Impact Area Review Team
Massachusetts Military Reservation
Building 330
May 17, 2000
6:00 PM

Meeting Summary

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

Ms. Frawley convened the meeting at 6:10 PM and reviewed the handouts.

Review of Action Items

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

Ms. Frawley reported that United States Environmental Protection Agency (EPA) sent a letter but a response had not yet been received as of this date.

Mr. Walsh-Rogalski reported that he had spoken to MAJ Mullen this afternoon, who said the letter was "under review by the Adjutant General (TAG)."

Mr. Hugus asked if EPA wrote a letter to the National Guard Bureau (NGB) asking for the inventory at the Ammunition Supply Point (ASP). Mr. Walsh-Rogalski replied that Mr. Hugus was correct and that he thought the letter had been forwarded to everyone on the Impact Area Review Team (IART). Mr. Hugus stated that he was just trying to establish this for the record and asked what the date of the letter was. Mr. Walsh-Rogalski replied that on May 8, 2000 EPA wrote a letter to GEN Keefe asking for a response by May 15, 2000. He added that the letter asked for two things ¾ the inventory of the contents of the ASP, and Massachusetts Army Reserve National Guard (MAARNG) representation at all public meetings relating to the IART.

Mr. Hugus asked if GEN Keefe had been the one who objected to supplying this information at the last IART meeting, or if it was someone else in the MAARNG. LTC Fitzpatrick replied that MAARNG leadership, one could say GEN Keefe, objected to release of the current inventory of ASP to the public. Mr. Hugus stated he could not hear LTC Fitzpatrick's reply. LTC Fitzpatrick replied that the state leadership, the MAARNG leadership, of which GEN Keefe is TAG, did object to releasing the current inventory of the ASP. Mr. Hugus asked if this was then the reason why the EPA request for information has not been answered. LTC Fitzpatrick stated that as Mr. Walsh-Rogalski said, MAJ Mullen is reviewing the letter to see how the State should best answer. He added that in addition to himself, the MAARNG was represented at this meeting by COL Bailey, the Camp Edwards Training Site Manager, who was in the audience.

Mr. Hugus commented that, as one of the citizens who felt that the team should be able to have access to this inventory, he would like to register a protest that the MAARNG has not been forthcoming with this information. He stated that the IART has a right to know, the TAG has missed the deadline, and he hopes the information will be provided as soon as possible. Mr. Hugus noted that, as usual, there are no consequences for a missed deadline.

LTC Knott asked Mr. Walsh-Rogalski, for clarification purposes, if MAARNG were in violation of anything when they did not respond in seven days or was that just an "asked for it" date. Mr. Walsh-Rogalski stated that EPA requested a response in seven days, so MAARNG was in violation of the Order right now.

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

Ms. Frawley reported that Mr. Zanis had forwarded a copy of his letter to Mr. Gonser. She said she believes Mr. Gonser has received the letter but that she does not know how Mr. Gonser then proceeded. LTC Knott reported that although he has not talked to Mr. Gonser, he has not received a copy of the letter. Mr. Gonser reported that he could not say that he has received it, but that he will check with Mr. Zanis. Ms. Frawley noted that the letter came out via e-mail a day or two after the last IART meeting. Mr. Gonser explained that the Joint Program Office (JPO) has not had e-mail for an extended period of time, that the Air Force Center for Environmental Excellence (AFCEE) server has been down since the Love Virus came out. Ms. Frawley stated that she would forward a hard copy to Mr. Gonser. Ms. Adams said she had a copy of the e-mail dated April 8, 2000, which was before the virus.

Mr. Hugus stated that he was also a party to this request, and that was not something the IART would like to leave for the future plans of the Environmental Impact Statement (EIS) that the JPO is helping to prepare. Mr. Hugus said the request should go to the MAARNG for immediate action. He explained that the firing ranges could potentially be in use now or this summer and, as has been said before, there are neighborhoods within a few hundred feet of these ranges; therefore the citizens do not feel it is appropriate they be used. Mr. Gonser said he will get the letter to the MAARNG at a couple of different levels, the Training arena, the Master Plan arena and the Facilities arena. LTC Knott stated that what he would like to give COL Bailey a hard copy tonight since COL Bailey was present at the meeting; that way no more time would be lost and COL Bailey could get the request to headquarters in Milford. Mr. Hugus stated that would be all right, but noted it has been two months since the request went in, things have been fumbled and the request has not gotten to its destination. He asked if the IART could ask COL Bailey for a response in a few weeks. LTC Knott said that could be done. LTC Knott went on to say that he thought it was probably more his fault, and that as he read this action item he got confused. He added that he thought Mr. Gonser had volunteered to take the request and put it into the Master Plan process, but it should have gone right to the MAARNG for the ranges, and he must have dropped the ball on that one.

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

Ms. Frawley said that this had been agreed to.

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

Ms. Frawley reported that this had been done and that the team members should have received them.

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

Ms. Frawley reported that this had been noted.

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

Ms. Frawley reported that the literature had been distributed in the May 2, 2000 Weekly Notes put out by Ogden.

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

Ms. Frawley reported that this had been done, some changes had been made to the maps, and Mr. Grant would present them during the Investigations Update.

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

Ms. Frawley reported that the term would now be "target areas" and the existing numbering scheme would continue.

9. The following agenda items will be discussed at the May 17 IART meeting:

• Textron information request submittal - NGB/EPA

• Small Arms Range testing discussion (requested by Mr. Hugus)

• Report on the Small Arms Range sampling decisions - EPA/NGB (requested by Dr. Feigenbaum)

• Blast Chamber update - EPA/NGB

• Public Information Team services - PIT

Ms. Frawley reported that these items which had been rolled over from the last IART meeting were on the agenda for this evening.

Review of Agenda

Ms. Frawley asked if there were any other additional agenda items for this evening. There was no response.

Approval of the Minutes

Ms. Frawley asked if there were any comments or changes to the March 8, 2000 meeting minutes. No changes were requested.

Ms. Frawley asked if there were any comments of changes to the April 15, 2000 meeting minutes. No changes were requested.

Agenda Item #2: Investigations Update (See Attachments #1 and #2)

Mr. Grant reviewed Ogden’s handouts for the meeting which included the note pages and maps for the discussion and an updated table called "UXO Detonation Results". He explained that the table, which contained only unvalidated data, was presented only to IART members. He added that, in addition, the handouts included the detection map package handed out to IART members at every meeting. He noted that the changes were in the explosives maps, which now included insets of the plumes in Demolition Area 1 (Demo Area 1) and the central Impact Area. Mr. Grant stated that the last handout was of the J-3 Range work plans.

Mr. Schlesinger asked if a press release had been issued stating that specifically named plumes had been found, or was the IART now just calling them plumes. Mr. Borci replied that the Demo Area 1 plume had been defined in January or February 2000.

Mr. Grant began his presentation with information on the new monitoring well (MW) installations. He reported that wells 11 through 16 out of 21 response wells had been installed in the Impact Area. He referred the team to Figure A in the handout. He said the wells shown in green are the newly installed response wells along two fences or transects, one along the western perimeter of the Impact Area, and one through the center of the Impact Area. Mr. Grant added that there were a few wells shown in red on the map, which indicated they have not yet been installed but that Ogden was in the process of installing the last five. He added that an additional well would be installed in the southwest target area.

Mr. Grant stated that the National Guard Bureau (NGB) and the Agencies have been talking about and agreed to install some new wells. He said that these wells were an "add-on" to the Response Plan and not in any plan yet. He noted their locations at the north and south ends of the inner and outer transects and stated an additional well would be installed along the particle track from MW-1 where it intersects Burgoyne Road to the west.

Mr. Grant reported that the five wells shown in red were to be completed by June 8, 2000. He stated that the additional wells would be started then and would be shown on a future map as soon as possible.

Mr. Grant commented that the Figure 1 map shows the two proposed mortar target (PMT) wells PMT-1 and PMT-2. He reported that PMT-1 was installed and was located hydraulically downgradient of a series of targets in the southwest part of the Impact Area. He added that PMT-2 was currently being installed, and was located directly downgradient of two buoy targets, Targets 9 and 10.

Mr. Grant moved on to the status of groundwater sampling, and noted that, as each group of wells had been installed at different times, they were at different stages of the sequential sampling process. He reported that the oldest wells, such as the Phase 1, Phase 2A and supplemental Installation Restoration Program (IRP) wells, had been sampled three times. He commented that a Sampling Round 4 had been added to the chart. He explained that Ogden has agreed with the Agencies on the next round of sampling which was taking place now. He said he thought that by the next update some of the bars on the graph would go to Round 4. Mr. Grant stated that there would three rounds of sampling in calendar year 2000. He said that one round was occurring now, the next round would happen in August 2000, and the third round in December 2000.

Mr. Grant stated that the newer well groups, such as the Far Field Group 2, the Gun & Mortar and the Demo 1 response wells, were a bit behind in sampling, as some had been installed as late as last Fall. He reported that as soon as three rounds were completed on all these wells, this data would be included in the evaluation of results phase and put into the calendar year 2000 sampling, if possible. He added that for some of these, such as the Gun & Mortar wells, Ogden just received third-round data. Ogden would review the data and would determine whether there are wells in that group suitable for additional sampling in calendar year 2000 and, if there are, they will be included in the August sampling round.

Mr. Grant moved on to the explosives detections in groundwater and noted that there was a set of two maps, and adaptations of the monthly handout maps are available to the IART. He explained that the monthly maps show any detections of groundwater contaminants in five different categories. Mr. Grant said that the adaptations called Figure 2 and Inset A showed similar information profile detections because Ogden has recently collected a lot of profiling data in the central portion of the Impact Area. He commented that it was important that the IART start discussing those findings. He said that he would talk about potential future response wells based on initial results.

Mr. Grant referred the team to Figure 2 and Inset A and noted that the profile results were shown in orange, while the Impact Area boundary was shown in red. He reported that the two areas of response wells were located along Turpentine Road through the center of the Impact Area, and along Spruce Swamp Road on the western perimeter of the Impact Area. He commented that these wells were all Royal Demolition Explosive (RDX) response wells installed for the purpose of delineating RDX, so the fact that Ogden is finding RDX is not too surprising. In order to delineate the extent of contamination in the Impact Area, Ogden had expected these results. Mr. Grant reiterated that the orange color shows that Ogden has profile results with explosives detections. He said that Ogden does not yet have the monitoring well results.

Mr. Grant reported that Ogden had gotten a couple of new detections since last month on the inner transect. He stated that the newer wells profiled during the past month were MW-101, MW-100, MW-99 and MW-98. Mr. Grant reported that there were explosives detections at MW-101, MW-100 and MW-99. He stated that the levels were similar to what was seen just to the south in the center of the Impact Area, between 1 to 20 parts per billion (ppb). Mr. Grant said there was no detection at MW-98. Mr. Grant explained that as you go up the line to MW-99, MW-92 had a detection but it was much lower, and he thinks that only one of the profile intervals had a detection. He said that for all intents and purposes it looks like a limit of RDX contamination at MW-99 is being reached in terms of profile results. He added that the MW-92 detection was less that 1 ppb of RDX.

Mr. Hugus asked if Mr. Grant was saying that the transect showed detections of between 1 and 20 ppb of RDX. Mr. Grant said that this was correct in profile samples. Mr. Hugus asked if there were any validated results. Mr. Grant replied that he does not believe any had been validated yet, but it is unlikely that the RDX results would change under validation. He added that the primary step that Ogden takes in validating explosives results is to check the Photo Diode Array (PDA) spectrum to determine if they are a match. Mr. Hugus asked if they all said "yes." Mr. Grant replied yes.

Mr. Hugus commented that the range of 1 to 20 ppb was pretty wide and asked Mr. Grant if he had any specific numbers on some of these wells. Mr. Grant replied that he thinks the highest detection was either at MW-93 or MW-91, of about 19 or 20 ppb. He stated that, of the newer detects found at MW-101, MW-100 and MW-99, one of those was up close to that, around 15 to 18 ppb. Mr. Grant said that for the most part Ogden was seeing higher detections at certain levels that are consistent with certain source areas and certain places. He explained that, typically at the water table, detections are in the lower range of 1 to 5 ppb, meaning there is probably a source very close to the well. He went on to say that down about 40 to 60 feet there were higher detections which means that that material came from further back toward the top of the mound. Mr. Grant noted that these particle tracks show the flow of groundwater, not the extent of contaminants. He added that if you follow a particle track back from something that is 60 feet below the water table, it comes back in here somewhere (Mr. Grant indicated the center of the Impact Area on the map), so Ogden is getting information back indicating that there are probable source areas along Turpentine Road and Tank Alley.

Mr. Hugus noted that Ogden had a "sideways" view of the plume from Demo Area 1 and asked if Mr. Grant had the same thing for this. Mr. Grant replied that Ogden did not have it yet for Demo Area 1 but that steps were underway to make that happen. He explained that Ogden first would have to get the survey data for the wells and then get particle tracks once the wells are surveyed to get a better sense of where things are coming from. He said that if you think back to six months ago, that is what Ogden is now doing for Demo Area 1. Ogden first has particle tracks in plan view, then has particle tracks in section view, and then draws plumes. Mr. Hugus commented that he was glad Ogden was doing this work and said that he urged everyone to work on that as it helps the team to understand what the plume looks like.

Mr. Prince referred to the wells located on the south end, 58MW0009E, 58MW0011E and 58MW0006E, and noted that just below it, within 1,000 feet, there were validated non-detects. He commented that this was a pretty fine line, and wondered if Ogden should go between those to see what is going on. Mr. Grant replied that there were a couple of different probable sources there. He said that the wells with the "58" prefix were IRP wells installed for delineation of Chemical Spill 19 (CS-19) and that AFCEE had developed some plume maps for CS-19. He stated that what AFCEE is seeing is a probable source in that area that is moving out to the west. Mr. Prince noted that it looked south. Mr. Grant said that it was probably a bit south of the concentrated detections, but that Ogden did have a detection at 37, upgradient of CS-19, and a detection at MW-85. Mr. Grant stated that in addition to the sources at CS-19 it was apparent that there are source areas upgradient of CS-19. He added that in section view, what is happening is that you will see detections at CS-19 coming from the water table, moving west, and then you will see detections coming from the central Impact Area moving under CS-19 to the west. Mr. Prince asked if Mr. Grant thought that was a legitimate split, the ones at the bottom being clean, and that there is probably just CS-19 and something else going on there. Mr. Grant said Ogden was not really sure yet, which is why they were proposing installing another southern response well, and would be putting another one in.

Mr. Borci asked if the map was missing PMT-1. Mr. Grant said yes, the mortar target wells were not shown on Inset A. He indicated the general location of these walls on the map. Mr. Borci asked if PMT-1 had an RDX detection. Mr. Grant replied yes. Mr. Borci stated that this would bear into Mr. Prince's question. Mr. Grant said yes, and that he would go through the results for PMT-1 shortly, but PMT-1 was a well placed downgradient of some of the mortar targets and is showing some RDX.

Dr. Feigenbaum asked Mr. Grant to give the levels at 44S and 27S. Mr. Grant stated that the level at 27S was 0.25 ppb, and at 44S the detection had been in the 1 to 3 ppb range. Dr. Feigenbaum said it does not seem to make sense, if detections of 1 to 20 ppb were found in the fence, you would expect upstream of it to get something like 20 ppb. Mr. Grant said that if you looked in section view at the detection, it was down pretty deep, so it probably was not coming from the 44S area, but from back towards Tank Alley. Dr. Feigenbaum noted that Ogden was not seeing that level anywhere and asked if Ogden had any wells to back that up. Mr. Grant said that Ogden did not have any wells in that area yet, and proposed well P-19 to try to see the extent of contamination in there. Dr. Feigenbaum stated that he thinks the IART should be thinking about another parallel well in that area to delineate the source. Mr. Grant commented that there is certainly a lot of response well thinking to get underway once Ogden got the particle track. Dr. Feigenbaum noted that it looks like the particle tracks are taking it back into the Tank Alley area, but there have not been any detections there. Mr. Grant said that there were not a whole lot of wells there. Dr. Feigenbaum asked if more wells were needed upstream. Mr. Grant replied that Ogden was talking to the agencies about that and was starting the planning phase for that.

Mr. Borci stated that EPA issued a letter to NGB asking them to collect soil samples around most of the targets along Tank Alley, including soil sampling around one of the armored personnel carriers (APCs) at the intersection of Tank Alley and Turpentine Road, and about 15 other targets. He explained that EPA asked for that because the one target EPA does have data for has fairly elevated levels of explosives compared to what had been seen at other areas. He added that EPA is looking for where the contamination is in the soil, and where these backtracks go. Mr. Borci commented that if they match up, that is a location for a well; if they do not, more thought will have to be put into it.

Mr. Schlesinger noted that Mr. Grant had said that Ogden was starting to see a limit and asked where in the northern portion of the green area just below 02M2 the limit was seen. Mr. Grant stated that MW-99 is the last boring where Ogden had profiles with significant RDX detections. Mr. Schlesinger asked what did Mr. Grant mean by limits and if Ogden would install additional wells farther downgradient. Mr. Grant said that what was Ogden was trying to do was bound the contamination in several ways. He stated that Ogden wanted to bound it to the north and south and off to the west and that Ogden was in the process of putting in additional downgradient wells to assist in that process.

Mr. Schlesinger asked if PMT-1 was less than 1,200 feet from the Bourne zone of contribution (ZOC). Mr. Grant said that that sounded right. Mr. Schlesinger asked if wells would be placed along the Bourne ZOC. Mr. Grant said that far field wells were placed along the downgradient western perimeter of the Massachusetts Military Reservation (MMR), and would ultimately show any contamination before it crosses McArthur Boulevard. He added that Ogden would probably need additional wells down there, especially if there is a detection in the second mortar target well which is closer to the ZOC.

Mr. Kinney asked if the detection at 58S had been significant. Mr. Grant replied it was significant as it was above the health advisory (HA) and was about 3 ppb. He noted that this was not as high a level as some of the detections in the central Impact Area, but what was significant about this was that it was far upgradient of anything in the central Impact Area. He added that, considering its position next to the steel-lined pit, the detection was probably related to activities that had occurred there. He said that the activities appear to be disposal activity versus the central Impact Area being a target activity. Mr. Kinney asked if Ogden was planning on putting wells farther upstream and commented that the wells seemed limited to the Tank Alley area. Mr. Grant replied that most of the particle tracks were pointing toward Tank Alley - he noted that what he really meant was estimated particle tracks, because until the wells were surveyed and the U. S. Geological Survey (USGS) ran the model backwards, Ogden could not tell exactly where they are going. He added that if some come back that far, there will be wells there, but that he thinks there are other wells around 58S because it is within the limits of the J-1 Range. Mr. Grant stated that as part of the J-1 investigation, Ogden has to look at the steel-lined pit and a nearby wastewater disposal area and try to figure out potential sources over there. Mr. Kinney commented that this is important because that is the ZOC for the wells dead north. Mr. Grant said that every ZOC, if the well is pumping hard enough, will come back towards the top of the mound and that 58S was very close to the top of the mound.

Mr. Schlesinger asked if wells were proposed north of MW-96 in the 95-15 ZOC north of MW-92. Mr. Grant replied that Ogden was proposing another well in the area.

Mr. Grant continued his presentation and moved onto the western Impact Area. He stated that there had not been much of a change since the last IART meeting. He reported that borings which had been profiled since last time were MW-96, which had a very low RDX detection of around 1 ppb at one or two intervals, and MW-97 where there was no detection. He reiterated that this was consistent with what Ogden was seeing on the inner transect, which is that the source area peters out as you get closer to Five Corners.

Mr. Grant reported that Ogden had received validated data for MW-41, which was clean. He explained that, in order to reduce clutter on the maps, Ogden tries not to label the clean wells and instead labels the wells with detections.

Mr. Prince asked if Mr. Grant could tell by the depth of the detections if the row containing wells 58MW0018B, 58MW007B and 39M2 were from CS-19 or from the upgradient area. Mr. Grant replied that 58MW0018B and 58MW007B appear to be CS-19 which is how AFCEE has drawn them. He stated that 39M2 was a bit far north of CS-19, unless Mr. Prince was talking about the bunker. Mr. Prince replied that he knew they were running under CS-19. Mr. Grant said 39M2 did not have much in the way of detections but that he thinks that once you get up to 87M2, that is where a more concentrated source of contamination is seen. Mr. Prince stated that contamination could also be from the 40M area. Mr. Grant agreed. Mr. Prince commented that as Ogden did not have any wells north of 40M1, the source could be in that area. Mr. Grant agreed.

Mr. Grant said that another interesting thing about the recent results for the western perimeter was that Ogden did manage to get samples analyzed from 87 and 86, and the results from 86 were pretty consistent with the profile results. He added that the results for 87 were a high RDX detection of 6 ppb, which was a bit lower than the profile detection of 34 ppb. He stated that RDX levels on the western perimeter were definitely above the HA but not as bad as one would think based on the profiling data.

Mr. Gschwend commented that Mr. Grant had mentioned the vertical maximum below the water table and used a number of about 40 feet down. Mr. Grant stated that on the inner transect some go deeper, although a lot are around 40 feet or so, and a couple around 65 feet or so. Mr. Gschwend asked what kind of a recharge is being added to the water table in that vicinity every year. Mr. Grant replied that he cannot answer that, but he believes that the rate of sublimation or incline there is about 1 foot in 60 feet, so for every 60 feet the groundwater travels in the area it moves downward 1 foot. He noted that this was somewhat steeper than on the western perimeter where the rate of sublimation was 1 foot in 100 feet. Mr. Gschwend commented that it sounded like an awful lot of recharge to him and said that he assumes Mr. Grant's hydrology colleagues have thought about that. Mr. Grant answered that the rate was based on the MOTH flow model that USGS has calibrated for the site, but that he was not sure what their recharge numbers are. Mr. Gschwend said that what he was trying to construct is the backtrack, in a vertical sense, to the water table to locate where these would impinge backward up to the source. He asked if that were consistent with where Mr. Grant's maps end these backtracks. Mr. Grant stated that what Ogden was seeing on the inner transect was some levels right at the water table, suggesting a source right along Turpentine Road, and the backtracks that go back as far as 65 most of the time point to an area around Tank Alley or just north of Tank Alley. Mr. Grant stated that he would say the particle tracks will end in that general vicinity when Ogden gets the particle tracks done, which is probably where another round of drilling is going to be concentrated in terms of finding out if they are at the source area now or near the top of the water table. He said Ogden would like to get a couple of clean wells in that area so that they can confirm that contaminants from the J-1 Range are not sliding out. Mr. Gschwend reiterated that 1 foot in 60 feet seems a lot. Mr. Grant agreed.

Mr. Walsh-Rogalski said he remembers reading an article in the paper that reported some of these detections and reported that the NGB thought a lot of the central Impact Area contamination was coming from burial. He asked Mr. Grant if this was still the case. Mr. Grant replied that theories abound, there are many possible theories at this point that are consistent with the data because they are at the early stages of getting the data. He added that as Ogden received more data they would start to zero in on the theories. Mr. Grant said that if Mr. Walsh-Rogalski was talking about the area of Turpentine Road and Tank Alley, that was "Ground Zero", where a lot of stuff was incoming - whether it is present as a source as unexploded ordnance (UXO) buried beneath the surface or at the surface - or whether it is present as a source because the bomb blew up and there is residual at the surface - is unclear at this point. Mr. Grant stated that Ogden was doing a couple of things to try to make that clear. He explained that aside from the additional groundwater wells, Ogden was doing some modeling to try to figure out, based on the soils present at MMR, what levels it would take to generate these concentrations in groundwater, and are we seeing those levels in the soil. He said that he thinks most people know the search for explosives in soil has not been too effective for the most part, particularly in Phase I. As Ogden is starting to look closer to the targets, they are seeing explosives at low levels. Mr. Grant said that the question is if the contaminant is not in the soil, why is it in the groundwater - is it that you have not found the source area, or is it that the source is the UXO, which cannot really be sampled unless you are under the UXO.

Mr. Hugus commented that Mr. Grant had said that there have not been detections of explosives at target areas, but the IART has been discussing for the past two meetings high levels of RDX found at a mortar target. Mr. Grant replied that it was Target 9, which is where Ogden is placing a monitoring well. He stated that Target 9 had RDX levels of up to 39,000 ppb. Mr. Hugus noted that huge RDX elevations in soil have been found at a target area. Mr. Grant replied right, but percentage-wise, the detections have been at a fairly low frequency - no question that it is there at one or two targets, but it does not seem to be widespread by any means. Mr. Hugus stated that part of the reason for that might be that these were recent targets that did not have time to degrade from rainwater or other elements. Mr. Grant said that could be. He went on to say that the theory that he was trying to reconcile is if this is the major source area along Tank Alley and Turpentine Road, Ogden has already sampled that in Phase I - not close to the targets, but along those general areas - and had not found anything, and why was that. Mr. Hugus replied that on the other hand, Ogden has not found buried caches of munitions that would indicate the sort of improper disposal that the NGB maintained as the reason for the contamination. Mr. Grant said Ogden had not, but that they have not had a survey technology yet that would do that.

Mr. Hugus commented that the IART was discussing what the RDX source is, and he thinks the team should get used to the fact that this entire area is a source area, and one single source location would not be found for the plume. He stated that once the team changed their minds about the fact that this is not like the Otis plumes with well-defined source areas, the questions will be taken care of. Mr. Hugus said that the way he sees it is that the whole area has been bombarded for 60 to 70 years, and where the shells landed and blew up was not definite, so he views the entire central Impact Area as the source. Mr. Grant commented that Mr. Hugus' views were consistent with the latest profile data; it appears to be a fairly diffuse source. He added that, again, it may make a difference whether it is a diffuse source at the surface, or low levels, because that would be cleaned up one way, or whether it is a diffuse source from scattered UXO, which would be cleaned up another way. Mr. Grant said that even in that broad generalization, there would probably be little pockets that can be explained by something else, just because there was some little disposal area or something not known yet.

Mr. Zanis asked if a low-order detonation could be a source area in the Impact Area. Mr. Grant agreed that that could be a possibility.

Mr. Zanis asked Mr. Grant what his thoughts were on the profile samples being so high and then dropping off when a regular sample is taken. Mr. Grant replied that Ogden had seen this before at Demo Area 1 on occasion. He said that he would caution the team that 6 ppb and 34 ppb were not that far apart in terms of ability to trust the data and that it probably means that the 34 ppb, which was detected at one of the every 10-foot profile samples, happened to hit a higher level in the aquifer. He added that, upon installation of a 10-foot screen, the average level is more like 6 ppb. He explained that the screen would be drawing from a 10-foot location in the aquifer, but the profile is essentially a single point in the aquifer. He described the profile as being like sticking a straw down and sucking up just a particle of water.

Mr. Zanis asked if, when the plumes were delineated, the multi-levels in the plumes would be shown. Mr. Grant replied yes, in the same way as for Demo Area 1.

Mr. Cambareri asked if there had been unvalidated detections at 96 and 92. Mr. Grant said yes. Mr. Cambareri asked if Mr. Grant had said Ogden was planning to extend the program north and to what degree north it would be extended. Mr. Grant said the program would be extended to at least another well location, the spacing would be 250 to 300 feet, so there would be another well located south of Five Corners and another well on Goat Pasture Road. Mr. Camberari asked if there were detections in these additional wells would Ogden extend the program again. Mr. Grant replied most likely.

Mr. Cambareri stated that the wells were moving toward the 95-15 ZOC and it seemed like the far-field well program was on the threshold of extending into that zone. He commented that on the basis of the ongoing water supply work, out of the five sites being looked at by the Standing Water Supply Group (SWSG), they are banking on those in the northern area, as the ones to the west are not as high yielding. He added that there still remains an issue for the Town of Bourne for two replacement wells. Mr. Cambareri said that it seems to him that well sites are being lost, this one does have a pump test, and he thinks there is justification for extending the far field well program to that area. Mr. Grant commented that he does not have the ZOCs for the new well sites yet, but that Ogden would add them to the maps as soon as possible. He indicated where they might be located on the map. Mr. Cambareri noted that most of the wells that are successful have far field wells within them to prove they have good water – and that there were no far field wells in the 95-15 zone. Mr. Grant concurred.

Mr. Borci wanted to state for the record a small difference of opinion. He said that four months ago the drilling program was entered into and EPA did not expect the extent and levels of contamination would be so widespread. Mr. Grant commented that looking back at Ogden's original detections at 1-44 to 26-59, it could be seen that they were inside all the other detections, so the extent of contamination was not clear at that time. He said that Ogden drew the particle tracks based on the way the groundwater flows, but could not draw a plume until the width is known, which is being determined now.

Mr. Grant stated that the general pattern of the detections is consistent with source areas along Turpentine Road and Tank Alley. He noted that, as Mr. Borci had mentioned, there were also a bunch of targets located along these two roads, and Ogden is in the process of finalizing a draft plan for soil sampling at these locations, which will go to the agencies and IART.

Mr. Grant reported that particle tracking was underway and the locations have recently been surveyed, the first step in particle tracking. He added that USGS would be running the model, and explained that USGS would take a particle of water at the proper depth where contamination is measured and run it backwards until it hits the water table, which is probably the tail end or source area.

Mr. Grant said that the last thing he wanted to mention was that, in addition to these results, Ogden got the results for the Target 5 boring and asked the team to refer to Figure 1. He noted the locations of the two proposed wells - PMT-2 which Ogden is working on right now is located right next to Target-9 and Target-10, and PMT-1 which is installed and is hydraulically downgradient of Targets 4, 5 and 6. He reported that PMT-1 had an RDX detection about 24 feet below the water table, which he said is consistent with that material coming to this location from a source back near those targets. He said the results from PMT-2 will be interesting because the soil detections at those three targets were much lower than at Target 9.

Mr. Grant said that the new maps on Demo Area 1 were updated from the December 1999 plume maps. He stated that when Ogden drew the maps in December 1999, the RDX extent had been based on profile results, but had since been updated based on groundwater monitoring well results which were much more accurate. He noted that Figure 5.3 illustrated three different lines extending from Demo Area 1 around a groundwater flow path to the west. He explained that the three lines represent estimated RDX concentrations: the outer interval having an RDX concentration of between the detection limit and 2 ppb, with 2 ppb being the HA; the next interval represented an RDX concentration of between 2 to 10 ppb; and the last interval represented an RDX concentration of greater than 10 ppb. He noted that this map was a refinement of the map presented several months ago, and, as Ogden goes through the process, further changes in the plume depiction for Demo Area 1 will be presented at the IART meetings. Mr. Grant said that the plume outlines were shown on the monthly Progress Report maps and the monthly IART handout maps and that the changes would be included in these venues also.

Mr. Schlesinger asked if the shape of the western part of the ellipse was inaccurate as it implies that the contamination goes back toward the road when it probably does not. Mr. Grant said he was not sure what Mr. Schlesinger meant but that Ogden put dotted lines on the western edge of the plume to indicate that Ogden does not have as much data as they would like there and would propose a well in that area to further refine that. Mr. Schlesinger said he was wondering, if water flows outward from the source, why does it suddenly flow back toward the center of the track. Mr. Grant asked if Mr. Schlesinger was asking why the plume was not following the particle track. Mr. Schlesinger asked why the plume was not shaped like a fan instead of like a bean and asked why the plume did not extend outward from MW-74 instead of inward toward the particle track. Mr. Grant said Mr. Schlesinger would have to talk to the hydrogeologist or the question could be put on the agenda for a future IART meeting. He said he was not sure what the reasons were, but that he knew there was a non-detect at MW-36. LTC Knott said that this was good a question that would need to be answered.

Mr. Zanis said that he thinks that wells are needed south of MW-34 and that the plume is far too short for the time frame and for how much water goes into the kettle hole, where the recharge is ten times more than what goes into the Impact Area. Mr. Grant stated that this topic has been discussed in the technical meetings. He added that it is a short plume, about a 10-year-long plume, and that the big unknown is how long it took to get back to the water table. Mr. Grant commented that, as Mr. Zanis mentioned, it is a shorter path, 40 feet instead of 100 feet, which is more typical. Mr. Zanis asked if there were a funnel effect from the kettle hole. Mr. Grant said that the kettle hole would bring a little runoff in. Mr. Zanis replied that it would be a lot of runoff and then there would be head pressure from all the water there. Mr. Grant said he thinks that there is a greater amount of infiltration occurring because of the runoff going into the bottom of the bowl. He added that he did not think it could be called a head as there is not a constantly saturated zone, there is material at the surface. Mr. Zanis commented that it has been pretty saturated for a long time. Mr. Grant replied that there is a pond there, but underneath the pond the soil was more or less dry for 40 feet before the water table. Mr. Zanis asked if Mr. Grant did not think wells were needed south of that. Mr. Grant asked if Mr. Zanis meant south of the toe of the plume. Mr. Zanis concurred. Mr. Grant said yes, Ogden proposed one well. He explained that at this point Ogden felt like they were starting to get a handle on the geometry of the plume and were passing from the investigation mode to thinking about remediation. He noted that this was one of the areas mentioned in the Field Sampling (FS) Work Plan because Ogden wants to start planning what technologies will be used to clean up the groundwater. He added that as part of that preparation of remediation, there would be additional delineation - putting in wells - how wide is it down there - in order to devise a system that will catch the whole thing. Mr. Borci commented that this is the picture expected with the location of that source. He explained that the placement of wells MW-34 and MW-36 was based on following the particle track out of MW-19, and that the green line in Figure 5-3 is the particle track. Mr. Borci said the map was slightly misleading, as the legends crop off part of the green, which is the area of the lowest Bourne water supply wells.

Mr. Hugus asked if Mr. Grant stated that the timeline for the plume was ten years. Mr. Grant replied yes. Mr. Hugus commented that Demo Area 1 had been in use for longer than ten years and asked why the timeline only went for ten years. Mr. Grant said that it was possible that more concentrated use took place in the late 1970s and early 1980s, and took another five or ten years for the RDX to get to the water table and start moving. Mr. Hugus asked if the time frame was then really 15 years. Mr. Grant said that at this point it was not known for sure how long it takes RDX at the surface of Demo Area 1 to dissolve and run through the 40 feet of soil to the water table.

Mr. Hugus stated that he assumes that this would be the first plume to get remediation and wondered what was left to be done before talking about that. He noted that the way the plume is drawn, it looks as if a well fence could be put in at the toe of the plume right now. He asked if NGB were not ready for that yet and added that he would love to hear from the regulators about this. Mr. Borci stated that in the FS Work Plan, this is the first source area that will be addressed. Mr. Borci said EPA had just received the plan which they would review and provide comments on. Mr. Borci said that this was on what he would consider an expedited schedule. Mr. Grant said that the steps were that first Ogden would have to issue the report, and everyone has to agree on the delineations. He added that, at that point, there is going to be some additional investigations to get, for example, the southern toe of the plume; there would be a screening report prepared to look at the technologies to be used for remediation. He said the screening report could be prepared quickly, as an evaluation for some of the technologies for Demo Area 1 had already been done last year and finalized in January 2000. Mr. Grant said the process set up in Administrative Order #3 (AO #3) was not a lengthy process, but does involve steps of submittals, and each submittal goes out to the public for review.

Mr. Kinney asked if the contours drawn in Figure 5.3 were based on just the monitoring wells shown on the figure. Mr. Grant said that was correct. Mr. Kinney commented that then MW-74, for instance, is non-detect so is assumed to be the northern edge. Mr. Grant agreed. Mr. Kinney asked if that exercise in connecting the dots could change if more wells were in place. Mr. Grant replied yes. Mr. Kinney said that logically the question is how many more wells did Ogden plan to put in and when. Mr. Kinney said he did not know, for instance how many times MW-74 was sampled. He explained that if MW-74 was only sampled that one time, that would not give him any assurance that it was not contaminated as, had been noted with the IRP process, one day it could be contaminated and the next day it could be gone. Mr. Grant said that was certainly possible but the plume is constructed based on the data and/or the hydrogeology and modeling results, which suggest things will pass in certain directions. Mr. Grant said that for Demo Area 1, Ogden thinks it has a fairly well-defined source area. He added that it looks like there is a depression where things happened and that most things tended to stay in the depression, as shown by the soil sampling. Mr. Grant said Ogden had used all that information to aid in drawing the picture of what is going on in Demo Area 1. He added that there are definitely uncertainties, which are represented by a dashed line. Mr. Grant said that the point that Ogden was getting to was that Ogden feels pretty comfortable with the general configuration of the contaminants, and that may be enough comfort to start planning for remedies.

Mr. Kinney stated that he did not want to stop Ogden from planning for remedies, but he thinks they should keep in mind CS-4, CS-10, Storm Drain 5 (SD-5) and all the ones that were part of the IRP process. He said they were told the plumes were delineated, and it turned out AFCEE was off by huge factors. Mr. Grant said that there were two opportunities for input and that he was sure the agencies were listening to Mr. Kinney. He said that one opportunity was the FS Work Plan which talks about what needs to be done at Demo Area 1 to get to the remedy stage, and the other is a technical memorandum to be issued in a couple of weeks which will say what Ogden thinks it is. Mr. Grant added that the agencies and the IART could comment on these. Ms. Drake said she had commented on plume definition previously. She explained that this plume more or less outlines an area of contamination, and the team is right to point out there are data gaps. Ms. Drake commented that there are even more data gaps than are apparent by looking at the data unless you contour the plume yourself. She added that the data could be re-contoured based on a couple of blobs as opposed to a long elongated continuous plume. Ms. Drake stated that it was in the NGB’s interest to define the plume so that when NGB evaluates remediation they will know exactly where the contamination is and is not. She stated that what has been done is to give the IART the worst case picture based on the current data with the ill-defined areas shown with dashes.

Mr. Kinney asked how many more wells were planned. Mr. Grant replied that only one well was planned for the southern toe of the plume. Mr. Kinney asked how many more samplings of existing wells would occur. Mr. Grant said that there would be two additional samplings.

Mr. Schlesinger asked if Mr. Grant could indicate the road on the map. Mr. Grant did so.

Dr. Feigenbaum commented that he supports his colleague Mr. Kinney in that he thinks more than one well is needed if the IART is to plan a remediation strategy. He noted that a treatment facility would be a fairly large commitment and, once put in place, would be pretty hard to move if NGB found they had not done it correctly.

LTC Knott said that he agreed with Dr. Feigenbaum and Mr. Kinney and that NGB would need to install more wells, but that Mr. Grant had answered the question correctly. He added that although only one well was planned right now, there would be more than just that one well.

Dr. Feigenbaum stated that the IART should not be committed to just a pump-and-treat strategy as there might be some in-situ or bio-remediation or recirculating wells. He commented that all strategies should be put on the table before committing to any one strategy. LTC Knott replied that NGB has established a team of experts from the Army Environmental Center (AEC) and the contractors to look at other innovative technologies so that when NGB gets to the point in the FS Work Plan of recommending a remedy to the EPA, they will have already tested several. LTC Knott said that the team of experts had met this morning for several hours, and he would have a recommendation next week on some new technologies that may work on soil, groundwater or both. LTC Knott said he does not want to wait until December to have these tools available. LTC Knott said that he was against pump and treat, especially in the central Impact Area, and he would like to be as unobtrusive as possible and still get the job done. Dr. Feigenbaum stated that NGB did not have the access problems the IRP has, and could essentially put wells anywhere and not discomfort anybody.

Dr. Feigenbaum referred to Mr. Schlesinger’s question and asked if the outer line was a non-detect line. Mr. Grant replied yes. Dr. Feigenbaum said that, assuming the groundwater flow is fanning out, the concentration of contaminants would go down as it does fan out, which is going to cause the non-detect line to curl in. He stated that it does not mean there is no more plume, it just means that it is the detection limit. Mr. Schlesinger asked what causes MW-76 to curl back in if the groundwater is going in the other direction. Mr. Borci commented that he did not want to cut people off, but that he thinks this conversation would be best for the next meeting, after the IART has the draft technical memorandum, so that the team can really discuss some of the items, see what the NGB is thinking, and how many wells they are proposing. Dr. Feigenbaum commented that it is a concentration question, it does not show you the direction of flow.

Mr. Cambareri said he thinks there have been a series of synoptic water tables in this project at this time and although he has a high degree of confidence in the computer model and the particle path, it seems to him it would be good to take a look and do an assessment of those synoptic water table maps and see if indeed there is no variation of flow from the model in that area if only one well would be installed.

Mr. Stahl noted that Mr. Grant had said that two more rounds of sampling would be done and asked what the proposed dates for those were. Mr. Grant replied that the nominal spacing was about three months, a round was being sampled right about now, and the last round would be in August 2000. Mr. Stahl asked if Ogden expected to see any infiltration in MW-36 and MW-34. He asked if it was expected that the RDX concentrations would increase in those wells during the rest of the samplings. Mr. Grant said he would expect it, but was not sure if the time scale would be that short - from August it might be a year, rather than a few months. Mr. Stahl noted that Mr. Grant had mentioned that the track was a 10-year track. Mr. Grant added that flow velocity was a foot or a couple of feet per day.

Mr. Grant reported that the second map for Demo Area 1 was a section view (Figure 5.11) looking to the north, with Demo Area 1 to the right hand side, and to the east and a little farther to the west would be Frank Perkins Road. Mr. Grant said that Ogden has in the past shown a particle track section view showing groundwater flow path, but what Ogden was doing now is mapping the extent of RDX using the same colors and methodologies so the IART could see that there was a vertical depression of groundwater moving off to the west. Mr. Grant reported that at the toe of the plume, the water table wells were clean. He said that this map is consistent with the model. Mr. Grant commented that when devising remedies, you would want to focus your remedy not on the whole saturated zone, but the section where the contamination is. Mr. Grant reported that the technical memorandum will be submitted June 8, 2000 for comment by the agencies and other stakeholders.

Mr. Grant’s last slide pertained to explosives detections in soils. He reported Ogden was not doing much soil sampling right now except for UXO detonation events, because Ogden has completed the big soil sampling projects like the Gun & Mortar positions sampling. He reported that the detections Ogden was getting related to the detonation of UXO. He explained that UXO that can be moved is transported into a safe holding area for disposal in a controlled detonation chamber (CDC), and the UXO that cannot be moved is disposed of by blowing in place.

Mr. Grant said detections Ogden has seen in the last month are for three different events. He stated that for the March 27, 2000 detonation on the J-2 Range, one out of the three craters had a Her Majesty’s Explosive (HMX) detection of below 1,000 ppb. Mr. Grant reported that, at the April 21, 2000 event, RDX and HMX were detected at five out of ten craters, which were scattered detections as the detonations were in different locations. He reported that three of the craters had RDX levels exceeding reportable concentrations for S-1 soils under the Massachusetts Contingency Plan (MCP). Mr. Grant said that the last detonation event occurred May 2, 2000. He reported that in this case, four out of 22 craters had explosives detections, including RDX, HMX and trinitrotoluene (TNT) and 2-NT, which might be the first detection Ogden has had of that compound. Mr. Grant stated that in this case, out of those four locations with detections, one of those locations had an RDX level above the reportable concentration (RCS-1). He concluded that RDX seems to be the compound detected at the highest level, occasionally exceeding reportable concentrations under the MCP. Mr. Grant said that again, the locations are in a handout, which was an update sent by e-mail and regular mail on May 2, 2000. He noted that the mailing contained two tables, one of validated data and one of unvalidated data, and that his presentation is an update of the unvalidated table; the validated table has not changed. LTC Knott added that this was in response to Mr. Hugus’ request last month.

Mr. Hugus commented that he appreciated Ogden and NGB responding to his request for a table of soil samples from purposeful detonation events but said that he did not understand the table. He explained that he expected to see the explosive compound listed and what ppbs were found. Mr. Grant explained how to read the table. He said if you read the columns from left to right, the left column will have an identifier for the sample which indicates which crater it was taken out of; the sample data is indicated; beginning and end depths are the depths below ground surface which for the most part is 0 to 3 inches; the analytical method is 8330; and the analyte column gives the name of the compound. Mr. Grant noted that the analyte column did not use abbreviations and listed the following compounds: 2,4,6 trinitrotoluene is TNT; Hexahydro-1,3,5-Trinito,1,3,5-Trizene is RDX and Octahydro-1,3,5,7 is HMX. LTC Knott said that the report could be simplified so the team could read it a little better. Mr. Grant said that there is no column for concentrations because concentrations are not released for unvalidated data, but the table does show any exceedence of RCS-1, in that, the last column on the right hand side will have an "X" in it.

Mr. Hugus asked what RCS-1 stood for. Mr. Grant replied that it was the reportable concentration for S-1 soils under the MCP. Mr. Hugus asked if that was based on the Massachusetts Contingency Plan of Reportable Concentrations which the team has said they do not agreed with, as they are way too high. Mr. Grant said that it is not necessarily a level that is actionable, but something that is a criteria to say whether or not something is high. Mr. Hugus asked how much RDX in soil is permitted under the MCP. Mr. Pinaud said he thought this had been discussed at the IART before and that the reporting concentration of RDX was 100 parts per million (ppm). He said he does not believe there is a cleanup standard for RDX. Mr. Hugus stated that he does not think this table or anything that the IART does in examining explosives concentrations in soil should be based on the MCP, as their levels do not apply or are too high to be meaningful to the IART. Mr. Grant said it was not the intent to use MCP levels for any kinds of cleanup decisions. Mr. Hugus asked why Ogden did not use the bare data instead of the MCP. Mr. Grant said that would be provided as soon as it is validated. Mr. Zanis asked why it was taking so long to validate the data. Mr. Grant replied that Ogden has expedited other samples, usually groundwater samples, and that these samples could be expedited if that was desired.

Ms. Garcia-Surette stated that she serves as Deputy Regional Director and stated that she would like to clarify one thing. She commented that with respect to the RCS-1 category for soils, the bottom line with those notification numbers is that they are not necessarily based on health and that it could be any other criteria that warrants reporting to the Commonwealth. Ms. Garcia-Surette added that the actual soil standards that are part of the Method 1 cleanup number are all risk-driven and she understands, as she sits on the Steering Committee for review, that every five years the MCP is revamped. She said that right now, Massachusetts Department of Environmental Protection (MA DEP) was in the process of calculating the soil and groundwater standards for RDX cleanup.

Mr. Hugus said that he would like to stress that the IART should deal with the raw data rather than what is above or below the MCP limit. He asked if it would be possible to do that. Mr. Borci replied that he thinks what answers Mr. Hugus’ question is that, as part of the Rapid Response Actions (RRA), the cleanup standard being used is 120 ppb, which is the detection limit for RDX, until the site-specific modeling is completed. He added that basically the cleanup is to background at this point, and that, whether or not there is an "X" in the column, if that concentration is above 120 ppb, EPA is asking the NGB to address that. Mr. Hugus stated that he wants to know what the concentration is so he can understand what is being done.

Mr. Pinaud commented that the RCS-1 column was on the table because MA DEP has asked NGB to put that column on all the data sheets they produce so that NGB is reminded that they have to report these values to MA DEP to be in compliance with the MCP.

Mr. Zanis asked if Mr. Grant was saying when the craters are sampled there are great variations. Mr. Grant agreed. Mr. Zanis commented that potentially every crater in the Impact Area could be a source area. Mr. Grant answered maybe, maybe not, and said that at this point Ogden was looking at the information to try to decide if the detection is from the round itself or from the detonation of the round. He added that there is information that suggests that the detonation is what is creating the problem, and stated that for example Ogden is finding detections at locations where the round is inert. Mr. Grant reported that Ogden was in the process of trying to piece together the puzzle, but the information suggests that a lot of this is due to the explosives added to the detonation process.

Mr. Zanis commented that it seems like he has stated many times before that after artillery practice he walked down through Tank Alley where the ground was still smoking and he could smell the RDX. He stated that to him it was pretty obvious that the detonation of the round contaminates the ground.

Dr. Feigenbaum said that in order to understand the table, another column would be needed to note if the round was inert or not. Mr. Grant replied that this information was a summary provided at Mr. Hugus’ request, and that he realizes it does not have everything the IART wanted. He stated that there was also a monthly reporting process where the results of detonation events that have occurred are put into a report to the agencies. He added that in a couple of months all this information would be validated and the IART would be able to see everything. Dr. Feigenbaum asked if the IART would have that. Mr. Grant replied yes. Dr. Feigenbaum asked that the report include whether the round was inert or not. Mr. Grant said the report would talk about whether the round was inert or not, and whether there was a problem with a detonation.

Mr. Stahl asked if there were any interest in going back to these sites and monitoring them again to see if the concentration goes down, how fast it goes down, and to try and get an idea of degradation or movement from these. He added that if they are sources of contamination that would be interesting to see. Mr. Grant replied that the main interest has been in cleaning up these sites, which is what the NGB has submitted plans for to the agencies - to go back with additional sampling for removal purposes. Mr. Grant said that what Mr. Stahl is talking about is confirmation of fate and transport theories. He added that it would be interesting to try that but really tough as the materials are heterogeneous and it would be hard to sample the same place twice. Mr. Stahl asked if the sites continued to be used for active training purposes, would everyplace a round hit need cleanup. Mr. Grant replied that this was something Ogden was trying to answer in the modeling study and that he knows Technical Outreach Services to the Communities (TOSC) has provided comments recently on the measurements approach for trying to parameterize the unsaturated zone model.

Mr. Hugus commented that the reason that he was interested in seeing these results was that since open detonation is occurring in order to get rid of dangerous UXO, it provides the IART with a chance to do an experiment on whether explosives residues are left in the soil. He added that the IART could then answer the question whether firing an artillery or mortar round leaves explosives in the soil. Mr. Hugus commented that he did not think this question needed to be answered anymore and that he thinks there is plenty of proof, but this is an experiment that can be controlled and the IART could get results from the experiment for further proof of that.

Mr. Hugus added that, on the other hand, he does not think open detonation should be done, which is why he looks forward to hearing about the detonation chamber later on, but since it may occur again he would like to see if it would be possible to test for air emissions from the next open detonation so that the IART knows what the effects are not only on the soil, but on the air that people breathe. Mr. Grant reported that air emissions testing was done for the first three or four detonation events and Ogden was not getting detections, so that part of the post-detonation sampling was discontinued. Mr. Hugus asked if Mr. Grant felt that it was fair, and had been 360° . Mr. Grant answered that the air sampling was at a down-wind air monitoring station and explained that Ogden could not put the station as close to the detonation event as they would have liked, but had placed it as close as they could. Mr. Hugus asked how far it was. Mr. Grant said the distances varied quite a bit, but that he did not know them offhand. He stated he could get that information. Mr. Grant added that in some cases there was a road conveniently downwind, but that in other cases there was no way to put the station downwind except at a road 100 to 200 feet away.

Agenda Item #3.. Textron Information Request Submittal (See Attachments #3, #4 and #5)

Information Request and Response

Ms. Dolan stated she would keep her remarks brief and welcomed Textron Systems Corporation (Textron) back to the IART meetings. She said she would let Ms. Lisa Wilson of Textron introduce who was with her tonight. Ms. Dolan reported that in December, 1999 AFCEE sent 104E information requests, pursuant to Comprehensive Environmental Response, Competition and Liability Act (CERCLA) information gathering authority, to Textron. She said that at about the same time NGB provided comments to Textron as to how to format a preliminary assessment Phase 1 report. Ms. Dolan said that on February 25, 2000 Textron submitted their 104E information request, which she hoped the IART members all had. Ms. Dolan reported that the IART members should have also received Textron’s Phase I Report - which if they did not have, Ogden could provide; also Textron’s Phase 2 Sampling & Analysis Plan for those ranges; and most recently, which the team might not have yet, a revised 104E response. She said that the revised 104E is reflective of the Phase 1 Report.

Ms. Dolan commented that the 104E Response provided a lot of information that had not currently been presented to the IART and also provided details of operations that the IART had been aware of over the course of the Impact Area Groundwater Study (IAGS). She stated that the 104E response does raise many questions, some of which have been formatted in a letter EPA sent to Textron on May 11, 2000, which she said Ms. Adams would review.

Ms. Dolan said she would only give some highlights from the 104E response for consideration by the team and listed them as follows:

• In the discussion of the Loading building, the Melt-pour facility, it indicates that 11 depleted uranium (DU) test warheads were loaded at the facility, however they were tested off-site in New Mexico.
  

• There was an artillery range on the site where 8-inch rounds and other tests occurred. Operations at that range are not adequately defined yet.

• There is a warhead test firing range where different types of explosively-formed projectiles (EFPs) were tested.

• There is a giant PATRIOT testing area where a test of the self-destruct system for the Minuteman 1 missile occurred.

• There is a demolition area behind the concrete targets consisting of a detonation pit and a burn box. Explosive wastes, propellants and munitions, including some from Textron’s Wilmington, MA facility, were burned or detonated in that area.

• There is a description of an ordnance assembly in the X-Ray building and also the Environmental Test and Assembly building. Those operations are not adequately described in the 104E response.

• With respect to the J-1 Range, where AVCO operated from 1980-1986, the primary operations conducted there were over-pressure testing of tank barrels using heat and the discarding of SABER rounds, 105 mm.

• Textron’s response indicates that propellant burning took place on the Range road.

• Textron indicates there was an Open Burn/Open Detonation (OB/OD) area near the 2,000-meter berm at the J-1 Range, which was significant.

• Textron indicates burning of slurry, which consisted of lead azide, RDX, freon and alcohol, took place near the 1,000-meter range.

Ms. Dolan reported that Textron would follow Ms. Adams’ statements, and present their work plans for the J-1 and J-3 Ranges. She added that Ogden would follow with a presentation on the J-3 Range. She reported that Ogden had disseminated work plans for the J-1, J-3 and L Ranges to the IART members. Ms. Dolan asked that the team be aware that the schedules Ogden and Textron have put together do not currently meld - there is some overlap but they are not on the same track.

Ms. Adams commented that Ms. Dolan indicated EPA sent out a subsequent information request, pursuant to the authority of the Resource Conservation and Recovery Act (RCRA), to clarify some issues EPA had concerning the original response to NGB’s information request. Ms. Adams stated that the IART members should have received copies by e-mail on Monday and that they were also available at the table this evening. Ms. Adams said that notable questions to be followed up on were getting hold of documents, if any exist, relating to the transportation, loading and storage of the 11 DU test warheads loaded at the J-3 Range, how they were shipped, and other information regarding their ultimate testing in New Mexico. She added that EPA wanted additional information concerning activities conducted by the Explosive Ordnance Disposal (EOD) Unit at the Base and stated that it is apparent from the Textron original response that EOD was involved with disposal of Textron waste. Ms. Adams stated EPA has asked for details regarding the transportation, storage and disposal of waste from Textron’s Wilmington, MA facility, and that EPA has asked Textron to more specifically identify all persons with knowledge of the burning of the excess explosives during the time Atlantic Research operated the J-1 Range. She said that some people had mentioned that they had follow-up questions based on the original Textron information response, and asked that the questions be forwarded to EPA who would make every effort to get Textron to respond to them.

Ms. Wilson introduced herself as an attorney with Textron, then introduced David McCabe and Robert Nicoloro as Environmental Consultants with Harding-Lawson Associates (HLA), and Richard Plzak, a Textron employee who worked at the J-3 Range quite often and who possessed a great deal of information about the past history.

Ms. Wilson said she would also like to clarify what Ms. Adams had spoken about in that it was unclear when Ms. Dolan spoke about the burning of propellant and other activities that occurred on J-1 Range. She stated that those activities may have occurred on J-1 Range, but Textron says they are not attributable to activities conducted by AVCO or Textron. Ms. Wilson stated that Mr. McCabe would give the presentation.

Work Plans

Mr. McCabe introduced himself as a hydrogeologist with HLA and stated he was heading up the Phase 2 investigation at the J-1 and J-3 Ranges. He noted that as was mentioned, Textron submitted their Phase 1 investigation in April 2000 as part of Textron’s closure of operations at the J-3 Range. He reported that, as a result of completing that Phase 1, Textron identified conditions requiring investigation as part of their Phase 2. He said that most of the areas were at the J-3 Range, with one area at the J-1 Range.

Mr. McCabe stated that the Phase 2 evaluation’s objective is to evaluate each of the conditions of concern identified in Phase 1 and said that he just wanted to stress that the scope of this investigation he was presenting tonight is an iterative process and that Textron will be continually evaluating the data, and the scope may expand as necessary. He said he would point out that Textron had submitted the Scope of Work (SOW) which has been distributed to the IART and that Textron recently met with EPA and submitted the SOW to them.

Mr. McCabe said that he had grouped the investigation areas into areas of common use, and displayed a map of the J-3 Range. He reported that the first area was the Test Ranges on the J-3 which consisted of firing points, ranges and berms. He said that in each of those areas HLA was collecting between three to four samples of surface soil at each location and analyzing the samples using 8330 and also for metals. He added that each soil sample would be screened in the field for volatile organic compounds (VOCs) and if there were any indications that VOCs were present, that sample would be submitted to a laboratory for VOC analysis as well. Mr. McCabe reported that the 20 mm range, and the firing ranges and berms in that area, would each be sampled. He added that the sampling interval for surface soils would be 3 to 6 inches. Mr. McCabe reported that the artillery range in the center of the site would also be evaluated, and noted the locations of the gun positions and concrete targets on the map. He explained that HLA would sample around the gun positions and at the bases of the targets. Mr. McCabe also said that at the warhead test firing area mentioned, HLA would collect surface soil samples around those gun positions. Mr. McCabe noted that the setup of the giant PATRIOT testing area was a 20 ft. x 20 ft. bermed area. He said that since the exact gun position was not known and the test has been dismantled, HLA would enact a grid-based sampling approach, covering the area with a 20-ft. x 40-ft. grid.

Mr. McCabe reported that the second area HLA would evaluate included both the area where burning and demolition occurred. He indicated the location of the first burn area on the map and noted there was a former burn kettle which he thought had been a modified cutoff buoy used to burn ordnance and other materials. He said the kettle was no longer there, but HLA would do surface soil sampling around the area where the kettle used to be. Mr. McCabe stated that in those areas HLA would be looking for explosives, metals and fuel residuals. He explained the reason HLA would be looking for fuel residuals was that fuels were reportedly used as accelerants. Mr. McCabe reported that a second burn area located north of the targets was a burn box, which was a 4 ft. x 4 ft. or 5 ft. x 5 ft. concrete pad with a shallow pan on top and a metal grate within where various materials were burned. He added that HLA would sample around the perimeter and noted that the concrete pad still existed. He next indicated the location of the demolition area and reported that HLA would do surface soil sampling in that area as well. Mr. McCabe explained that because of the likelihood of a vertical distribution potential in that area, HLA would also do soil borings down to 16 feet to confirm if there are explosives there and the vertical distribution of explosives if they are there as well.

Mr. McCabe stated that the next grouping included dry wells and septic systems. He said that there was a dry well associated with the Workshop building, and that photo development was done in that building. He reported that based on the interviews conducted, it appears that the photo-processing chemical discharged to a dry well outside of the Workshop building and that HLA would collect a grab sample from that dry well. Mr. McCabe reported that HLA would take a look at two septic systems’ leach fields. He said the first was located at the Loading building, which was connected to a sink and also to a floor drain in the boiler room. He explained that because there was a small potential for employees handling explosives to wash their hands in that sink, HLA thought it prudent to collect a sample of the solids at the base of the septic tank. Mr. McCabe added that there was another septic tank at the Assembly building, which had been hooked up to receive discharge from another photo-processing unit at that building. He stated that HLA would sample that septic system as well.

Mr. McCabe said the process water areas would be evaluated. He explained that process water was the water generated in the Loading building as part of the milling, cutting and cleaning of test ordnance in that building. He explained that up until 1990 that material was stored in a concrete storage tank which had been removed in 1990. He added that Textron did not find any records or observations that post-excavation sampling was done, therefore soil borings below where the tank was located would be performed. He noted that there were no indications that the tank leaked. Mr. McCabe stated that the discharge areas refer to two discharge events of process water to ground surface from that tank. He reported that the two events happened in the mid-1980s and it was estimated to be about 1,200 gallons, which is approximately the capacity of the concrete tank. He went on to say that one event was known to have occurred about 100 feet south of the Loading building but the exact location was unknown. Mr. McCabe said HLA proposed to do a grid-based surface soil sampling program in that area and also perform soil boring at the location of the highest detect in surface soil. He added that, in conjunction, HLA proposes up to four groundwater monitoring wells, two on the downgradient side of the release, one at the center of the release point, and one upgradient of the release point. He noted that groundwater samples from those wells would be analyzed for explosives. Mr. McCabe said that during this event the process water had been pumped out of the tank. He reported that a second event occurred in the mid 1980s where the process water was put into drums, brought over to the J-1 Range and emptied in the depression from the 1,000-meter range berm. He said HLA’s investigation approach for this event would be the same as described on the J-1 Range, a grid-based surface soil sampling program, subsurface borings and four groundwater monitoring wells - two downgradient, one at the center point, and one upgradient.

Mr. McCabe next covered the empty drum area and explained that after approximately 25 drums were emptied on the J-1 Range, the drums were brought back to the J-3 Range, crushed and covered with soil. He said that as far as HLA could determine the drums were still covered and he noted their approximate location on the map. Mr. McCabe stated that in coordination with their UXO contractor, HLA would be using geophysics to try to locate the drums, excavating the drums, disposing of the drums, and sampling soils from below the drums.

Mr. McCabe next reported on the flammable materials storage area. He noted that this had been a small metal shed used to store small quantities of flammable materials such as gasoline and diesel fuel. He said that the shed was no longer there and that there was no indication of surface soil staining below where it was, but HLA would collect a couple of grab surface soil samples there and analyze them for fuel residuals. He stated that the reason for this action was that some of the interviews indicated that the shed had a rusted bottom.

Mr. McCabe stated that HLA anticipated being in the field early in the summer, and was currently coordinating to have the UXO sweep done for the range. He reported that the investigation would be completed by the end of the summer and the data would be in and that HLA hoped to issue a report in the fall. Mr. McCabe stated that this concluded his presentation and noted that he had placed extra copies of the handouts on the back table.

Dr. Feigenbaum said he was interested in the report of past activities. He said as he understands it, there were explosive materials from the Wilmington, MA operation brought to the J-3 Range. He stated it was hard for him to get what the time frame of that was and asked if anyone knew. Mr. Plzak replied that was during the early to mid-1980s. Dr. Feigenbaum quoted from the report, "...the materials included propellant" and commented that the NGB stopped burning excess propellant around the very early 1990s because it was thought to be dangerous - he then continued his quote "...detonators, rocket motors, smokeless power, 20 mm powder…" Dr. Feigenbaum noted that the report stated that a truck carried these materials, and asked what type of truck was used. Mr. Plzak replied that he believed it was a pickup truck with a cap run by the Textron Safety Department. Dr. Feigenbaum continued to quote from the report "...contracts ordered them to the J-3 approximately twice a year, magnesium chaff was burned..." Dr. Feigenbaum asked what Textron had to do to get permission to bring the materials from Wilmington, MA to dispose of it at the Base and asked why Textron did not dispose of it in Wilmington, MA. Mr. Plzak replied that he did not know what was done in terms of getting permission. He added that the J-3 Range was Textron’s explosives site and Textron would generally function explosive materials at that site. Mr. Plzak stated that he was not personally involved and did not know the details but knows that the material has to be transported in an approved vehicle and the persons transporting it have to have the appropriate licenses. He explained that for any operation Textron conducted which involved functioning propellants or explosives out on the range, Textron would need to get clearance from Range Control before proceeding to fire anything.

Dr. Feigenbaum asked who gave Textron permission to bring hazardous toxic material, that when burned has toxic consequences, to the Base. Ms. Wilson replied that Textron had a license with the U.S. Army Corp of Engineers (US ACE) to use the J-3 Range and that everything Textron did was in accordance with that license. Dr. Feigenbaum asked if the license provided for unlimited disposal. Ms. Wilson replied that the license provided for Textron to use the Range. Dr Feigenbaum asked if that meant in any way Textron pleased. Ms. Wilson replied within certain parameters, and stated that the license did not specifically, as she recalled, say Textron could only detonate certain rounds - it did not go into any specifics about what Textron specifically could burn or not burn, or fire or not fire, discharge or not discharge. Dr. Feigenbaum asked if Textron had been given a "free hand" by US ACE to do anything they pleased. Ms. Wilson said Dr. Feigenbaum could characterize it like that if he wanted. Dr. Feigenbaum asked if the US ACE was the only appropriate licensing agency and if MA DEP, for example, knew this was going on. Ms. Wilson said that Textron had an arrangement with the US ACE because that is who the NGB sent Textron to when they asked to use the Range. She added that Dr. Feigenbaum would have to speak to another governing agency and that this would not be something she could comment on.

Mr. Gonser commented that the US ACE was the real estate agent for the Department of Defense (DoD) and would function as a realtor. He said that US ACE does not determine what lands are used for or even what the rules are, but would act as an agent to draw up the necessary documents and put them in there. Mr. Gonser said he was sure that, in general, any of the leases require the occupants to comply with all federal, state and local laws. Dr. Feigenbaum replied that he was sure that the local laws did not permit the burning of toxic materials within hundreds of feet of residential neighborhoods. He asked Ms. Wilson if it did not occur to her that there is something wrong about this picture and stated that it is obviously in violation of local laws. Ms. Wilson said she would not comment on that at this time. Dr. Feigenbaum replied that Ms. Wilson did not have to but somebody else might want to. Ms. Wilson replied that no one else will either. Dr. Feigenbaum commented okay, that he saw Ms. Wilson was a little nervous about it and he could see why.

Dr. Feigenbaum asked if the IART could obtain copies of the licensing agreement. Ms. Wilson said she did not know if Textron could make those public, but she would check and see. Dr Feigenbaum asked why the agreement could not be made public, as it was between Textron and an agency of the United States. Ms. Wilson said that she would have to check with the agency of the United States. Dr. Feigenbaum asked if EPA could make the request. Ms. Dolan asked if Dr. Feigenbaum was referencing the licensing agreement with the US ACE. Dr. Feigenbaum replied yes. Ms. Dolan stated that this was available and that she believed Mr. Cody had provided copies to the IART members last fall. Dr. Feigenbaum asked if the team had all received copies. Ms. Dolan replied yes and that she was not sure what other agreements were in place, as this was the only one she was aware of.

Dr. Feigenbaum asked if it were true Textron leased the ranges for $1.00 per year. Ms. Wilson replied that was not correct, she believed it was $500.00 a quarter. Dr. Feigenbaum stated that it was then $1,000.00 a year. Ms. Wilson reiterated that the fee was $500.00 a quarter. Dr. Feigenbaum commented that it was then $2,000.00 a year for Textron to be able to do anything they pleased in our neighborhood.

Dr. Feigenbaum referred to page 4-36 of the report and noted that Ms. Wilson had interviewed an Atlantic Research employee He asked if Textron had had a subcontracting relationship with Atlantic Research. Ms. Wilson replied that some of Textron’s employees also worked for Atlantic Research. Dr. Feigenbaum then quoted from the report "...excess explosives from the button bomblet anti-personnel mine were burned at J-1..." He said that this did not make sense to him, that there was only one mine and asked what was being discussed, as a mine is a single unit and if Ms. Wilson had meant excess mines. Ms. Wilson commented that it sounds like Atlantic Research performed that, not AVCO or Textron, so she could not comment. Dr. Feigenbaum commented that the event occurred on J-1 which was Textron’s facility. Ms. Wilson replied that Atlantic Research did it on J-1 which was not Textron’s facility and stated that if Dr. Feigenbaum continued to read the sentence she believed it said "... while Atlantic Research was operating the J-1 Range..." Ms. Wilson stated that Textron never had a license on J-1. Dr. Feigenbaum asked if there were a second corporation operating out there. Ms. Wilson said that that was her understanding that there were more than one or two. Dr. Feigenbaum asked why Textron was reporting on this then. Ms. Wilson replied that the reason was for completeness and accuracy. Dr. Feigenbaum asked someone to please explain this to him. Ms. Dolan replied that AVCO, a predecessor to Textron, operated at the J-1 Range from 1979-80 to 1986 and that other contractors operated on the J-1 Range from as early as 1957, including Atlantic Research. Dr. Feigenbaum said that he thinks it is very unclear what these years were. He stated that it appears from page 4-35 that this occurred until 1986. Dr. Feigenbaum asked if AVCO would have permitted Atlantic Research to operate on the Range. Ms. Wilson stated that it was not up to Textron to allow or not allow anyone else to use the J-1 Range, as Textron operated on that particular range as a subcontractor to the U. S. Army. She added that Textron did not have exclusive control of that range. Dr. Feigenbaum said he wanted to ask about Atlantic Research. Ms. Wilson said she did not know anything about Atlantic Research. Dr. Feigenbaum said he just wanted to ask about how it related to this report. Ms. Wilson agreed to that. Ms. Dolan commented that she thinks that during HLA’s interviewing of AVCO and Textron personnel, one of those people had also worked for Atlantic Research in the past and provided that information. Ms. Wilson said that Textron then provided the information for completeness.

Dr. Feigenbaum said that it was still unclear to him. He stated the report says "... the button bomblets were manufactured by National Fireworks in Hanover, MA, .... excess explosives consisting of a slurry of lead azide, RDX, ground glass were packaged in freon and placed in 55-gallon drums ....and transported to J-1." He asked if it were correct that the button bomblets were transported to the Base from Hanover, MA. Ms. Wilson said that was Textron’s understanding from what this employee told them, and that this employee did work for those organizations. Dr. Feigenbaum said that Textron spread these materials. Ms. Wilson said Textron did not spread the materials. Dr. Feigenbaum stated that somebody spread this material, including lead azide, on an area of approximately 1,000 square yards and then set it on fire. He asked if that was correct and if the reason was to get maximum volatilization. Ms. Wilson said this is what Textron was told and that Dr. Feigenbaum would have to ask Atlantic Research. Ms. Wilson asked if Atlantic Research were present this evening. Dr. Feigenbaum said he did not know and also asked if Atlantic Research were present.

Dr. Feigenbaum said that he would suggest that what Textron did was bad enough in bringing it from Wilmington, MA, and that it looks like there was a free-for-all going on at the base, anyone could bring anything they wanted. He commented that it was not clear when the IART would get to the bottom of it all. Dr. Feigenbaum stated that he thinks this voluntary process of Textron providing whatever information they felt like was ineffective and he thinks the IART needs to figure out how to get some legal teeth into this.

Ms. Wilson asked Ms. Dolan to explain about the 104E. Ms. Dolan replied that the NGB has sent out several information requests. She said she would not speak for NGB, but that NGB has sent information requests to the successor of Hesse-Eastern, MIT, AVCO and Textron, with Textron assuming the liabilities of AVCO. She said that she thinks NGB is still on the lookout for where Atlantic Research ended up, which is still a gap in the information. LTC Knott reported that Atlantic Research had been found. Mr. Grant stated that Atlantic Research still appears to exist under that name and is located in the Washington, D.C. beltway area.

Dr. Feigenbaum commented that the IART is led to believe that the ultimate responsible party here is US ACE. He asked if US ACE had told Textron they had a blank slate and could do anything they pleased. Ms. Wilson commented that Dr. Feigenbaum had a copy of the license and if he would like to go back and review the license then Textron would be glad to answer specific questions.

Dr. Feigenbaum said that he would like to know why Textron did not do this in Wilmington, MA. He asked what was special about the people of Cape Cod that Textron was inflicting this kind of burden on them. He asked again why Textron did not do this in Wilmington MA and said Ms. Wilson could forget the second part of his question. Ms. Wilson replied that she would assume that Textron did not have the facilities in Wilmington, MA. Dr. Feigenbaum asked if there were people living too close to Textron’s operations or what. Ms. Wilson said she would not debate with him. Dr. Feigenbaum commented that Textron was practically doing this in people’s back yards and that he was not interested in debating it either.

Mr. Prince stated that he had some questions regarding the groundwater sampling. He stated that apparently the only places the groundwater would be tested would be below the Loading building, AOC 1 and AOC 10, and in the suspected process water disposal area. He noted that the screens would be only 10 feet below the groundwater table which he did not believe was deep enough. Mr. Prince said he was also concerned that groundwater would not be tested in other areas, such as the former flammable storage shed and burn kettle, the warhead firing range, the demolition area and others. Mr. Prince commented that he did not believe the groundwater testing protocol was appropriate and that Textron had a lot of work to do in that area. Mr. McCabe replied that the groundwater program was designed to address the areas thought to have potential to have impacted groundwater and that the screens were appropriate for wells that are focused on locating a source.

Mr. Prince stated that the groundwater goes down pretty quickly here, and that Mr. McCabe was talking about, for instance in the demolition area, a release of explosives, petroleum products and metals. He added that in the warhead firing area it would be RDX, HMX and TNT. Mr. McCabe replied that as he had mentioned, this is an iterative process, and that there is only the potential for releases to have occurred in those areas. He stated that HLA would evaluate the surface soil data and if there are detections in the surface soil that have not been characterized, they will then look at the vertical distribution in subsurface soils. He added that if there is indication of vertical migration, HLA would perceive that as a data gap for groundwater, and in successive mobilizations they would look at the groundwater in that area. Mr. Prince replied that he stands by his comments as he does not think HLA would necessarily find anything on the surface, they would have to go deep. He stated that he thinks this is critical as there are a lot of problems downgradient of Textron’s area and suggested HLA look at it again.

Mr. Hugus stated that he shares Dr. Feigenbaum’s indignation about the fact that so many harmful things were done so close to residential areas that should not have occurred at all. He added that apparently it did not stop until the cease-fire order in 1997 and that he was glad it did. Mr. Hugus commented that it was now time to reckon with what happened. He added that there are things in the list put together by HLA that just do not seem very credible. Mr. Hugus referred the IART to Section 4 which Dr. Feigenbaum had cited, page 4-36, where the report said the 55-gallon drums of lead azide, ground glass and RDX were burned in 1,000-yard-long lines, diesel fuel was then poured over the same area and ignited. He reported that on the next page, in the section on generated wastes, under air emissions, HLA says they felt there were no significant emissions at J-1. Mr. Hugus asked how HLA could say that there would be no significant emissions from an activity like that. Mr. McCabe said he thought that waste emissions referred to Textron activities. Mr. Hugus asked if Mr. McCabe was saying that Textron did not do this. He noted that this was not specified in the report, it just says no significant emissions. Mr. McCabe said that he understood.

Mr. Hugus commented that there are other areas in the report on Textron’s activities where the results are "no significant emissions." Mr. McCabe asked for a specific example. Mr. Hugus asked if Textron fired 8-inch artillery rounds. Mr. McCabe replied if that was at the artillery range, then yes. Mr. Hugus replied that in that section HLA says there are no significant air emissions, but the IART knows that there are significant air emissions from firing an 8-inch artillery round. Mr. Hugus explained that an 8-inch round is huge, and that the IART has seen pictures at previous meetings where the firing puts out huge clouds of smoke. He stated that HLA was saying things without having any grounds for saying them, which unfortunately, was typical because there has never been any testing for air emissions. Mr. Hugus commented that for HLA to say that air emissions are insignificant is beyond their own knowledge as they never had testing facilities to know one way or the other. He added that he does not think it is responsible for HLA to say air emissions were not a problem, which is what he has seen in a cursory review of the document. Mr. Hugus commented that it is the common story of the contractor covering for the proponent, thereby calling HLA’s credibility into question.

Mr. Hugus stated that a huge number of armaments were tested at the J-Range, the PATRIOT missile, Minuteman 1, tank guns, and he also read 688 warheads were tested. Mr. McCabe said that, as he understands it, the warheads were inert. Mr. Plzak explained that the EFP warheads were detonated on the J-3 Range to drive a projectile into a target on-site and that the number of tests Mr. Hugus was talking about does not refer to inert units. Mr. Hugus asked if the EFPs contained propellant. Mr. Plzak replied no, they were high explosive (HE) charges that were detonated on the Range. He went on to say that they contained HE, which is slightly different from propellant, and were detonated in place, not launched; however they did contain energetic materials that were detonated.

Mr. Hugus said that he would like to concentrate on the Depleted Uranium (DU). He stated that when Textron previously came to the IART, it was reported that four DU charges were located at the base, and now 11 are being reported. Mr. Plzak answered that he went through a search of the records available in Textron and got the shipping documents, test reports and loading reports. He stated that he discovered a total number of 11 documented occurrences when he searched the records. He said someone may have guessed that there were four, but he found 11. Mr. Hugus asked if Textron had a relationship with Nuclear Metals. Mr. Plzak asked what Mr. Hugus meant by a relationship. Mr. Hugus asked if there were any connection between Textron and Nuclear Metals of Concord. Mr. Plzak replied no, Nuclear Metals of Concord may have fabricated the DU liners, but they are not owned by or a partner of Textron or AVCO as far as he knows.

Mr. Hugus asked if Textron was claiming that DU was only loaded at the base and not fired. Mr. Plzak replied that he is stating that Textron did not fire any DU projectiles. Mr. Hugus asked if Mr. Plzak was on base during the entire time. Mr. Plzak replied that he was working for AVCO at the time those projectiles were loaded. He said he was not directly involved in the loading or shipping of the DU projectiles, but was basing his statement on a search of Textron’s records of those tests. Mr. Hugus asked if Mr. Plzak was working at Camp Edwards at that time. Mr. Plzak said yes.

Mr. Hugus stated that Section 4 of the document says that one of the reasons why it is clear that DU was not used here was that there was a radiological survey of buildings on the J Range. Mr. Hugus said that he thinks that if DU had been fired here, the place to find it would be at the metal targets. He commented that there was no testing of the metal targets because they had been taken away, at least that is what he has heard. Mr. Hugus stated that, for the record, he does not believe the radiological survey proves anything one way or the other about DU. Mr. Hugus commented that he does not believe the document is credible and that he continues to think DU might have been fired at the base and the IART is not being told about it.

Mr. Hugus asked if perchlorate had ever been used for rocket fuel. Mr. Plzak said he could not answer as he was not sure what the components were. He added that Textron did fire some solid propellant rocket motors but he did not know the chemical makeup off the top of his head and would not feel comfortable answering without referring to the records. Mr. Hugus commented that, for the IART investigation, it would be important to have the answer and that he knows of other bases where perchlorate was used for solid rocket propellant. He added that perchlorate has caused serious problems in groundwater and asked if it would turn up on the IAGS analyte tests. Mr. Grant replied that perchlorate was added to the analyte list as of February, 2000 and that there are a series of 20 or 30 wells slated for sampling, of which a few have already been sampled, with the rest scheduled for sampling in August 2000.

Mr. Schlesinger stated he would be submitting most of his comments in a note to EPA. He noted that Mr. Plzak mentioned consulting documents and that page 2-3 of the report stated "...a review of TSC documents were used for indicating that TSC was not responsible for burying munitions on J-1 Range..." Mr. Schlesinger commented that none of those documents were listed in the references in the back of the Report so the team did not really know what Mr. Plzak reviewed or what was used to base that knowledge on - it is just a statement to us. Ms Adams replied that the EPA has asked for these materials in their subsequent information request.

Mr. Schlesinger commented that his second point was relative to what Dr. Feigenbaum had said about Atlantic Research. He said that this was new information to the team and asked if it was new information that Atlantic Research was out there. Mr. Borci replied no. Mr. Schlesinger asked if every company licensed to work out there by US ACE was known. Ms. Adams said she did not believe every company was known. She added that EPA recently received a response from NGB by Masco Corporation, successor to Hesse-Eastern, which identified two new potential users, Arthur D. Little and Northern Flare. She noted that this was the first she had heard of those companies and she was not convinced that the IART possessed a comprehensive list. Mr. Schlesinger asked if 104Es would be submitted to those additional companies. Ms. Adams said EPA will encourage NGB to do that. LTC Knott stated that the answer was yes.

Mr. Cambareri said he would like to echo Mr. Prince’s concern about the well locations and the number of wells. He commented that the Phase 2 plan talks about the well locations, and they are focused on two areas of concern having to do with the discharge of process water. He said he understands that most hazardous waste investigations are concerned about the discharge of water as a vehicle for bringing contaminants into the subsurface. He explained that at Camp Edwards, the explosives and the actions of the explosive detonations are cause for contamination, and in many cases there is RDX in groundwater beneath areas where the soil was non-detect for RDX. Mr. Cambareri said he thinks the groundwater portion of the Phase 2 Investigation needs to be widely expanded. Mr. Cambareri said he was also concerned to see how Textron’s direct-push vibratory boring techniques would be successful at the Base, going through 110 feet to the water table. He said he was not sure this was the right technique to use if HLA needed to go further. Mr. McCabe replied that, as he understands it, those depths have been attained by using direct push vibratory drilling out at the Base.

Dr. Feigenbaum commented that on page 4-36, the Report mentions a 1999 co-interview - he guessed the "co" was US ACE, which took him a little while to figure out - which says "...an existing AVCO employee indicated that excess propellant for the 105 mm heat round was burned in the middle of the road that runs through J-1." Dr. Feigenbaum commented that the Report was in 1999 but that it did not say when the interview was or when the event occurred and asked if anyone knew when they happened. Ms. Adams replied that she believes the information is in the Archive Search Report and she would check.

Dr. Feigenbaum asked if the IART could be provided with the 1999 US ACE Report which seemed to him to be a valuable source document. Ms. Adams stated that again, she assumes the reference is to the Archive Search Report which she believes he has. Dr. Feigenbaum questioned whether or not the IART had that document. Ms. Adams replied that the team had the summary but did not know if they had all the appendices that went with it. LTC Knott said that he thinks Dr. Feigenbaum has it, but it would not be a problem to send him another copy. Dr. Feigenbaum commented that he has so much stuff he does not know what to look at and what not to look at.

Mr. Hugus commented that US ACE was the overall licensing agency for all of these activities and were also the people conducting the Archive Search Report, which is a huge conflict of interest.

Mr. Hugus noted that he had forgotten to mention that one of the reasons he believes DU was fired at the Base is that AVCO and Textron were doing testing of armor-piercing munitions. He referred to page 4-18 of the Report which stated "...the gas gun was used to fire projectiles used to pierce through armor plating and that a physical and thermal reaction made this possible..." Mr. Hugus commented that he knows that there are other forms of munitions used for piercing armor and said he was not sure what this section referred to. He asked if tungsten-carbide rounds or other types of rounds had been fired. Mr. Plzak replied that Textron’s armor-perforating projectiles are made of copper and some of tantalum. Mr. Zanis added what about SABOT rounds. Mr. Plzak answered that Mr. Hugus was asking about the warhead range, and that Textron did not have SABOT rounds on the warhead range. He added that the copper and tantalum units fired were HE warheads, an EFP, the materials were copper in some cases and tantalum in other cases. He stated that no DU was used.

Mr. Hugus commented that another reason he was concerned was because armor-piercing munitions were experimented with and noted that DU is the armor-piercing munition of choice. Mr. Plzak replied that it perhaps was Mr. Hugus’ choice, but it was not what Textron was firing. Mr. Hugus said it was not his choice, and has been used frequently in recent wars in Iraq and Yugoslavia. Mr. Plzak said he could not speak to what was used in Yugoslavia, he was speaking about what Textron did on the J-3 Range.

Mr. Hugus asked Mr. Plzak to explain what SABOT rounds are and what they are used for. Mr. Plzak replied that a SABOT is a piece of material, basically a sub-caliber penetrating projectile. He added that a projectile is encased in a SABOT which falls away after a cannon is fired. He said that it allows you to fire a smaller-caliber projectile out of a larger-caliber gun barrel. Mr. Hugus explained that it enabled one to use a huge amount of propellant to fire a small round in order to get a terrific velocity in the projectile. Mr. Plzak said that Mr. Hugus was correct. Mr. Hugus asked if there were any chance of a ricochet with that type of round. Mr. Plzak said yes. Mr. Hugus asked if Mr. Plzak felt it was responsible to fire such a thing in an area like this. Ms. Wilson replied that Textron had permission to fire rounds per the licensing agreement. Mr. Hugus said that as a resident of the area, he cannot let this pass without saying that the citizens feel that what Textron did here was not appropriate for the area. Ms. Wilson said she understood. Mr. Hugus said that Mr. McCabe spoke of doing groundwater and soil sampling, which is fine but there is a question of ethics regarding Textron’s completely inappropriate activities. Mr. Hugus stated that the fact that Textron was licensed to do it by US ACE does not provide any satisfaction, especially considering that there are serious disease elevations on the Upper Cape.

Mr. Schlesinger made an action item request. He requested the IART improve their knowledge of companies working on the J Ranges by getting a more complete list from US ACE and copies of all the US ACE contracts. He said he understands from Ms. Adams that the contracts were not all received when requested after the Archive Search Report was done. He commented that the IART should not have to wait for a submission this late into the game to find out who was out there.

Mr. Dow stated he wanted to follow up on something Mr. Prince mentioned. He said that there are many cases on the Base where heavy metals occur in the soil and are found in groundwater. Mr. Dow commented that he has been told these materials are not very mobile, nevertheless they are found in the groundwater, including lead, which is the probably the classic case for something that is not supposed to be mobile. Mr. Dow said it seemed to him that a groundwater sampling phase was needed because just determining where the contaminants are in the soil will not determine what is in the groundwater. Mr. McCabe replied that to clarify, HLA would be installing and sampling eight wells, and will evaluate the need for more as they see what they find.

Mr. Judge noted that Textron had a contract with US ACE, and stated that it was easy to point the finger at US ACE. He asked if there were anything written in the contracts about safety protocol and about using sound judgement. Mr. Judge said that generally these are written into contracts to make sure you do not fire a round going a billion miles an hour with the potential of ricochet in a residential area; what they want you to do is fire a round that is protective and do it in an intelligent manner knowing the situation you are in. He added that he thinks US ACE will probably take issue with the way Textron operated on the Ranges, especially when they look at the contracts and say "what you did was not follow the letter of the contracts in the safety and protection of the actions you took." Mr. Judge said he would suggest looking more specifically into those contracts to see if those caveats are in there.

Mrs. Crocker asked when EPA would expand the IART. She said it seemed to her that a broader representation from the community was needed in order for the IART to gain credibility as to representing the breadth of community. She asked if there were any plans for that. Mr. Walsh-Rogalski replied that under AO #3, it is the responsibility of the NGB to develop a public involvement plan. He reported that several versions have been gone through, and that EPA had received another version yesterday but had not reviewed it. He added that expansion was clearly one of the goals and hoped they would be successful doing that. Mrs. Crocker asked if this was not a EPA group that they were listening to tonight. Mr. Walsh-Rogalski said he was not sure what Mrs. Crocker meant. Mrs. Crocker asked if this was not the IART of the EPA. Mr. Walsh-Rogalski replied that this was the IART that was established under AO #1 that has continued to function under AO #3, although what we are discussing here are matters related to AO #1. Mrs. Crocker said she realized that, but she would request that EPA make more of an effort to get a broader representation of community assessment.

Mrs. Crocker commented that her understanding from her Barnstable Rod & Gun Club friends is that firing was re-established because there was no lead proven to be in the groundwater. She asked is there or is there not scientific illustration of lead in groundwater. Mr. Borci replied that there has been one comprehensive study done to-date at this Base, which is the Lead Berm Project. He added that lead was found in the soil that migrated below the berm and that he thought the deepest sample was 10 feet. Mr. Borci said he does not believe that any elevated levels of lead attributed to those berms, or any of the lead that was removed, was found in downgradient groundwater wells; however the expected migration rate has not been evaluated in a lot of detail. Mr. Borci offered to check. Ms. Crocker asked that EPA do so, because of a comment made earlier in the evening about lead in groundwater. Ms. Crocker commented that insinuations need to be scientifically backed up in order to be accepted as fact.

Mr. Hugus commented the lead azide that Atlantic Research burned would be an air problem, not a groundwater problem. Ms. Crocker said that is what she thought, but she would like to have that clarified by EPA so that we are all talking truth and science and not insinuations.

Mrs. Crocker said she remembers when the towns of Sandwich and so forth got land, and that in her remembrance of the newspaper article the land was supposed to be a buffer zone for open space around the Base. She asked why Sandwich built on that land. She noted that people are complaining about how difficult it is to be a resident near the Base. She said it was her understanding that there was not supposed to be residential development, it was supposed to be a buffer zone. She asked if anyone knew about that. Mr. Borci said these were questions EPA was not prepared to address this evening. Mrs. Crocker asked EPA to look into that as it was very critical in terms of community expectations, and historical clarification is needed. Mr. Borci said that EPA could look into that. Dr. Feigenbaum added that there was no Town of Sandwich property that was a buffer zone with the Base. He stated there was land that was privately owned and whether it was correct or not for them to develop for housing is not a question for the IART to answer because under this particular system the property owners had a right to dispose of that property any way they wanted.

Mr. Dow said that he was told that the reason the lead was in the groundwater is that it came from fuel and not lead bullets. He added it does not mean that, if you do a study of lead or thallium or any other heavy metal in the soil, the form it is in when it enters the soil will determine when it gets into the groundwater or not. Mr. Dow said he thinks the previous speaker gave an unscientific analysis of the problem.

Ms. Frawley asked if there were any more questions for Textron.

Mr. Judge commented that when he started going over the report and realized that DU was depleted uranium he just about came out of his socks. He said that tonight he is hearing "sorry, it was not 4, it was 11". He asked if Textron could misplace any rockets while they were going along and stated that Textron has already proven that they are unable to count straight. Mr. Judge said that Textron had better get their numbers right and they had better come back and be quite sure because these people are where the rubber meets the road and they are going to find out. Mr. Judge asked is it 4, is it 11, is it more, or is it less - we are talking about DU on Cape Cod and Textron needs to make sure they are correct.

Mr. Grant stated that he would give a brief explanation of the J-1/J-3 Range Draft Work Plan, which he said had been provided to the agencies and stakeholders on April 21, 2000. He noted that the plan is up for review so he does not believe the agencies have commented on it yet, but that comments could be passed on during the meeting. Mr. Grant referred the team to the map Figure 2.11. Mr. Grant explained that Ogden’s workplan covered three different ranges, J-3 Range, the L-Range and the J-1 Range north of the L-Range. He added that all three ranges are in areas of detected groundwater contamination, and all three present potential source areas that Ogden is interested in identifying, which is why they were all combined into a single work plan.

Mr. Grant noted that Figure 2.11, similar to HLA’s map, showed several different portions of the J-3 range. He noted that the word slide talked about the potential release areas. He explained that Ogden had organized their work plan according to the type of release area and that Ogden had identified five different areas where firing points were located, three different areas where targets were located, two areas that could have been used for disposal, and four areas for wastewater discharges. Mr. Grant said that the areas Ogden had identified were essentially the same as those HLA had reviewed and that the ones Ogden feels would be of most interest would be the two disposal areas - the burn kettle and demolition area and the wastewater disposal area. Mr. Grant noted that as Mr. McCabe had mentioned, there are three different septic systems, one by the Melt-pour building, one by the Workshop, and one by the Environmental building. Mr. Grant stated that of most interest was a single-event wastewater discharge of 1,200 gallons just south of the Melt-pour building.

Mr. Grant commented that to put things in context, Textron was preparing their Phase 2 Work Plan at the same time Ogden was preparing its Work Plan for the same area. He said that neither had the benefit of looking at each other’s plans, although Ogden had at least the benefit of looking at the 104E response when preparing theirs. He stated that there were now two different work plans trying to address the same area and there was quite a bit of overlap.

Mr. Grant reported that soil sampling was proposed at 14 potential release areas for a total of 177 samples at somewhat the same locations that Textron proposed in their work plan. He stated that Ogden’s groundwater sampling approach was different. Where Textron proposed sampling in source areas, Ogden did that in one case in the center of the J-3 Range where the demolition operations occurred, but in terms of other potential source areas, Ogden proposed putting monitoring wells downgradient along Greenway Road. Mr. Grant stated that there were existing wells in this area by virtue of it being an FS-12 release area, but there are additional wells proposed in Ogden’s work plan to supplement those wells and try to get a handle on the groundwater downgradient of J-3.

Mr. Grant referred to Figure 3.10 and stated that the top of the mound was close to the gauntlet area of J-3. He commented that one problem is Ogden does not have many wells at the top of the mound which is what Ogden has proposed to define in this investigation. He said that the thought is that the groundwater flow from the back end of J-3 could go the west toward the Impact Area or it could be going to the east. He said that groundwater flow in the area near the Melt-pour building and the demolition area is probably to the east or southeast.

Mr. Grant noted the locations of the particle tracks on Figure 3.10 and stated that at the particle track from 90MW0022 there had been a RDX detection at depth. He noted the direction of the track and where it reached the top of the water table was close to the demolition area in the center of the J-3 Range. Mr. Grant reported that there had been a HMX detection at MW-30 which did not go back far but did go forward into the FS-12 extraction system. He said there had been a HMX detection at 90WT0004 which pointed to the same area around the Melt-pour building. He reported that the last particle track was for detections at WT-13, which was in FS-12 and was pointing back toward the L-Range.

Mr. Grant said that Ogden was proposing soil sampling, that their method was different from Textron’s but the locations were much the same. He reported that Ogden’s groundwater sampling proposal involved a slightly different set of wells and that a geophysics survey would be done in the next couple of months to look for possible buried UXO.

Mr. Cambareri asked if Ogden would be putting in push wells or regular wells. Mr. Grant replied that Ogden proposed regular wells. He said there were discussions with the agencies last week, and that he thinks the push wells make a lot of sense especially in the area of the Melt-pour building because the depth of the water table is only about 40 feet. He noted that it may be more difficult up on the J-1 Range as it is typically 100 feet to the water table. Mr. Grant stated that push wells may also help with defining the top of the mound because the drive points could be done quickly to try to get the center of the mound.

Mr. Schlesinger asked if some of these activities that are so horrendous were going on 15 years ago, could this material have moved quite a distance. Mr. Grant replied yes. Mr. Schlesinger asked if the contamination should all be going into the FS-12 fence and if it were too early to speculate that it might be past that point and under Snake Pond. Mr. Grant said that was the subject of a Response Plan Ogden had recently implemented and one of the topics for tomorrow’s technical meeting with the Agencies. Mr. Grant reported that Ogden sampled another six IRP wells in the in FS-12 area the last part of the RRA and did not get RDX detections. Mr. Grant stated that at this point, based on discussions held with the IRP, Jacobs and AFCEE on how their model works and what Ogden has modeled in the area, it looks to Ogden like the contamination would go into the FS-12 extraction system if the system is on. Mr. Grant said he understood that the IRP was slightly modifying the extraction system to eliminate some injection and increase pull in the system, in which case the contamination would more likely go into the extraction system. He reiterated this topic, whether there is enough coverage in the area was currently under discussion with the agencies.

Ms. Frawley noted it was now 9:00 PM and asked if the team wanted to continue. The team said they did.

Agenda Item #4. Controlled Detonation Chamber Update (See Attachments #6, #7, and #8)

Mr. Deleppo reported that the US ACE is planning to invite the public to see the chamber and how it works on June 14, 2000 before it is put into use. He added that Mr. Donovan could give details on how the chamber works. Mr. Deleppo asked if there were any questions or concerns he could address at this time.

Mr. Gschwend commented that Mr. Deleppo had mentioned the use of bag houses, which are for particulates. He asked if the chamber had carbon traps or how it would catch vapors. Mr. Deleppo replied that he did not believe carbon filters were employed.

Mr. Donovan invited the IART to review documentation he brought on his chamber. He noted that regarding lead, he had documentation for work done last year at the Santa Susana Range for Boeing at Canoga Park, California, and a stack test of a model in Tennessee. He noted that chlorine gas was included in the documentation. He explained that each piece of PVC pipe gave off one pound of chlorine gas. When they downloaded the 483, they used to dupe the PVC pipe until we made them stop.

Mr. Donovan stated he is 58 years old and joined the Army in 1962. He had been a dairy science major at the University of Illinois in 1960 and was commissioned in 1963. He noted that he spent his first year at Fort Devens, MA. He added that he has been a Green Beret for 13-1/2 years, and also had been an engineering staff officer. Mr. Donovan stated that he has three companies: one of them is Donovan Demolition, the largest commercial user of plastic explosives in North America; another company called Donovan Commercial Industries is a manufacturer of explosives; and the third company is called DeMiller and Ashland. All companies are engaged in the demilitarization business for the government, and all stem from the chamber he had built 13 years ago.

Mr. Donovan asked the team to review the documents in order to get an idea of the statistics and asked that they be circulated as he had brought only one copy with him. Mr. Donovan said the CDC detonates at 2.8 million pounds per square inch (psi) inside the chamber at 5,600° Fahrenheit. He explained that the expansion tank, which is 512 cubic feet, is not really a cooling system and stated that the blast is controlled by adding a certain amount of water to it, based on the kilobars of pressure to British Thermal Units (BTUs) given off by a pound of explosives. When the device is shot, it is cool, and when it comes out the other end, it goes through the APCU, which is 1,350 square feet of filtering system which grabs everything down to a half micron. He went on to say the shrapnel state inside is armored plated, is totally self contained, is cooled by water, and has its own generator and air compressor.

Mr. Donovan commented that he has been asked questions about the air; i.e., when you open the door, what is going to come out, and he stated absolutely nothing. He referred to Mr. Deleppo’s illustration and said there are two holes that go around the front of the chamber, and as soon as it is fired there is a lever thrown, and the compressor is running and springing air out. He reported that there are three air changes a minute, so before the door is ever opened you have air that has run through the chamber that is perfectly clean. He explained that it is a pulsating bag house, which means that it alternates -- there are six filters inside this thing and they are pulsating so that all the particulates are knocked off the filter and drop down to the bottom. Mr. Donovan said LTC Fitzpatrick had been to see the CDC last month.

Mr. Donovan commented on the discussions he had heard tonight, and noted that he had feet on both sides of this camp. He stated that, having spent 20 years in the Army, he knows military bases fire rounds and they detonate, and, up until DeMil came along, the cleanest way to get rid of UXO was to either blow it up or burn it. He went on to say that anybody that tells you there is no toxicity from a detonation is a liar; and that he did not think anybody in this room is going to sit here and argue that point with him. Mr. Donovan said that one of the problems with open detonation on a range is when you detonate outside and you take more explosives, A5, RDX, whatever you want to use, and pour it on top of it, it adds more contamination to the soil. He said that in the commercial world they have permissible explosives, which are what you have in a mine if it does not kill the human beings working down there. He said military explosives are not permissible, and the toxicity from breathing those will cause you to have headaches, heart palpitations and, if you breathe enough of it, you will keel over and die. Mr. Donovan said that is the standard rule and is the truth. He commented that anybody that tells you any differently is a liar. Mr. Donovan stated that he has probably as much experience as anybody in this room in this particular field of endeavor, which is why he is here. Mr. Donovan summarized that that is how the CDC works, and that is why DeMil is here -- it will do a nice clean job for the IART. He then offered to answer any questions.

Mr. Hugus commented that he wanted Mr. Donovan to know that the IART wanted DeMil to come and take care of this problem. He said that Mr. Donovan’s son had given a presentation, and he was sorry to say the NGB did not believe him or something, but the IART felt DeMil had the technology to take care of this two years ago and he did not see the reason for the delay. Mr. Hugus said the reason we were told that the Donovan chamber could not be used here was because DeMil could not handle the air emissions. Mr. Hugus asked if that were true and if DeMil could have done this two years ago. Mr. Donovan replied yes. Mr. Hugus asked that the record reflect this.

Mr. Donovan reiterated that DeMil had a chamber model in Tennessee that had air pollution control systems on it, which is where the stack test comes from, and which was done long before we came to Massachusetts. He stated he would give the team a tape to review. Mr. Donovan said he would not get in the middle of any argument. He is just here to do business; he works for these people, and US ACE and the EPA have been extremely good to DeMil. Mr. Donovan said he has no axe to grind here and he was just glad to be coming up here next month.

Mr. Hugus responded by saying he was not asking Mr. Donovan to get in the middle, he just wanted to clarify it for himself, as he does not believe the IART was told the truth two years ago. Mr. Hugus said a lot of rounds that have been open-detonated in the Impact Area since then could have gone into a chamber. He said the group is angry about that, which is the reason he brought it up. Mr. Donovan says he understands and under those circumstances he would probably be angry, too. He commented that this has been most informative to him and that he has been impressed by what the public understands about this business, which is much more than most places he has been to.

Mr. Hugus noted that there were 105 mm and 155 mm rounds, and possibly even 8-inch rounds, that may need disposal. He asked if the chamber would be able to handle that or if there would be another one later on that will. Mr. Donovan said he could bring another mobile unit to the Base to do this. Mr. Grant asked if this has been through the approval process. Mr. Donovan said he wanted to explain about being approved. He stated that DeMil has a 130-lb. unit at the Blue Grass Army Depot where we are shooting four 105 mm at a time. He added that the IART will have those stack tests. Everything goes to DDSB. Mr. Donovan said the site survey for the mobile units is done and the stationary chambers have been done. He said he thinks this is more of a case of as you get larger in size it should pretty much be rubber-stamped, because all the people up there realize this thing is scalable. If you can do it with 130 lbs., you could do it with 3 lbs. It stands to reason that if you bring a 30-lb. unit in, if it will take a 155 mm you can do it. He noted that the T-10 is rated at 13 lbs. Mr. Donovan commented that he could not say he could bring one in six weeks. He said the IART members have all worked with the government enough to realize it is not easy, and stated that he has to go through the same channels as everyone else.

Mr. Hugus requested that NGB get this thing on line now so that we can have it ready here. He commented that it was too bad it was not ordered in the first place so we did not have to order a second chamber. He asked if there were plans to get a bigger unit to take care of the bigger rounds. LTC Knott said that there is a plan to get a bigger unit, not necessarily a Donovan unit, but a bigger unit, but unfortunately it has not been built yet. He said that this unit will handle bigger munitions than 81 mm here, and that NGB has committed to that. LTC Knott reiterated that he has to go through the same process as DeMil and, if DDSB says that DeMil has one that has been tested and which will take care of a 155 mm and has the DDSB stamp of approval, he did not see why he could not reach out to DeMil.

Mr. Stahl stated that he thought Mr. Gschwend’s comment was on the mark. He asked for clarification that DeMil had data that shows that you do not release unexploded residuals of TNT, RDX, or any of that kind of stuff out the back end of this chamber because it does not have carbon filters.

Mr. Donovan replied that a year ago he attended a Force Protection Show at Quantico. He said there were two companies there that do all the gas chromatography and spectrum graphs for the U.S. government. The two competitors ended up spending 2½ hours together and could not find any explosives in the chamber that had been shot 257 times. He explained that the UXO volatilizes, and that kind of heat kills everything and is being kept inside. Mr. Donovan commented that one problem is that you cannot get any air tests on open detonation. He explained that the explosion goes straight up in the air, and a screen placed over the top would be destroyed. He said a screen on the side would be wind-direction dependent. He added that the blast would first go up and then out in an umbrella effect, and one could actually lie down and get in under the umbrella and survive it. So, there isn’t anything left inside it.

Mr. Donovan said DeMil has a work order with the US ACE to start on chemical and biological agents, and performed tests on some 95% malathine, a surrogate for GB. He said what was left in the chamber was sent out to Southwest Research in Wisconsin, an agricultural lab that specializes in pesticides. He said the residue was .005 ppb. Mr. Stahl stated that this was within the chamber after detonation. Mr. Donovan agreed and added that DeMil took air samples from the back end of the chamber. Mr. Donovan said charcoal filters take care of chemicals and IART does not have any chemicals.

Mr. Stahl said he was concerned that if you blast it out the back end, it might not be totally burned and might end up as a residual on the ground at some distance from the chamber. Mr. Donovan disagreed and stated he has tests from Daley & Associates Lab out of Illinois who tested the DeMil chambers, which do not have bag houses because pentaerythitol tetranitrate (PETN) is completely burned up. He said Daley & Associates tested the soil sample and the gravel inside the chamber and found nothing. Mr. Stahl commented that PETN is different from RDX and TNT and it explodes differently. Mr. Donovan commented that PETN explodes differently but it is a mass burn, 5,600° volatilizes it all, and that the tests from Tennessee show there is no explosive period. Mr. Stahl said he would accept that. Mr. Deleppo said that US ACE tried to address Mr. Stahl’s concern in the work plan using information from another unit tested in Tennessee. Mr. Donovan said you have got to understand how this thing works, it is a limiting orifice, and the detonation is loud, just like it would be outside, but everything is trapped. He explained that there is 10½ square inches of air coming out which expands and becomes 110 square inches of air going into the expansion tank, so the burn lasts. He added that when you burn explosives outside, you burn them, only this burns a lot faster than heat generated from a fire with explosives. Mr. Donovan said C4 burns hot and that is RDX.

Mr. Stahl says he is concerned about the oxygen, and complete combustion requires a lot of oxygen input. Mr. Donovan replied that no, explosives are their own oxidizers, which is why you can blast underwater and they still blow up. He stated you do not need to force oxygen into a chamber to cause it to burn everything up. Mr. Stahl stated that it will not give a complete oxidation. Mr. Donovan replied that Mr. Stahl should consult Dr. Feigenbaum when he finishes reviewing the data and ask him if anything was left. He reiterated that DeMil is used in California because there is no explosive residue. Mr. Donovan commented that the reason Region 9 in California is demanding that blast chambers be used is because there is no explosive residue. He added that there is no groundwater or air pollution, and, additionally in California, no fire hazards. He said if the UXO were fixed-fused, something like a 40 mm which would be blown in place, no EOD technician in the world would blow it in place, and noted there have been people killed here within the last 12 months by a 40 mm round at Fort Drum.

Mr. Zanis stated he does not see a problem with the detonation chamber, but does see a problem with picking the rounds up and getting them to the chamber. He explained all the rounds listed on the handout were at the APC that NGB called a pile of scrap metal. He stated a method must be found to get rounds found on the ground to the chamber, and into it, safely. Mr. Donovan replied that the majority of rounds, once they are fired, can be picked up and moved, although there are some things, like the 40 mm, that you cannot handle that way.

Mr. Zanis commented that NGB has not picked up one round yet and saved it for the detonation chamber. Mr. Zanis reiterated that NGB has not picked up a live 155 mm or 81 mm mortar and moved it to the detonation chamber to hold it, they keep blowing them up. He added that if it is a training round, they save it. Mr. Donovan said that maybe when the chamber is here and they have some way to get rid of it they will pick the 81 mm up and stick it in the chamber. Mr. Zanis replied that DeMil’s first 200 rounds will be scrap metal.

Dr. Feigenbaum commented that he was sure the data would be interesting, but he thought when Mr. Donovan’s son was here, there had been a discussion on backing a carbon filtration device up into the rear end of this thing. Mr. Donovan replied no, that is something that can be put on and it has really been talked about for the chemical and biological munitions, not the standard munitions. He added that from the tests that have been done nobody thinks it is necessary. He stated that, when all the data is in from Blue Grass Army Depot, it will also be forwarded to the team. Mr. Donovan said the testing includes a whole multitude of rounds, and some really nasty things were shot in there, so the stack tests will give you a good idea of what is coming out the top of the chamber. Dr. Feigenbaum commented that Mr. Donovan has said the UXO volatilizes, and noted that is exactly the material that the IART would be worried about. Dr. Feigenbaum explained that we are kind of "lily livered" around here when it comes to putting stuff into the air because there is a lot of lung cancer in the area. As you have heard in the previous discussions about burning stuff, we just cannot take any load of volatilized nitrogenous compounds and stuff that is not totally oxidized. He added that he thinks it would be really nice to see a carbon filtration unit on the back of the chamber, which he said Mr. Donovan’s son had talked about. Mr. Donovan replied that it was primarily for the chemicals and not for the munitions. He added that you can always go to a better mousetrap. Mr. Donovan said he would say the chamber is about 99.9% cleaner than what is being done outside. He went on to say that a regular fire is not hot enough to volatilize, and that at 5,000 to 6,000° Fahrenheit you are talking about a tremendous difference in temperature then that of an outside fire. Mr. Donovan commented that he would like the team to look at the lead produced from 64 rounds in the California data, as they would find it interesting.

Dr. Feigenbaum stated that someone other than himself will ultimately make this decision but the IART has had a long history of insisting on carbon filtration as the end point for any incendiary device. He noted that this is a long history that DeMil is coming into and he does not mean to doubt Mr. Donovan’s credibility. Mr. Donovan replied that the only difference is in a furnace you do not get those kinds of degrees. He explained when a popping furnace is used at 1,236 , the incinerator process is about 800  Celsius, and a lot of times they have a hard time getting there. He reiterated that 5,000 to 6,000  Fahrenheit is a big difference.

Dr. Feigenbaum asked if the temperature is uniform throughout the whole combustion chamber. Mr. Donovan replied no, that this chamber is only 125 cubic feet. He said that when the round goes in it sits on a steel ring dead center in the middle of the chamber, with water around it. He added that the whole fireball goes out and there is equalization pressure in all places. Mr. Donovan said there are manifolds at the top and on the sidewall. He noted that this air rapidly expands and that the next step is it starts to quickly force itself out, it gets into the expansion tank and expands all the way up where it starts to really lose its power. Mr. Donovan reported that three things take place: one is heat, if you reduce the heat, you reduce the energy, and reducing the energy reduces the pressure; the explosives themselves will be gone; and carbonization will be seen on the walls of the chamber. When the job is done they take the cartridges out of the bag house, bag them up and take them to a landfill that can take this type of material. He noted that the piece from California shows actual filters that were taken out in Canoga Park. Dr. Feigenbaum asked what the cartridges were. Mr. Donovan replied that they were fiber, they are standard off-the-shelf cartridges supplied by Tort Donaldson Cartridges and designed for 250  Fahrenheit. Mr. Donovan stated it grabbed particulates down to a half micron, as shown in the test results he gave the team, when the T-10 was tested by the state of California without the filter. Dr. Feigenbaum wanted to know if the testing was strictly for particulates.

Mr. Donovan asked the members to take a look at the particulates it grabbed. Mr. Donovan referred the team to the stack test on the Tennessee chamber to see what got out. He asked them to remember when they see the chlorine, understand why it is there.

Mr. Borci stated that he pulled open a page in the reports, and there are three emissions tests on vapor emissions from the chamber and all runs of 2,4,6 DNT, HMX, and RDX were below the detection limit. Mr. Borci said the data is in here. He added that the EPA just got the Work Plan the other day, and he is sure EPA can probably put together a table to address those concerns directly, but the data EPA has shows that there will be no emissions of the explosives of the type EPA would expect to find out here. He stated EPA will evaluate that as part of the Work Plan.

Mr. Zanis asked Mr. Donovan whether or not the chamber is at atmospheric pressure or is the system pressurized or a vacuum drawn to the system. Mr. Donovan replied no and explained that DeMil wraps the round with explosives, shoots it and it critical masses it. He said they started doing that on the 483 because the bomblets would not go off and that compressed RDX gets a virus. If you totally compress this thing and kill it, you are actually collapsing the round. He added that the explosive is put on the outside that causes this damage, and that the round itself goes off in the chamber. Mr. Donovan said the temperatures in the chamber are not created by the explosives and the munitions, but are created by DeMil from the explosives that are surrounding them. Mr. Zanis asked what was used. Mr. Donovan replied it is a standard sheet explosive. For chemicals DeMil has designed a high-oxidizing explosive which is pumped over 6,000 . It just happens that we are the ones who are making it, and we are also selling it cheaper than you can buy it from the competitor. He explained that DeMil is able to take recycled materials from the military to use in the chamber, and that, at Blue Grass Army Depot, DeMil takes washed-out Comp B in a granular form and is using it in a cardboard tube on the 105 mm’s and 4-deuces.

Mr. Stahl asked if some kind of residual testing for explosives could be performed around the chamber after it is set up and had run for awhile to make sure no residual explosives were exiting. LTC Knott stated NGB had no objections to these tests. Mr. Borci commented that it is good to have questions now for the EPA to incorporate these suggestions when evaluating the Work Plan. Mr. Stahl concurred and noted that although the data there says there is not any, he knows that there are very tight tolerances on-site. He added that the chamber should be evaluated to see if there are any kind of residuals off the back and, if there are, the team can then evaluate whether carbon filtration should be added on the back of the unit.

Mr. Hugus asked Mr. Donovan where his responsibilities end, and if DeMil would be transporting munitions to the chamber. Mr. Donovan said DeMil will not, but his son and an EOD technician will be on-site to work with Sudacor. He reported that DeMil would spend two weeks training Sudacor’s EOD technicians who are all ex-military bomb disposal non-commissioned officers. He added that DeMil would be on-site once a month to ensure everything is going properly.

Mr. Hugus noted that Mr. Zanis had pointed out that a lot of munitions are not even being picked up. He asked if rounds that would fit in the chamber but were considered too dangerous to move could be transported in another manner such as a robotic technique. Mr. Schlesinger asked if DeMil could tell if a round was inert before it was placed in the chamber. Mr. Donovan said you cannot always tell beforehand, but can afterward. Mr. Schlesinger requested that a list be kept.

LTC Knott stated the military’s EOD would make the determination if the UXO is safe to move or not. LTC Knott said he is perfectly willing to look at any kind of technology, but he is not aware of any robotics that will climb into the T-10 and put it in the chamber. He reiterated that he is willing to review the technology but stated if EOD says the UXO is not fit to move, no one, uniform or not, is going to move it.

Mr. Donovan commented DeMil had used an androse inside of it. He explained that if the UXO is so unsafe that it is going to go off by human contact, you do not want to put an androse on to be picking it up either. He added that an 81 mm round is designed to penetrate 1.11 inches of hardened steel and therefore will do a lot of damage to an androse which are very expensive at $100,000 each.

Mr. Schlesinger referred to the Ordnance and Explosive CDC Final Disposition Safe Holding Area Report and asked for an explanation of the handouts. LTC Fitzpatrick explained that the 3-page stapled handout listed items sitting on the magazine at Five Corners. The single-page handout lists the items out near the APC that were in the Impact Area. The items that are listed "yes" on there are for the CDC, those that say "no" have not been approved for use inside the chamber by U.S. Army Training Center for Explosive Safety.

Mr. Schlesinger asked if there were other items to be moved. LTC Fitzpatrick replied that there are only two other items, an 81 mm and a 60 mm that have been identified as not safe to move, and are scheduled for detonation tomorrow. Mr. Schlesinger asked is there is anything that we know of that is safe to move that is not at Five Corners yet. LTC Fitzgerald answered no.

Mr. Schlesinger commented that there are all those items that have not been identified but have been located with the magnetometer and flagged. He added that Mr. Borci had taken him to a field with flags. He asked if those had been anomalies.

Mr. Borci said EPA cannot even put a number on how many anomalies there are, however the rounds discovered when the contractors do intrusive work, such as clearing a drill pad or collecting a sample, they just try to avoid. He added that when the contractors need to clear the drill pad, they need to dig and find out what each of those flags are, and that is when most of the UXO items are discovered that have either been open-detonated or are added to the CDC list.

Mr. Judge stated he was glad Mr. Donovan was here. Mr. Judge added that rounds can be cut in half, and then put into the chamber which he thought would be useful for the naval rounds. He commented that the reason behind this chamber is to eventually get to a point where areas can be cleaned without endangering anyone. Mr. Judge said it surprised him that none of the "top brass" in Washington had any idea how to move potentially dangerous munitions without endangering soldiers’ lives. He stated all they knew was detonation in place, which is what we want to get away from.

Mr. Judge stated that the NGB was conducting a detonation event the next day and asked if the Town of Sandwich had been notified. LTC Fitzpatrick replied that MAARNG did the right thing. He explained that the EPA had been notified 72 hours earlier, and the notice to the media had been placed 48 hours earlier. He noted that he had no control over when the media chose to release the information, but that the information had been released to the media. Mr. Judge stated a protocol for notification of local towns had been set up upon the discovery of the 1,100 mortars buried in a bunker behind a school. He said he wanted to ensure that protocol is followed which includes notifying the town administrator, and the town administrator then notifies the various selectmen.

Mr. Judge said that, historically, when a CDC was proposed they were told it did not exist. He said that after they pushed, Mr. Donovan stepped forward and said he could do that. Mr. Judge said someone decided that Mr. Donovan was not going to get that contract, which was awarded to another company. He added that, as far as he knew, the original company that was contracted to deliver this machine was still on the drawing board. Mr. Judge stated that Mr. Donovan had the foresight to develop a machine on his own, which is the only reason we are here. He added that then the Army also had the foresight to say, "we have one that works, let’s get it to the MMR" which he appreciated. Mr. Judge said the next phase is to make sure that these questionable rounds can safely be loaded into the chamber. He suggested trying to push the UXO around with a tank retriever to see if they will detonate and, if not, then load them into a CDC. He said he was astounded that the Army had not developed an automated system to load the CDC and that he thinks they have done so. He said the Army will need to be pushed harder as he knows that there are robots out there, he knows Mr. Donovan has access to those robots, and he knows there are other companies that have this type of thing that can move these rounds safely so that no one is in danger. He said it should be cleaned up and said he did not want 50 detonations a day based on the premise that we do not want to endanger anyone, so everything gets detonated in place. Mr. Judge stated that the point of bringing a CDC to the MMR was to detonate rounds in the CDC.

Ms. Frawley noted the time (9:50 PM) and asked if the team wished to continue. It was decided to continue.

Agenda Item #5. Public Information Team Services

Mr. Murphy opened his presentation by stating that the Public Information Team (PIT) members were making themselves available to review IART items that would be distributed to the public. He said he was asked to make this presentation to the IART on behalf of the PIT. He stated that he is the community involvement person from EPA who is working on this, as well as the IRP sites, and, from a selfish perspective, he would appreciate having citizens who are experienced at looking at this type of thing provide comments. The comments are recommendations but they are not things that are going to change the technical nature of a particular item, handout, fact sheet, or a proposed plan. He gave an example: in reviewing a fact four times there is a tendency to miss things, you do not catch the same type of thing you would the first time through. He said he thinks citizen review is helpful to the finished product. He added that the PIT members had asked him to make clear that they are not coming begging, they are offering their services as people who are interested in the project who think they can have a good effect on the end product. Mr. Murphy said a response from IART members is that PIT members could attend IART meetings, get up to speed and comment as part of this meeting. He stated that although this was doable, he thinks most people here understand that there are enough meetings and that people want to avoid as many meetings as they can. He said, as an efficient alternative, they could attend a PIT meeting and be presented with just sheets from both the IART and IRP. Mr. Murphy said this would be the official offer from the PIT, and that they are interested in doing that. He noted that people are open to other suggestions about coming to these meetings and participating as a general member of the public or trying to become a member of the team.

LTC Knott stated that, for the record, as NGB tries to expand the IART in both membership and community attendance, the PIT is another avenue to get more community people involved. LTC Knott said he would suggest the IART utilize the PIT but define the scope. He commented that the PIT was a good asset, they are operating on their own time, they do it because they want to do it and believe in what they are doing.

Mr. Schlesinger commented that PIT members will have to attend IART meetings to get the information that they want to serve out to the public. Mr. Murphy replied not necessarily. He suggested that if the information were in a fact sheet or a written document, it can be distributed in a draft format to PIT members, or team members here, before the final product is scheduled to be presented at a poster board session or in a fact sheet mailout. He said people would look at it after the technical project managers complete the draft and that PIT members or other citizens would review it to see if it is readable and if the maps make sense to the average person. Mr. Schlesinger asked what kind of timeline would be observed. He explained that, as it stands, IART team members are waiting a while to get information. He noted that Mr. Grant does a great job at scrambling real fast to get all the information out on a weekly basis. He asked if PIT involvement would not result in one more layer of bureaucracy, resulting in slower release of information to the team so that it is less capable of making decisions than it already is. Mr. Murphy replied that, as part of the public involvement plan the PIT is trying to work out with the NGB, they are trying to determine turn-around times. He stated that, for some urgent fact sheets in the IRP program, PIT does not get a chance to look at them. He said the PIT reviews them as time permits, it is not something that slows down the process or at least it has not done so in the past.

Mr. Schlesinger said that in June 1999 the IART had a great meeting but spent hours developing what the group called a fact sheet which was a negotiation of what the facts were. He said he questioned the idea of a fact sheet, as the facts are very sketchy. Mr. Schlesinger stated he would be hesitant to release to the public what are called facts by one party before they are seen by the team and agreed to that they are indeed facts. Mr. Murphy replied that the PIT would not be commenting on any technical information. He said the PIT would focus on readability and formatting. He commented that he does not think people should be wary of them treading on any of the technical facts.

Dr. Feigenbaum stated that he agreed with Mr. Schlesinger that it is just another layer of bureaucracy. He said that if the folks on the PIT are looking for something to do, because some of their work is running down through the IRP as we are getting more and more decisions on the plumes, then they need to attend the IART meetings. He commented that if the PIT was really committed to do the work, they have got to be committed to come to one meeting every six weeks. Dr. Feigenbaum said everyone wants more citizens on the team, so he would suggest that PIT people go through whatever process there is to join the team and then specialize in that particular activity. He added that right now the PIT only gains authority through CERCLA and the IRP, and would not even be empowered to do what Mr. Murphy is saying as the PIT per se. Dr. Feigenbaum commented that you cannot just put out documents to the public if you have no idea what kind of discussion has gone on, as the document is like the tip of the iceberg. You have got to see the iceberg, you cannot just write the cover sheet. Mr. Murphy said that he will pass that information along. He added that he thinks it is helpful that the PIT does not see the whole iceberg and are doing sheets that are out there for the general consumption. He noted that he thinks there is a balance between trying to get all that information in and getting a summary of a page or two which he said is essentially what the general public is looking for. He stated that he thinks that is the kind of document that is going to be helpful. Mr. Murphy said he will bring the IART's suggestion back to the PIT members and the team would probably see some PIT members at future IART meetings.

Ms. Frawley announced that NGB had wanted to discuss the IART facilitator proposal, but in the interest of time would put something in writing and put it out in the Weekly Notes. She noted the subject could be discussed at the next IART meeting.

Agenda Item # 6. Small Arms Range Discussion

LTC Knott commented that he thought the discussion on the CDC may have already answered Mr. Hugus' and Dr. Feigenbaum's questions.

Dr. Feigenbaum asked what NGB was proposing to do. LTC Knott said he would review the plans again. Dr. Feigenbaum stated that there were additional questions regarding testing relative to firing events and which ranges would be tested.

Mr. Grant said the presentation in January 2000 talked about soil and groundwater sampling at three ranges which were identified as the Alpha, Gulf and India Ranges. He noted that a revised proposal adding air sampling had been provided to the agencies three weeks ago. Mr. Grant said the revised proposal indicates that the intent of the air sampling is to evaluate air emissions from a current firing activity. He added that for the air emissions, it does not really matter whether the range has heavy use or not, the only criteria for the air sampling is to select a range where M-16 firing is occurring. Mr. Grant reported that the selection would be done in accordance with Range Control and the agencies in order to select a range that allows Ogden to put the air monitors in close proximity to the firing lines. He said there would be up-wind and down-wind air monitoring stations with sampling and analysis for propellants and metals.

Mr. Grant noted that the soil sampling proposal remains the same and commented that Dr. Feigenbaum and the team had requested sampling before and after the firing event, instead of just sampling post-firing. He said that the subject had been discussed in a technical meeting and that Ogden feels that the materials likely to be present, the semivolatile organic compounds (SVOCs) and the metals, are not mobile enough to warrant or expect to see a change for any particular firing event. Mr. Grant stated that Ogden is looking at cumulative firing impacts and that, by sampling after a firing activity, they feel the data would reflect not only that activity but all the firing activities that happened over the last many years. He said that the reason was because those contaminants are not moving. Mr. Grant reported that Ogden is still proposing post-firing soil sampling at the high-use ranges to measure cumulative impact, which is not really a significant change for them.

Dr. Feigenbaum asked then why would Ogden bother doing the testing right after the firing event. Mr. Grant replied that it did not make a real difference to Ogden if the testing was done before of after the firing event. Dr. Feigenbaum asked whether or not the propellant products washed into the soil. He commented that in the past, Mr. Grant had stated that there is a great deal of mobility in these products. Mr. Grant replied that Ogden is sampling for explosives, metals, and some SVOCs. He added that the propellant compounds Ogden is looking at do not have a very high mobility, and are likely to be present for a significant period of time afterwards. He stated that the same would be true for the metals and that the explosives are least mobile of all, or as bad as the metals.

Dr. Feigenbaum asked if they could test that hypothesis by seeing what a firing event does. Mr. Borci commented that the big picture here is to see if there has been an impact over 20 years of use. He added that we need to see if we can even detect if there has been an impact there before looking at the miniscule amount that is likely to be deposited during one event. Mr. Borci said he thinks the realistic picture is the difference in pre- and post-firing is so far below the detection limits that the results in the two sample rounds will be identical. He added, however, that over 20 years of use perhaps an impact may be seen. Mr. Borci stated that the IART needed to focus on this first and that the agencies agreed that this plan was designed to do that. Mr. Borci said EPA will evaluate the results and then address Dr. Feigenbaum's question of obtaining a further level of definition.

Dr. Feigenbaum commented that he is not sufficiently expert to know whether the products that came out of Mr. Zanis’ 1985 paper are mobile in soil or not, or if they are soluble or if they decompose further. He stated that the team needed to know that. Dr. Feigenbaum commented that Mr. Borci may not be looking at 20 years. He noted that if a big unit comes in this summer and is firing for six or eight hours at a time, it seems to him that there might be a lot of fresh product which will disappear. Mr. Borci said that his answer, in consulting with LTC Knott, would be to try and time the sampling event to be as quickly as possible after a firing event. He noted that the ranges being discussed were currently active and had been heavily used in the past.

Mr. Hugus asked when the test is going to happen. Mr. Borci said he could take a look at the training schedule, as he believed the test was set to go once EPA approved the plan. He said it would be just a matter of coordinating arrangements, and that he could get back to the team on this at the next IART meeting. He noted that it was possible the testing might occur before the next IART meeting, or shortly thereafter. Mr. Hugus wanted to know if the testing could take place as soon as the next heavy training date. Mr. Borci said yes and that he believed the testing could take place as soon as EPA approved the Work Plan. Mr. Hugus asked for the next heavy training date for small arms, and noted that training occurs almost every weekend, so testing could possibly take place on the upcoming weekend. LTC Knott commented that the Work Plan would need approval first before testing could take place. Mr. Grant added that MA DEP’s comments on the revised proposal were received last week and Ogden had not yet had a chance to respond to them. Mr. Hugus commented that once the plan is approved then the testing could take place the following weekend.

Mr. Schlesinger asked how the timeline would be devised. He asked if an old high-use range that is inactive would be used for comparison purposes. Mr. Grant replied that he thinks the initial stab is to get the "worst case" so Ogden is using the three ranges that they think will have the highest cumulative impacts. He went on to say that, as Mr. Borci mentioned, if Ogden finds impact on these three ranges they would then consider before and after testing or testing different ranges also. Mr. Grant said that he thinks soil sampling before and after a firing event would be a significant problem as the same soil cannot be sampled twice. He explained that the samples would be physically separate and the question arises regarding homogeneity of distribution. Mr. Grant said he did not think the changes would be detectable and this was another factor creating potential for confusion in interpretation of results.

Mr. Borci addressed the history of the Phase 2B Work Plan and said he believes the EPA requested that sampling take place at some of the original, older rifle ranges.

Dr. Feigenbaum asked who is supervising the design and implementation of the air quality piece, and how the IART would know they were going to have a real test. Mr. Grant replied that Ogden has been doing air sampling for the blow-in-place events, and he would assume Ogden would continue to do air sampling in this event too.

Dr. Feigenbaum asked if that was going to get approved by both agencies.

Mr. Schlesinger asked who would devise the soil sampling layout.

LTC Knott replied that these concerns are addressed in the Work Plan, which is reviewed by the regulators and the IART. He added that if the regulators do not approve, NGB would not do it. He noted that the plans include IART input. LTC Knott stated that the proposal will follow the normal sequence, it will go to the regulators and IART for comments. He added that if all agree fine, if not, the plan will be amended accordingly and NGB will move forward with it.

Dr. Feigenbaum stated that, for the record, he does not buy Mr. Grant's argument about the homogeneity. He stated that typically there are 20 firing positions and each one is similar. He said that he was sure Ogden would be able to get some soil to test.

Mr. Schlesinger noted that LTC Knott did not answer his question, and asked who is doing the soil sampling scheme. He explained that there was a spatial statistician in the TOSC group and he wanted to make sure that this person knows how the location is chosen and if it was representative of where the matter ought to be. Mr. Schlesinger said that he wanted the TOSC person to be able to review that information. Mr. Grant replied that the Work Plan proposed to the agencies is sampling on grids, which is similar to what is normally done in the Impact Area Study. He explained that the grids are centered on the firing lines so some of the grid points are in front of the line and some of the grid points are in back of the line. He added that the Work Plan proposes three sampling grids per firing line, one in the center and two on the outer edges of the firing line. Mr. Grant said he believes the sample depths are similar to what is done elsewhere, taking a 0-6-inch sample and a 18-24-inch sample.

Dr. Feigenbaum commented that he still thinks that without doing a before and after sampling, the assumption Ogden is making is that any given day of firing is insignificant. He said if that is true compared to 40 or 50 years of firing then the argument will be made to "just continue doing it because it is insignificant". Dr. Feigenbaum stated that this is the reason why the IART needs to get whatever data it can about what happens on a given day of firing.

Agenda Item #7. Wrap Up Schedule Next Meeting, Review Action Items.

Wrap Up, Schedule Next Meeting

Ms. Frawley suggested Wednesday, June 28, 2000 as the date for the next IART meeting. She stated she would prepare the action items and e-mail them to the team for comment.

Action Items:

1. EPA will forward to Mr. Gonser and LTC Fitzpatrick a hard copy of Paul Zanis’ 4/8/00 e-mail to the National Guard requesting that 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 their consideration.

2. NGB to invite its hydrogeologist to the next IART meeting to discuss the west end of the Demo 1 plume.

3. Richard Hugus requested that the UXO detonation soil sampling results chart be revised to include the actual sample results data.

4. Ogden will distribute the air emissions sampling results from the open detonation sampling event to the IART.

5. EPA asked that the IART citizen members forward any comments or additional questions on Textron Systems Corp.’s response to the CERCLA §104(e) information request to Margery Adams.

6. EPA will distribute a copy of the license agreement between Textron Systems Corp. and the US ACE to the IART.

7. NGB to report back to the IART the answer to the question, did AVCO use perchlorate as a rocket propellant at MMR.

8. Peter Schlesinger requested that EPA ask the US ACE 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.

9. NGB agreed to take under advisement air emissions testing at the backside of the controlled detonation chamber to determine the need to install carbon filters on the chamber.

10. NGB will include an IART facilitator proposal in the weekly notes for IART review and comment.

11. 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.

12. The following agenda items will be discussed at the June 28, 2000 IART meeting:
    - Assistance to IART Facilitator - NGB
    - Discussion on the west end of the Demo 1 plume

13. EPA to send a follow-up letter to MAARNG on an inventory on the number and type of items currently stored in the ASP.