampling was done before refinements were made to the soil sampling approach. Those refinements included sampling a lot closer to the target, and reducing the number of grid points, which effectively should decrease the detection limit because compositing samples eliminates the possibility of diluting out a single high detection.

    Dr. Feigenbaum noted that that project really will finalize the picture of the situation. Mr. Grant agreed, and noted that another piece that will help the understanding of the picture tremendously is the unsaturated zone modeling. He noted that everything that has been done thus far has been in the saturated zone, in the aquifer, at the water table and below. The current proposal, to which the agencies have agreed, and on which TOSC members have commented, is to do a model from the ground surface down to the water table. This will aid in understanding what levels at the ground surface could create this sort of groundwater contamination – for example, whether they are low levels, or levels that are easy to detect. Dr. Feigenbaum said that he imagines that the final results from the entire analysis will be useful for investigations all over the country. Mr. Grant said that he hopes that they are.

    Mr. Hugus asked if the Guard’s "archeological dig" is occurring at the HUTA, where intensive sampling will be done. Mr. Grant replied that it is.

    Dr. Feigenbaum inquired about the propellant investigation . Mr. Grant asked if he was referring to the gun and mortar investigation. Dr. Feigenbaum confirmed that he was. Mr. Grant reported that that investigation has been completed in terms of the field work. The Guard requested and was granted by EPA an extension to the completion date for the technical memo, which is now due on July 7, 2000. In the next two weeks that memo will be submitted to the IART for comments. Mr. Grant described the memo as a pretty massive document, and explained that there were more soil samples in this one study of gun and mortar positions than there were in all of Phase 1. The Guard requested an extension because of the large volume of information that has to be processed.

    Dr. Feigenbaum asked if the gun and mortar investigation included any water sampling. Mr. Grant replied that groundwater monitoring wells were installed at four gun positions and four mortar positions. So far, after three rounds of sampling, those wells are clean for explosives. Dr. Feigenbaum questioned whether that meant that the wells also were clean for propellants. Mr. Grant stated that they appear to be clean for propellants. Dr. Feigenbaum inquired about metals. Mr. Grant said that there have been detections of metals and some of the other compounds that are seen in monitoring wells around the Impact Area. Dr. Feigenbaum noted that he will be looking for that technical memo at the beginning of July.

    Demo Area 1 Plume (West End) Monitoring Well Replacement

    Mr. Grant stated that last IART meeting there was discussion about the shape of the Demo Area 1 RDX plume and future steps to characterize the contaminant levels in the toe of the plume. He pointed out the direction of groundwater flow from Demo Area 1, and noted that the shading on the map depicts ZOCs for Bourne public water supply wells. He also noted that there are three different lines. The outer line shows an RDX level that is non-detect, and the next line shows an RDX level of 2 ppb, which is the health advisory level. Mr. Grant said that he thinks that the inner line shows an RDX level of 10 ppb.

    Mr. Gregson noted that at the last IART meeting, Mr. James Kinney asked whether it was thought that the downgradient end of the plume should fan out more. This was discussed at the technical meeting and with the USGS, and consideration was given to how plumes in the southern part of the base, with similar small source areas, were drawn. Mr. Gregson stated that at this point he is comfortable that the plume shape that is shown probably is the most likely representation. He also noted that the Guard agreed to install a well downgradient, which would detect if the downgradient edge of the plume fanned out. Also, the Guard has agreed to install another well, contingent on whether the shape of the plume is still in doubt after the installation of the downgradient well.

    Mr. Zanis asked if Mr. Gregson is saying that another well would be added if there is a detection at the downgradient well. Mr. Gregson replied that he is. Mr. Zanis noted that he has seen plumes that have more than one toe to them. Mr. Gregson stated that the Guard will take a look at the results of the downgradient well, and if there is discomfort about the downgradient shape of the plume, more wells will be installed. Mr. Grant asked the team to keep in mind that the purpose of the current effort is to try to characterize the plume enough so that remedial technologies can be screened effectively. Additional characterization most likely would be done before a technology was deployed, and that is when refinements would start to be made. Mr. Zanis remarked that a if there were to be a surprise, it would happen later. Mr. Grant stated that it would happen before the system was designed.

    Mr. Hugus commented that while Mr. Grant has been good about providing contour lines for the lower end of the concentrations, he would suggest that contour lines for the super high concentrations also be provided. For example, at MW-31 concentrations go up to 280 ppb, which could be depicted by a thick red line perhaps. Mr. Grant stated that Mr. Prince had inquired about the schedule for "this red dot" and EPA and DEP have talked with Ogden about installing that after the supplemental wells in the Impact Area are done. Mr. Grant noted that the Impact Area response wells will be completed by the end of July, unless bad scheduling conflicts arise. That also would be the timeframe to install the downgradient well, and a second well, if necessary.

    Mr. Grant reported that deep soil sampling also is being conducted at Demo Area 1. He then described Demo Area 1 as a topographic depression, approximately one acre in size, which is surrounded by a perimeter road. Deep soil sampling conducted to date has been from the center of the depression to the west, where it is thought that some of the highest frequency demolition activities or training activities occurred. Deep soil sampling from the center of the depression to the east has been proposed in the documents for Demo Area 1; this would cover the location where MW-19 is installed. Mr. Grant stated that he thinks that sampling will start sometime in August.

    Mr. Grant noted that a couple of documents currently are out for comment. One is the tech memo issued on June 8, 2000, which describes the results from the response wells. The other is the Feasibility Study Workplan that was issued on April 7, 2000, which, although not specific to Demo Area 1, does include information about it, as requested by EPA.

    Mr. Zanis asked if soil sampling was done "underneath the chunks of C4." Mr. Grant replied yes, at Demo Area 1. Mr. Zanis inquired about the depth of the samples. Mr. Grant said that the first set of soil samples was taken only to a couple of inches.

    Mr. Hugus asked why RDX at 50 ppb was noted at MW-31. Mr. Grant explained that Mr. Hugus was looking at the latest results; the particular figure out of the tech memo depicts the current concentrations, which have changed since 280 ppb was seen. Mr. Hugus asked what has happened to the 280-ppb concentration. Mr. Grant replied that it probably has moved on.

    Mr. Grant continued his presentation by reviewing soil sampling results. He reported that in the last month results have come in from the detonation crater sampling events on May 17, 2000 and June 9, 2000. Mr. Grant then explained that there are occasions when UXO must be removed in order for the study to proceed safely. He said that some UXO can be removed and placed in a holding area until disposal in the contained detonation chamber. Other UXO, however, cannot be moved safely and must be blown in place. Soil from the crater that is formed from the detonation operation is sampled. Mr. Grant noted that current detections are fairly consistent with previous detections; explosives were detected in somewhat less than half of the detonation craters.

    Mr. Grant reported that the follow-up to this type of detection is to remove the contaminated soil and resample until clean soil is encountered. He noted that at the J-2 Range where the detonations occurred, one of the two craters had RDX. At the former A Range, two of the five craters had RDX and HMX. Mr. Grant noted that these results appear in the handout of UXO detonation results; however, they do not appear with the validated data, because they are very recent. (See attachment #2) He said that the data table shows the compounds detected, but does not show the concentrations because the data are not validated. It does, however, indicate whether the detection exceeds the reportable concentration. Mr. Grant noted that one of the five samples collected on June 9 exceeded that concentration; it measured at three times the reportable concentration.

    Mr. Grant reported that other new explosives detections were in samples from locations where C4 residuals were present, in both Demo Areas 1 and 2. At Demo Area 1, three locations were sampled; at Demo Area 2, six locations were sampled. Out of those nine locations, eight had RDX, HMX, or TNT present in the soil beneath the residual material. Basically, chunks of explosive material, which for some reason did not detonate, are being found in these former demolition areas. These are being removed for disposal in the contained detonation chamber, and the soil beneath the residual material is being sampled to determine whether contamination is present. Generally, contamination is being found in those samples. Mr. Grant reported that, similar to the detonation crater detections, follow-up involves additional removal process and additional sampling until acceptable levels are reached.

    Mr. Zanis mentioned that C4 residuals weather away and go into the groundwater. Mr. Grant stated that there appears to be a weathered block of material, but essentially it is a dry, crumbly material.

    Mr. Hugus noted that he originally had asked for specific data on the blown-in-place events so there would be further proof that exploding munitions at the ground surface leaves residues of RDX in the soil. However, the Guard has since admitted that such things do cause contamination. Mr. Hugus noted that he does want to state for the record that blown-in-place events do result in contamination. He then said that he thinks there should be a protocol for taking up the contaminated soil after each blown-in-place event called for by the explosives ordnance disposal (EOD) people. He noted that it would not make sense to cause new source areas all over Camp Edwards, and he asked if such a protocol plan is in place.

    Mr. Gregson stated that the Guard does have a plan in place with EPA to track those locations, collect additional data to ensure that the extent is defined, and then remove the soil from areas where there appears to be a problem. Mr. Hugus asked if those areas are covered up in the meantime. Mr. Gregson replied that they are covered with plastic until the soil can be removed. Mr. Hugus asked how the Guard will deal with that soil. Mr. Gregson replied that the soil will be addressed as part of the bio-treatment facility for the rapid response action.

    Dr. Feigenbaum asked Mr. Grant to identify the kind of shells that were blown in place on May 17 and June 9. Mr. Grant replied that he did not have that information handy. Mr. Borci referred Dr. Feigenbaum to the UXO detonation results in the unvalidated section of the data table. Mr. Gregson further explained that the sample designation code indicates the mortar rounds, whether 37-mm, 105-mm, and so forth. Mr. Grant agreed and noted that sample designation codes appear in the "Ogden ID" column of the table.

    Dr. Feigenbaum asked if these were relatively small areas, about the size of the craters. Mr. Grant replied that he believes there was no effective detonation on these rounds. He said that usually if only a discreet sample is collected it means that the round did not detonate because it was inert. He noted that it was not known that the round was inert, or it would not have been blown in place.

    Dr. Feigenbaum asked if it is correct that the residuals were from the C4 that was used to blow up the rounds. Mr. Grant replied that if the round itself did not contain any high explosives, the contamination probably is the result of the detonation process, rather than the existence of the round. Another possibility, which is less likely, is that there could have been preexisting contamination at that location.

    Dr. Feigenbaum asked if there are any plans to do more of these kinds of studies, to get a control on it. Mr. Grant noted that Ogden has been reporting detonation results on a monthly basis; at some point there should be discussion at the technical meetings about how to summarize those results over a longer period of time. He noted that it is not evident from the monthly reports that there is a trend in terms of the type of UXO that creates contamination; rather, it may be more related to the detonation procedure, what was used for detonation, and whether it was a clean or unclean detonation event. Mr. Grant stated that such a report has not been produced at this time.

    Dr. Feigenbaum inquired about the possibility of looking in the immediate vicinity of the crater. He noted that when a crater is created, material is removed from the crater site and scattered; therefore, that material might be of more concern than the material in the bottom of the crater itself. Mr. Grant said that he does not remember how the detonation craters are sampled, although he does know that composite sampling is done.

    Ms. Drake asked Mr. Grant to identify what is meant by "T9." Mr. Grant replied that "T9" stands for "target 9."

    Mr. Gregson noted that a supplemental sampling of those areas is a grid pattern that is about 20 feet on an edge. Each corner is sampled, and then one sample is taken in the center, 10 feet on an edge. Eight discreet samples are tested to determine the extent in a radius of about 10 feet from the center of the detonation crater. In response to an inquiry from Dr. Feigenbaum, Mr. Gregson explained that initial sampling is done within the crater itself, while supplemental sampling occurs after there has been a detection in the crater. Dr. Feigenbaum asked if those results are available. Mr. Gregson replied that that sampling has not been done yet, but will be done soon.

    Dr. Feigenbaum noted that he is concerned about the material that gets up into air during blown-in-place events. He remarked that the initial velocity of those particles probably is pretty high, and he wonders not only about the air quality effects, but also about what the IART might have been looking at in terms of the large-scale broadcast of materials in the air. Mr. Gregson stated that air monitoring was conducted during the first several rounds of these events to see if they were producing emissions to the atmosphere that were detectable downwind. He reported that the air monitoring resulted in no detections; therefore, the program has been discontinued.

    Mr. Cambareri suggested that it might make sense to implement a generic response in to in-place detonations. For example, after each blown-in-place event, several cubic yards of material could be removed. Mr. Gregson replied that this type of response would be considered if detections were seen consistently in every crater. However, as Mr. Grant stated, less than half the craters are showing detections of explosives. At this time, it is considered a good approach to deal with those craters where contamination is seen and to try to understand why contamination is found in some craters and not in others. Mr. Gregson also noted that, to a certain extent, a generic response is being implemented in that when C4 residuals are found, rather than sampling directly beneath the chunk of C4, that chunk is removed, along with about one cubic foot of the soil beneath it. There is not confidence at this time, however, that every blown-in-place location warrants soil removal.

    Mr. Prince stated that in the May 29–June 2, 2000 progress update the Guard indicated that rifle grenades may been located at site 4. He asked if this means that the grenades were located a long while ago or recently. Also, he noted that he assumes that "site 4" is well site 4. Mr. Grant stated that his recollection of that conversation was that one of the UXO personnel at the technical meeting had information that some ordnance might have been discovered at well site 4. Details about the type and amount of ordnance were not clear, however, and the Guard agreed to check into it and follow up. Mr. Prince noted that he has not seen anything further about the ordnance in later reports. Mr. Gregson stated that he thinks the ordnance were found to be inert training rounds. They were removed by EOD personnel and no other rounds have been found at that location. Mr. Borci added that one may have been a smoke round, which was placed in the safe holding area for the contained detonation chamber. He said that he believes that nothing worse than one smoke round was found.

    Agenda Item #3. Public Involvement Plan

    Mr. Murphy reported that the public involvement plan for the Impact Area and training ranges currently is being prepared by the National Guard. A draft version was submitted to EPA and DEP, and the agencies have provided comments that are being incorporated at this time. Mr. Murphy stated that one part of the plan is a section called "Community Concerns." He noted that the Guard’s contractor has begun to document those concerns, based on past meeting minutes and other items. He explained that this topic is on this evening’s agenda to provide an opportunity for people to include any specific concerns to this section of the plan. LTC Knott noted that it is his understanding that the purpose of this agenda item is for the Guard to get clarification in case there are community comments that are not clear. Mr. Murphy noted that the plan will go out for public comment, at which time any additional concerns could be included.

    Mr. Cambareri inquired about the due date for the public involvement plan is due. LTC Knott stated "we have about three weeks now." He said that there is a deadline to get a revised plan back, and EPA and DEP comments currently are being incorporated. Mr. Cambareri asked if the plan will incorporate material that came out of the interviews conducted by the gentleman from Nebraska. LTC Knott replied yes, that will be part of the plan. He also stated that the plan will be back to EPA in the middle of July, after which it will be put out for public comment. After the public comment period, the plan will be finalized.

    Mr. Prince said that he wished that the team had received the meeting agenda in advance so members would have known what was coming. Mr. Murphy said that that is a very good suggestion. Mr. Borci explained that because the contract with Operational Technologies (OpTech) ended, it was an unusual situation and there was a bit of scramble to get the agenda out. He apologized that the agenda was not sent out in advance of the meeting.

    Mr. Zanis remarked that he would like it if Ogden e-mailed its progress reports in a more timely manner. He noted that they are sometimes three to four weeks behind, and sometimes two reports are sent out at one time. He said that he would like it if they were sent as soon as possible.

    Agenda Item #4. Other Issues

    Mr. Murphy noted that Mr. Hugus had requested that an item be added to the agenda. Mr. Hugus explained that he wanted to have this opportunity to ask the citizen members of the team to remain after the meeting to talk with Mr. LiBrizzi and Ms. Culligan. He said that this request has to do with having a caucus with the TOSC part of the group.

    Mr. Hugus also commented that he thinks it would be unfortunate if CS-19 were split off from the IART’s investigations. He said that he hopes that AFCEE’s efforts and presentations will be fully integrated with what Ogden is doing and presenting.

    Mr. Hugus further noted that he would like to know more about what Tetra Tech is finding in its UXO survey. He said that the technical meeting minutes show that Tetra Tech gives presentations every time; however, there is no indication of what it being found, if anything. He said that he thinks this information would be useful to the IART, and suggested that Tetra Tech provide an update at the next IART meeting. LTC Knott stated that Tetra Tech will be providing briefings at future IART meetings.

    Archive Search Report/Geographical Information System (GIS) Scopes of Work

    Mr. Hugus noted that of particular interest to him is the recent news about World War II era chemical agent training for soldiers and the recent news about the expanded base boundary during World War II training. He said that he would like to know how this information was discovered.

    Mr. Murphy noted that this topic comes up later in the agenda under "Archive Search." Mr. Hugus countered that this is not part of the archive search because MAJ David Guido is not part of the archive search. LTC Knott explained that MAJ Guido works full time at the Impact Area Groundwater Study Office (IAGWSO) during the week, and on weekends he is the detachment commander for the Massachusetts Army Guard Historical Detachment. LTC Knott said that on drill weekends MAJ Guido’s mission or job is to look for archives and any information that will help the history of the Massachusetts Guard. He reported that MAJ Guido found a box labeled WWII and discovered the map and other things to which Mr. Hugus referred. LTC Knott stated that the following week MAJ Guido brought the material to him to be shared with DEP and EPA.

    Mr. Hugus remarked that the finds it worrisome that MAJ Guido just happened to stumble over this box in an armory in Worcester. LTC Knott explained that that armory had been converted into an archive. He said that people drop off boxes, like the one MAJ Guido found, when sorting out the belongings of family members who have died.

    Mr. Hugus stated that he still thinks it is a problem because for at least two years there has been an active attempt to gain knowledge about past activities at the base that might have caused harm to the environment, and the locations of that potential harm. However, this recent discovery was accidental, and was not part of the official ongoing archive search. Mr. Hugus said that there has not been much in the way of results from the archive search itself, and what MAJ Guido found is one of the most important things to be found so far. He said that he thinks that the USACE should be ready to dig in to the "two floors’ worth of information now, because of this discovery." Mr. Hugus clarified that he is frustrated that the ongoing archive search really has not turned up much, while an accidental discovery like this has. Mr. Zanis added, "We never did get to read the Minute Man Magazines after I presented the one that showed the smoke generators being used."

    Mr. Borci noted that a review of last October’s EPA comments about the archive search shows that the agency was very concerned that a real thorough had not been done. He also explained that this specific topic was going to be addressed as part of the archive search item because LTC Knott will be outlining steps to correct the problem. Mr. Borci said that he thinks it is inadequate not to have the historical archives completely researched and he is confident that comments made in October 1999 clearly spell out EPA’s concerns.

    Mr. Gonser stated that one of the major topics at a meeting that he attended at the Pentagon on Monday was archive search reports and the new information that has come to light. He noted that Ms. Sherri Goodman tasked all the services to look at their archive search procedures so that the whole DoD can improve its methods so that information does not "trickle out" a little at a time, and there can be confidence that all the pieces of information can be brought up as quickly as possible without spending endless amounts of time. Another aspect of archive searches that was discussed was how to determine what is significant, and how to determine for the people who are doing the search the kinds of things to look for and the kinds of things to highlight. Mr. Gonser stated that there definitely has been a lot of conversation in Washington about this particular issue.

    Mr. Zanis noted that he was told by someone at the Massachusetts Guard that he could not have the Minute Man Magazines at a secure office because issues had been found to be missing. Mr. Zanis stated that there appears to be a problem with theft in the Guard, and so he would recommend that someone accompany individuals who are granted access to archive rooms.

    Mr. Zanis also stated that he has original photographs of gas warfare training at Camp Edwards. He said that the gentleman who took the photographs will talk to some of the regulators, but does not want to be labeled as anti-military for coming forward with these original photographs. Mr. Zanis said that he has pictures of the gas chambers themselves. He also remarked that he thinks that the "actions of some people thinking that they have wrapped themselves tight in the flag" are hurting the study by inhibiting other people who have information from coming forward.

    Mr. Zanis stated that the gentleman he mentioned actually told him about the procedure of putting mustard gas in a shovel-load of dirt and walking down the row of soldiers so they could get a whiff of it. Then, the dirt would just be thrown on the ground. Mr. Zanis said that this practice could have taken place anywhere – on a road march from here to Provincetown. He noted that this makes him wonder if he really wants to find out what went on.

    Mr. Zanis also said that another gentleman gave him some Camp Edwards newspapers from 1941, which contained information about Popponesset being used as a firing range and Sandy Neck being used as an impact area. He noted that there was another area where firing occurred and where a General handed out medals for good behavior. Mr. Zanis assured the group that this information is available.

    Mr. Hugus commented that what Mr. Zanis is saying is important because chemical warfare training did not happen just during the World War II era. He said that that there is a facility where this training occurred up until recently, or, perhaps, may still be occurring. Mr. Hugus then said that he would like to know whether interviews will be conducted with people who were involved in this training, and whether agents such as mustard gas, lewisite, and other chemicals were disposed of. He said that someone has to know this information and he would like answers.

    Mr. Hugus also stated that the boundaries of MMR always have been considered the end of the study. However, if it is found that contaminants were disposed of elsewhere, those areas also should be within the purview of the IART. He stated that the does not think that the IART should just wait for people to come forward with this kind of information; rather, he thinks that the Guard should go out and find the people who have this information and ask them, with the EPA in attendance, to tell what happened.

    LTC Knott acknowledged that EPA and DEP comments indicate that there were big data gaps in the archive search report, the J-Ranges being one of them. He stated that the Guard has incorporated all those comments, and it now has the money available to negotiate with Mr. Deleppo and award contracts to the USACE. LTC Knott also reported that as part of that team, the Guard is hiring a retired police officer/private investigator, who will know how to ask the questions. Also, the Guard is hiring an historian who can compile pieces together and determine how to backtrack to look for information. In addition, the Guard is hiring a lawyer to help interpret the documents, contracts, and so forth. LTC Knott stated that the new archive search will involve interviews with anyone who is willing to talk, and will include interviews conducted by EPA and DEP.

    LTC Knott reported that he expects that the contract with the USACE will be awarded within the next 30 days. He said that EPA has provided a list of additional interviewees and the Guard already has a list of interviewees referenced in the original interviews. Also, over the last three days since the newspaper article ran, people have been calling to say that they have information. LTD Knott stated that he feels very confident that the next archive search report will be a lot better than the first one.

    Dr. Feigenbaum stated that he appreciates the report from LTC Knott, which does alleviate some of the IART’s anxieties. He also thanked Mr. Borci for reminding the team about the October letter from EPA, which indicates that the EPA is "on the case."

    Dr. Feigenbaum then noted that he wonders whether some of the recently discussed materials should be added to the list of analytes. He said that he is concerned about the breakdown products of these poisonous materials and their persistence in the environment. LTC Knott stated that he thinks these are good questions, which should be discussed at the technical meeting.

    Dr. Feigenbaum stated that he and Mr. Zanis went out to Sandy Neck, where mortar rounds, shrapnel, bullets, and so forth, can be found, which indicates that there definitely was activity on the beaches. He also said that he is almost positive that the Guard’s 1983/1984 Master Plan, which started a lot of controversy, included information about doing amphibious operations. He pointed out that this would mean that as late as the 1980s the Guard was interested in amphibious operations on these shores. Dr. Feigenbaum remarked that he has no idea what was done during the Vietnam War and the Korean War, but he thinks that information ought to be ascertainable.

    Mr. Borci said that he believes that a lot of the sites are on the formerly-used defense sites (FUDS) database. He reported that EPA is going to try to set up a meeting with the USACE, which runs the FUDS program in New England, to ensure all the known sites are included in that database. He also said that he thinks that there is a FUDS database website, and that web address could be sent out.

    Mr. Murphy asked LTC Knott if he had anything else to say about the archive search report or the Geographic Information System (GIS). Regarding the GIS, LTC Knott stated that the plan is to have the USACE place computers in all the local libraries. He explained that a hard copy still would be available as well; however, the data in the computers would be searchable, and would provide information, maps, and pictures. Mr. Hugus noted that the local libraries are overloaded with informational materials from the IRP. He suggested that the Guard utilize space in the computers already at the libraries.

    Ms. Grillo stated that while updating the IRP’s Community Involvement Plan, there was discussion about the amount of information and how to distinguish between the programs. She said that she believes that Ms. Vanessa Musgrave of the IRP brought to the JPO the issue of how to work with community libraries with respect to outdated information, although each library does have its own policy about keeping old documents. Ms. Grillo said that she thinks that computer capabilities are being considered in terms of addressing the specific issue that Mr. Hugus raised.

    Ms. Larkin reported that the NGB is going to fund the equipment for an ongoing project to coordinate with all of the MMR organizations that have environmental programs. She explained that each of the libraries will have a computer system that contains documents from all of the different organizations, thereby allowing people to have access to documents from any one of the environmental programs. Ms. Larkin noted that the libraries have been overwhelmed with documentation, and there is a study to determine what people actually use and what they request. She said that a plan will be brought to the regulators within the next couple of weeks, after which it will move forward.

    Ms. Larkin then introduced Mr. Farinella, who just started working at the JPO, and whose project for the summer is administrative records. She noted that Mr. Farinella has been working very closely with the libraries.

    Ms. Grillo noted that, as a regulator, she wants to be certain that the community and the IART also have an opportunity to weigh in on that proposal, since they are the end users. Ms. Larkin stated that once LTC Knott okays the funding, the next step will be to bring the project before the IART, and then the public. She stated that the libraries really have been an integral part of putting the project together.

    High Use Target Area Survey

    Mr. Lahti introduced himself as a senior geophysicist with Tetra Tech. He reported that an airborne geophysical survey of the HUTA is being conducted this week and next, and an innovative technology demonstration was conducted last week in the standardization area. He noted that the update on the HUTA includes the workplan development, which is now in the final comment stage from EPA and other regulators. He reported that a land surveyed site has been selected, but it may move slightly based on data from the airborne survey. The investigation should begin next month with some of the preliminary work that needs to be done.

    Mr. Lahti referred to the gridded square that was selected for the HUTA and noted that it has been located north of Tank Alley and east of Turpentine Road, based on the particle back tracking data, groundwater monitoring wells, aerial photography, and other information that was gathered over the last several months.

    Mr. Lahti stated that during a fly-over of the area last week, some decent pictures of the HUTA were taken. He pointed out Turpentine Road, MW-44, the pad for MW-93, and the area where the HUTA is expected to be located. He noted that some of the old targets there may have to be moved. Mr. Lahti then showed another view which depicted Turpentine Road with a series of wells, and pointed out the HUTA and Tank Alley.

    Mr. Lahti reported that the airborne magnetometer survey system has been used on several other impact areas around the county. The system consists of a magnetometer on three points, roughly six meters apart such that a nine-meter distance is traveled and data are collected along three line paths at the same time. He showed another view, from the front, and noted that the total length across is about 9 meters or approximately 40 feet. Mr. Lahti noted that initially the plan was to conduct the survey just over the HUTA; however, because of the equipment mobilization costs, it was decided that the survey would cover the entire Impact Area. He said that to date the HUTA has been covered and the data are being worked this evening, while this meeting is taking place.

    Mr. Lahti reported that the main purpose of an airborne survey is to survey large areas safely, accurately, and rapidly. He noted that the entire 2200-acre Impact Area should be covered in about 10 days. The data from the airborne survey will be compared with the aerial photography analysis that was done. Also, the data will be used to determine other potential areas of anomalies that may exist in the Impact Area.

    Mr. Lahti reiterated that last week an innovative technology demonstration was conducted in the standardization area where a number of ordnance items have been planted. The demonstration involved a buggy-mounted electromagnetic metal detector with a global positioning system (GPS) for accurately locating the data position. He stated that the advantages of this innovative technology is that it utilizes the proven technologies that currently are being used at the site, it is a multiple sensor system, and the electromagnetic system covers about three times the amount of ground in each pass as it goes over the area. Also, travel is at about 8 miles an hour with the arrays, and a higher density data set can be collected.

    Mr. Lahti reported that a limitation of the technology is that it is a highly site-specific system. He said that at MMR it may be applicable in some of the larger gun and mortar positions; but in smaller areas and treed areas, it would not be effective. Also, similar to the ground systems currently being used, it would require some vegetation clearance. Mr. Lahti also mentioned that while GPS works very well, it sometimes is not very effective in treed areas.

    Mr. Lahti stated that the preliminary results of the technology tested last year show that it is very capable of detecting ordnance items. It accurately locates the anomalies, and rapidly processes the preliminary data. The system is contained in a large semi-trailer with an on-site computer that prints out data within about an hour after data collection. The results, however, are very similar to current technologies being used, and the technology is being evaluated in terms of whether it is applicable at any MMR areas.

    Mr. Lahti noted that he expects to be able to provide more information at the next IART meeting regarding the work being conducted at the gun and mortar positions, Demo Area 1, and some water bodies. He added that he also hopes to provide information on the data being collected on the slit trench. He also noted that data collection on the water bodies was completed last week.

    Mr. Zanis asked if it is correct that Tetra Tech is basing the HUTA on the particle tracks and not necessarily the amount of craterage in the area. Mr. Lahti replied that it is being based on a combination of the air photographs analysis, particle tracks, archives of where the munitions were fired, and general knowledge of the site. Mr. Zanis asked if the J Ranges also would be surveyed with the helicopter. Mr. Lahti replied that the helicopter should be over the J ranges tomorrow, and recommended that Mr. Zanis not fly over that area for the next couple of weeks.

    Mr. Hugus asked if the slit trench is located along Turpentine Road. Mr. Lahti replied that it is. Mr. Hugus asked if any UXO have been found, or if the equipment still is being calibrated. Mr. Lahti replied that most of what was found in the slit trench was some car bodies, as well as some office supplies, engine parts, and that sort of thing. Also, there may have been a few casings for munitions on the surface. He noted that as yet no intrusive investigations have been done to see what is under the surface, and he has not yet seen the geophysical data for the slit trench.

    Mr. Hugus asked if all the garbage would have to be cleared away in order to find munitions in a case such as this. Mr. Lahti replied yes, all of the surface metal was moved out of the area and it was photographed and catalogued. Mr. Hugus asked if UXO have been found anywhere, or if it is too early in the work. Mr. Lahti replied that he has not talked with his UXO people, but he does not think that much was found in the area. He noted that he expects to have more information on this next month.

    J Ranges Sampling Update

    Mr. Borci noted that the team just heard Mr. Lahti talk about the HUTA part of the munitions survey. He then explained that the munitions survey is broken into several pieces, which include the HUTA in the central Impact Area, Demo Area 1, the slit trench, water bodies, 16 gun and mortar firing points, and the J Ranges. He also noted that the HUTA survey is really in two sections, the first of which occurs this summer. Based on the information that the helicopter over-flight provides, a second HUTA site will be chosen for excavation work. Mr. Borci said that it was originally thought that that location would be around MW-2, at an old target area that was used in the 1940s. However, that is yet to be decided.

    Mr. Borci stated that the J Ranges investigation will cover the J-3 range, from south to north; the L range, which is a 40-mm range just north of the J-3 Range; and the J-1 and J-2 ranges. Soil and groundwater sampling will be conducted at all of those areas this summer.

    Mr. Hugus asked who will be doing the work. Mr. Borci replied that right now the plan is that Harding Lawson, which is Textron’s contractor, and Ogden Environmental will coordinate efforts to do the sampling. LTC Knott said that it is important to note that Textron will have to perform at the same standard that EPA approves for Ogden. He said that Textron will not be released from liability for its license until there is an investigation of the all the J Ranges, by a combination of Textron and the NGB, that meets all the standards and quality objectives for the groundwater study.

    Tank Alley Target Sampling

    Mr. Borci stated that EPA is about to submit its comments on the sampling plan for this investigation that will occur later this summer. He reported that one armored personnel carrier, at the intersection of Tank Alley and Turpentine Road in the center of the Impact Area, was sampled and showed fairly high residues of what was seen in the groundwater study in explosives in soils. As a result, EPA has asked that the Guard label the targets there for sampling. Mr. Borci noted that it appears that the study will be done in two phases - Tank Alley, and then scattered targets throughout the Impact Area that were not covered as part of the mortar targets investigation.

    Phase II (b) Investigation

    Mr. Borci explained that the Phase II(b) Investigation is kind of a catch-all study for a lot of the training areas and ranges that were not covered as part of the initial investigation. He noted that from now through end of July, EPA and the Guard will be doing site reconnaissance to determine where sampling should occur. The Guard will prepare a sampling plan, which is scheduled to be presented to EPA by the end of August, at which time the IART will have an opportunity to comment on that information.

    Mr. Borci stated that the Feasibility Study Workplan, which is a requirement of AO3, was submitted on April 7, 2000. He described the workplan as a kind blueprint for how remediation will occur on the base. He noted that EPA is about to provide its comments on the workplan to the Guard, and the first item that will be addressed in the Feasibility Study Workplan is Demo Area 1. Mr. Borci mentioned that the team saw the new location for the well on the west end, with the contingency for additional wells. He then said that feasibility study process is going to be condensed so that that well will be installed as soon as possible, before reaching the feasibility study stage. Mr. Borci reiterated that Demo Area 1 will be addressed first. He noted that it is divided into two units – groundwater and soil – and groundwater will be addressed first in terms of remediation. Mr. Borci stated that he has reviewed all the plans that are out there.

    Mr. Hugus noted that Mr. Lahti showed an area that he called the HUTA, which appeared to be north of the red rectangle, and Mr. Grant’s slide showed that a ten-foot deep excavation would be happening there. LTC Knott stated that that is the same thing.

    Mr. Zanis noted that he wonders when Ogden Environmental will consider studying the uptake of these contaminants from the soils into the plants, thereby entering the food chain. He said that he asked for such a study early on, and would like to know if the regulators also will request this type of study. Mr. Borci stated that he believes that EPA would first look for a study about RDX in plants. He said that this is on the agency’s radar screen, but it has not been a high priority. He explained that EPA is going after high concentrations in soil and trying to address the threat to the groundwater first.

    Mr. Zanis noted that there is a problem with lead being taken up by plants, and he has a study that refers to this. He asked if the plants in the lead berm areas will be sampled in order to determine whether lead is entering the food chain. Mr. Borci said that this issue can be discussed at Thursday’s technical meeting. Mr. Zanis stated that he thinks it is time for this type of study to be conducted. He said that he would like to know the extent of this kind of contamination at the base, "from lead, to RDX, to you name it."

    Mr. Pinaud said that there could be preliminary discussions about this tomorrow. He also asked about the extent of information available on the issue. LTC Knott stated that a literature/data search would be the first step. Mr. Zanis noted that he has found some information on plants taking up TNT and RDX. Mr. Pinaud requested that Mr. Zanis point the regulators to that information.

    Dr. Feigenbaum asked Mr. Borci to talk about Envirogen’s work on bio-treatment of soils. He said that he thinks a small-scale demonstration was planned and there had been questions about whether the bacteria would be poisoned by TCE or other materials. Mr. Borci stated that the Guard has done extensive delineation sampling to see how much soil they are going to be taking up. He said that he believes that samples have been sent to a laboratory for treatable studies, and the data should be back soon. LTC Knott noted that this will be an agenda item at the next IART meeting.

    Popper Kettle Status

    Mr. Gregson reported that the popper kettle was removed from its location, and the contents were dumped on plastic sheeting. He noted that sub-caliber munitions were found among the ash debris, and soon the Guard will be starting the process of separating the munitions from the ash. The ash will be disposed of off-site and the munitions either will be blown in place or brought to the contained detonation chamber, as appropriate. Mr. Gregson reported that the ash debris from the opening of the popper kettle was collected and placed on plastic as well. Also, soil samples were collected from beneath the location of the popper kettle, and those results should be available soon.

    Mr. Hugus asked who used the popper kettle and what was exploded in it. Following a gesture toward Mr. Zanis, Mr. Gregson replied that he is unsure who used the popper kettle and what was done in it. He said that he can only speculate, since ash and munitions debris were found, that it was used as a burn kettle for disposing of munitions. Mr. Hugus asked if it is correct that the popper kettle was located fairly close to the J-3 range. Mr. Gregson clarified that the kettle was actually on the J-1 Range. Mr. Hugus said that he thinks it could be assumed that the kettle might have been used by the contractors at the J-1 range.

    Mr. Hugus also said that he believes that he formally requested EPA’s inquiries of the EOD unit at the 102nd Fighter Wing (FW). He noted that he thinks that one of the questions that EPA asked the EOD unit is whether or not it used the popper kettle. Mr. Hugus asked if EPA has gotten a response to that question. Mr. Borci said that he believes that the 102nd has been given an extension of about two weeks to provide its response, which is now expected by about mid July.

    Mr. Hugus said that he would like to state for the record that when he asked what was in the popper kettle, the Guard’s reaction was to ask Mr. Zanis. Mr. Hugus stated that the Guard has been operating the base and should know what was done there. He said that nobody from the Guard is forthcoming with information about any of these activities, and he thinks that it is truly amazing that he has to ask a citizen, who was not even working at that site, what went on there. Mr. Hugus remarked that perhaps LTC Bailey knows about the popper kettle, and added that he feels certain that somebody must know and there should be an effort to find out.

    Mr. Zanis stated that a lot of small arms were thrown into the popper kettle. Also, there could be fireworks debris from when fireworks from range control were stored down on the J-2 Range in the fenced-in area. He noted that he believes that the popper kettle may also have been used at Demo Area 1. Mr. Zanis stated that the EOD people mainly used the kettle to throw in a lot of old small arms. He also noted that it was right by the steel-lined pit where AVCO threw 105-mm rounds to burn with other ordnance that was found in the area. He remarked that often people would not even bother to throw stuff into the steel-lined pit, but would just throw it off to the side of the road. Mr. Zanis stated that he is sure that there are individuals at the NGB or the 102nd FW who know who was using the popper kettle, and they just have to speak up.

    Agenda Item #5. Set Next Meeting Date, Review Action Items, and Adjourn

    Mr. Murphy proposed July 27, 2000 as the date for the next IART meeting. There were objections.

    Ms. Meli then read the action items from the meeting as follows:

    1. COL Bailey’s letter of response regarding active ranges on Greenway Road will be distributed to the IART in the next weekly mailing.
    2. The air and soil sampling plan for the active ranges also will be included in the next weekly mailing.
    3. Dr. Feigenbaum requested the regulators’ assistance in obtaining an inventory of artillery weapons systems that are no longer in use.
    4. Mr. Aker will present the cross-section and plan view of Chemical Spill 19 (CS-19) at the next IART meeting.
    5. Mr. Zanis requested that all identified plumes be depicted on all IART maps.
    6. The IART will receive a copy of the propellant investigation technical memorandum in the next weekly mailing.
    7. Mr. Hugus requested that Mr. Grant include high-concentration contours in the maps.
    8. Mr. Zanis requested that Ogden distribute progress reports in a more timely fashion.
    9. Tetra Tech will be providing updates on the UXO Survey at future IART meetings.
    10. The technical meeting will address the feasibility of sampling plants for the uptake of contaminants.

    Dr. Feigenbaum thanked Mr. Murphy for facilitating the meeting and doing a great job.

    Mr. Murphy adjourned the meeting at 9:13 p.m.

Site Map | Related Links | Comments/Contact Us | Search | Home
Administrative Notice