Impact Area Review Team

River River Drops of rain on a leaf

Impact Area Review Team
American Legion Hall
Sandwich, Massachusetts
November 28, 2000
6:00 p.m.

Meeting Minutes






Todd Borci



Jane Dolan



Margery Adams




Jan Drake



Len Pinaud



LTC Joe Knott




LTC Donald Bailey

MASS Guard



Shaun Cody




CPT Bill Myer




Ben Gregson




Marty Aker




Tom Cambareri




Paul Zanis




Joel Feigenbaum



Richard Hugus









Jim Murphy









David Jacobson




Mike Jasinski



Ellie Grillo





Millie Garcia-Surette



Mark Panni



Paul W. Locke




Mark Begley




Brian P. Moran




Richard Judge

Sand. Selectman/SMB

Tony DeBaggis



David Dow

Sierra Club


Henry Byers


Robert Gill




Justin Mierz



Kevin Dennehy

Cape Cod Times



Mark Forest


Rob Clemens

AMEC Environmental



Marc Grant

AMEC Environmental



Kim Harriz

AMEC Environmental


Mark Applebee

AMEC Environmental


Bill Gallagher

AMEC Environmental


John Rice

AMEC Environmental


Darrell Deleppo



Chris Cheney


Nick Iaiennaro


John MacPherson




Ray Cottengain




Jae McInerny



Leo D. Montroy

Tetra Tech



Tom Rust

Tetra Tech

Linda Daehn

Tetra Tech

Vijay Garg

Tetra Tech


Mike Teate

Tetra Tech


Daniel M. Eddinger

Tetra Tech



Jim Quin

Foothill Engineering



Doug Shattuck



Doug Larson



Keith Comer




Karen Foster



Carl Gentilcore




Tom Fogg

Jacobs Engineering


Kristin Smith




David Urann




Pamela Bonin




Deirdre F. DeBaggis




Handouts Distributed At Meeting:

  1. Draft Agenda
  2. Status of October 19, 2000 Action items
  3. Unexploded Ordnance (UXO) Discoveries/Dispositions Since 10/19 IART
  4. Update Report for Massachusetts: US Army Corps of Engineers (USACE)
  5. Letter: Chemical Monitoring Wells for New 3 Million Gallons Per Day (3MGD) Water Supply Wells US Environmental Protection Agency (EPA)
  6. Letter: Executive Office of Environmental Affairs (EOEA) to EPA regarding "Chemical Monitoring Wells for New 3MGD Water Supply Wells"
  7. Reportable Concentrations (RCs) in Groundwater and Soil1 : EOEA and EPA
  8. GENERAL LAWS OF MASSACHUSETTS: Chapter 131: Section 58. Shooting upon or across highway; hunting near dwelling.
  9. GENERAL LAWS OF MASSACHUSETTS: Chapter 269: Section 12E. Discharge of a firearm within 500 feet of a dwelling or other building in use; exceptions.
  10. GENERAL LAWS OF MASSACHUSETTS: Chapter 140: Section 56A. Shooting Galleries.
  11. Presentation Handout: Numerical Standards in the Massachusetts Contingency Plan (MCP) : Paul W. Locke, Massachusetts Department of Environmental Protection (MADEP) Office of Research and Standards
  12. Presentation Handout: Archives Search Report (ASR) Integration and Enhancement
  13. Presentation Handout: Munitions Survey Project, IART Briefing
  14. Presentation Handout: IAGWSP UPDATE, November 20, 2000

Agenda Item #1. Welcome, Approval of September 7, 2000 Meeting Minutes, Review Action items
and Draft Agenda

Mr. Murphy convened the meeting at 6:10 p.m. He stated that he wanted to wait for everyone to be present before beginning the meeting and apologized for the delay. Mr. Murphy noted that the IART is being held at a new place this evening and welcomed everybody. He stated that before reviewing the agenda and action items he wanted everyone at the IART table to introduce themselves.

Review of Agenda
Mr. Murphy stated that before reviewing the action items he would like to review the draft agenda and the minutes. He noted that regarding the agenda, the Massachusetts Department of Environmental Protection (MADEP) has asked to move their presentation up to the first item because they have another meeting to go to this evening. Mr. Murphy informed the team that Dr. Feigenbaum had called to ask whether an item could be added under "Other Issues" regarding the United States Army Corps of Engineers (USACE) to provide their previous experience with unexploded ordnance (UXO). Mr. Murphy then asked if there were any other comments on the agenda. There were no comments and the agenda was accepted.

Approval of Minutes
Mr. Murphy asked if there were any comments on the minutes from October 19, 2000. There were no comments. Mr. Murphy stated the October 19, 2000 IART meeting minutes were approved without any changes.

Review of Action Items

  1. The Impact Area Review Team (IART) agreed that copies of handouts distributed at the meetings would no longer be included in the following month's IART mailing.
    Mr. Murphy stated that this action item, previously approved by the team was executed starting with last months mailing.

  2. The Massachusetts Department of Environmental Protection (MADEP) will report back at the November IART regarding the outstanding Ammunition Supply Point (ASP) inventory issue.
    Ms. Garcia-Surette stated that since last months IART there has been a lot of communication between the MADEP Southeast Region and the Executive Office of Environmental Affairs (EOEA) regarding the ASP inventory. She added that the EOEA has communicated to the Federal Environmental Protection Agency (EPA) and the Adjunct Generals office with the goal of resolving the issue of the ASP inventory.
    Ms. Garcia - Surette stated that she received a notice from EOEA stating that the Military is willing to talk to EPA regarding an appropriate data exchange process for the ASP. This notice reads: "EOEA does encourage that the EPA accept the ASP inventory information even if it means keeping it confidential for security reasons. MADEP is willing to enter into an agreement with EPA and the military to independently review and assess any and all information made available to EPA during the process. The goal is to ensure that the public is provided with the maximum amount of information allowable under the law. Again today the EOEA spoke with COL Constantine, BG Keefe's Chief of Staff, and he confirms the military is willing to sit down with EPA to discuss this matter."

    Ms. Garcia-Surette reiterated that the EOEA encourages EPA to accept the information with the condition that the information be kept confidential given security issues. Ms. Adams noted that the possibility of EPA receiving the information but not making it available to the citizens has been discussed in the past. Ms. Adams stated that EPA's position is that the ASP issue is a right-to-know issue, and the citizens who have been so active in the IAGWSP are entitled to the information as well; however, EPA will take that consideration under advisement once again.

    Ms. Garcia-Surette stated that MADEP or EOEA have not performed a legal review of right-to-know policies and a she believes legal review should be performed to determine whether this information falls under a legal exemption from the right-to-know policies.

    Ms. Garcia-Surette noted that MADEP endorses receiving the information in order to perform a comprehensive site assessment and characterization, at MMR. She said the information should be presented in a way that is consistent under the law. Ms. Adams stated that she understands what Ms. Garcia-Surette is saying; however, if EPA received the information, EPA would have to determine whether or not they could lawfully withhold the information from the citizens.

    Ms. Adams reiterated her point that the citizens have been very active in the IAGWSP and may have interesting perspectives to offer on what is contained in the ASP. Ms. Adams said that any security issues should already exist because the ASP is out there; however, as she understands, it is not under guard.

    Ms. Garcia-Surette noted the military is willing to give the regulators the information. She said the issue is what the regulators do with that information. Ms. Garcia-Surette stated the regulators are tasked with ensuring there is a comprehensive site assessment and in the spirit of gaining the information the Military is willing to cooperate with what they have communicated to the EOEA office today.

    Mr. Murphy stated that he believes EPA and MADEP need to discuss this issue further. Ms. Garcia-Surette added that MADEP considered the exchange of information, and requests EPA to undertake the offer to obtain the ASP information so that the process can be moved forward.

    Dr, Feigenbaum stated that he does not think that MADEP and EPA are the only interested parties regarding the ASP inventory. Dr. Feigenbaum said that he is in agreement with Ms. Adams that the citizens have been working on this for a long time, have an interest in knowing what is in the ASP and if there has been any spilling or leaking from that location. He noted that he believes it was discovered that there was toxic contamination leaking from the old ASP location, and the citizens have no idea what may be happening at the current ASP location.

    Dr. Feigenbaum stated that he has been working on the project for close to twenty years and has heard in the past the issue of national security used as a cover; and he does not accept national security to be a legitimate reason to not let the citizens know what is in the ASP. He stated that he believes releasing the information would not jeopardize national security in any way. Dr. Feigenbaum said if there is a question of somebody coming in to steal the contents of the ASP, he believes the Guard is not properly maintaining security at the site.

    Dr. Feigenbaum said he is not happy with MADEP and EOEA's response to this issue. He said he believes Secretary Durand should attend an IART meeting. He noted that Secretary Durand's predecessor used to attend IART meetings. Dr. Feigenbaum stated he believes that Secretary Durand has "maintained a fine disregard" for all the communications through MADEP to the IART. He added that he believes a lot of people are unhappy about that.

    Mr. Hugus stated that he came in late on the discussion and asked if BG Keefe has said he would release the ASP information if EPA kept it confidential. Ms. Garcia-Surette stated that that is correct. Mr. Hugus noted that the IART has already been through this and he is glad EPA has maintained that they will not keep information from the public and the citizens on the team.

    Mr. Hugus said that he believes roughly two years ago a crate of munitions was found in the ASP which was swelling. He said those munitions had to be removed from the ASP and detonated. Mr. Hugus stated that the IART found out about that incident because they have made it their business to know what goes on at Camp Edwards. He said he believes that the citizens have a right to know what is in the ASP.

    Mr. Hugus stated that BG Keefe maintains that he is a good friend of the environment and a good steward at Camp Edwards; however, Mr. Hugus believes BG Keefe is "stonewalling" the citizens from the ASP inventory. Mr. Hugus said that he would appreciate anything EPA can do to urge full disclosure of the ASP. He added that he is also concerned about possible contamination in the vicinity of the ASP that may be caused by explosives stored at the site, or the possible dumping of munitions there.

    Dr. Feigenbaum stated that he thinks neither MADEP nor EPA personnel are equipped with classification security clearances. Ms. Adams stated the EPA Region 1 has access to personnel in Washington who do have classification clearances. Dr. Feigenbaum asked if the ASP information would only be reported to those EPA personnel who have security clearance.

    Ms. Adams stated she will not speak for BG Keefe, however, her understanding is that this is not a national security issue. She believes it is a simple security issue and the Guard does not want people to know what specific munitions are at the ASP.

    Dr. Feigenbaum asked if simple security is a legal category. He said he believes either it is a bonafide security classification question, or not. He added if it is a security classification issue, then only those people who have been investigated by the Federal Bureau of Investigations (FBI), and who are given various levels of security clearance would be able to have the inventory of the ASP.

    Ms. Adams stated she can not speak to the rationale of BG Keefe. Dr. Feigenbaum noted he thinks the citizens are dealing with a "phantom" security classification, and the only people who find it impossible to know what is in the ASP inventory is the public at large. Dr. Feigenbaum also noted that he thinks the technical definitions of security are not being maintained by Secretary Durand's proposal.

    Mr. Zanis suggested that if the citizens can not see or know what is in the ASP, maybe the Guard should put in a series of wells around the current ASP location to see if the site has impacted the environment. He stated that he thinks about a dozen wells downgradient of the ASP could possibly detect if any contamination may be coming from the ASP and impacting the environment. Mr. Zanis added that he feels the citizens should demand the proposed wells at the ASP point to retaliate against the Guard's indecision.

    Mr. Borci stated he would agree with everything Mr. Zanis said up to "retaliate" point. Mr. Borci said EPA has added the current ASP as an area to be investigated under the Phase 2b part of the investigation and that series of investigations will occur over the course of the spring and early summer of 2001. He added that any environmental information from the Archive Search Report (ASR) and the Impact Area Groundwater Study Program (IAGWSP) will be investigated.

    Mr. Zanis stated he had indicated the current ASP site at the very beginning of the study to be an area where monitoring wells are needed. He added it has been three years and he believes it is about time to install the monitoring wells downgradient of the current ASP.

    Mr. Hugus stated that he forgot to mention that a couple of years ago when munitions had to be removed from the former ASP and blown in place (BIP) that there was a request from EPA for an inventory of that ASP. He added that that inventory was provided and was made public. Mr. Hugus said he believes the Cape Cod Times newspaper covered the story. Mr. Hugus added that as far as he knows there were no repercussions from releasing the information at that time, so the present security issue argument does not make sense to him.
    Mr. Hugus asked if EPA has any knowledge of improper disposal of around the ASP. Ms. Adams stated that is being investigated as part of the ASR. She added if there is any information EPA hopes to obtain it.
    Mr. Hugus asked if any representatives of the Guard could answer some of these questions. LTC Bailey stated that he can not add to anything other than the Guard has indicated their willingness to provide EPA with an inventory of the ASP as requested. He added that the decision to not make the inventory public is made above his level, and this is where the Guard stands.

    Mr. Hugus questioned if that means the Guard will provide the information to EPA with the condition that it not be released to the public. LTC Bailey stated that is what he believes was said. Mr. Hugus asked LTC Bailey why he does not want the public to know what is in the ASP. LTC Bailey reiterated that it is not his decision, it is for security reasons and that has not changed.

    Dr. Feigenbaum asked if anybody above LTC Bailey's level can tell the citizens what the next step is. Ms. Adams stated she thinks EPA will continue to push the issue and try to persuade BG Keefe to release the inventory in a way that it can be made public, and consider whatever options are available to EPA to move forward with the ASP inventory issue.

    Mr. Hugus asked if it is possible that the ASP inventory issue falls under the provisions of the administrative orders. Ms. Adams stated that is a possibility. Dr. Feigenbaum asked if an action item for the next meeting can be added that states somebody will report on the ASP issue. Mr. Murphy indicated that to be an EPA action item.

  3. The United States Environmental Protection Agency (EPA) and the citizen members of IART request that Air Force Center for Environmental Excellence (AFCEE) make presentations on the CS-19 investigation to the IART.
    Mr. Murphy stated that according to the written response, COL Coke from the Air Force Center for Environmental Excellence (AFCEE) agreed that when there is discussion at the IART on CS-19. as part of the overall discussion an Installation Restoration Program (IRP) representative would be available to supplement whatever Ogden is presenting.

    Mr. Hugus said he was present when COL Coke announced his decision at the Joint Process Action Team (JPAT) meeting. He stated what he believes was said was that COL Coke understood the citizens point of view, and that it would be OK for AFCEE personnel to make presentations at IART meetings. Mr. Hugus stated that what he believes he is reading on the action items handout is watered down. Mr. Hugus added that he believes somebody paraphrased COL Coke incorrectly, because Mr. Hugus's understanding is different.

    Mr. Murphy noted that he believes that COL Coke's answer to the action item was taken directly from the JPAT meeting minutes. Mr. Hugus stated that his understanding is that the IART would get primary information from the primary source directly, not through Ogden, on CS-19. Mr. Hugus stated he believes that means the IRP people would directly present to the IART members.

    Mr. Borci stated that he believes Mr. Hugus is correct, and what is written may be watered down in Mr. Hugus's eyes, but in intention IRP personnel presenting directly to IART is the commitment. Mr. Murphy asked if there was anybody present from AFCEE that could clarify. Mr. Aker stated that Mr. Hugus is correct, that COL Coke did agree to have an AFCEE person make a presentation.

    Mr. Zanis said that he believes the same situation has happened more than once where someone says something verbally and then it is written differently. He added that he believes it is not right. Mr. Zanis said he "wishes these guys could get it together." Ms. Bonin clarified that the written response to this action item was taken verbatim from the JPAT meeting minutes. Mr. Zanis noted he believed that COL Coke said there would be no more second hand information; however, this response is saying that Ogden will be giving the presentation and that the IRP will back-it-up. Mr. Zanis addressed Mr. Borci stating "nothing has changed and COL Coke needs to be invited back to the meeting and have a talk with him once again." Mr. Borci stated that AFCEE has made the commitment to present and EPA will hold them to it.

    After choking on a cracker and stating he can not find the toothpicks, Dr. Feigenbaum asked if Mr. Gill could clarify because he agrees that what is written does not convey the sense of what COL Coke said.
    Mr. Gill stated that Mr. Aker has already clarified that the intent of COL Coke's statement was that AFCEE will present. Mr. Gill said he does not question that these were the exact words COL Coke used, however, the intent that was certainly conveyed is more specific than what the words written on paper would appear to indicate. Mr. Gill added that AFCEE will be at an IART presenting.

    Dr. Feigenbaum asked if that would be clear enough for those taking minutes. Mr. Zanis asked if someone from the IRP can write that down on a piece of paper, while it is still fresh. Mr. Zanis noted that he observes there are no volunteers. Mr. Murphy stated maybe after the meeting. Mr. Zanis called everyone "Cowards." Mr. Murphy said it will be recorded in the minutes from this meeting.

  4. The Impact Area Groundwater Study Program (IAGWSP) will distribute copies of AFCEE's draft CS-19 Remedial Investigation (RI) document.

    Mr. Murphy stated this action item has been completed.

  5. At the November IART meeting, The National Guard Bureau (NGB) will distribute copies of the small arms range air and soil sampling results from 9/23/00.

    Mr. Murphy stated the Small Arms Range air and soil sampling results will be part of Ogden's presentation at the IART meeting tonight.

  6. Mr. Hugus requests that the Technical Team meeting minutes from September 4, 2000 be reviewed as to the discussion on the role of the IART in the IAGWSP. He wants to know who said that too much time at the IART meeting is being spent on issues that are not the primary focus of the groundwater study, and wants more detail on why this is a concern.

    LTC Knott stated that he said those words. He explained that he believes that there are issues that are not related to the groundwater study specifically, such as politics etc… and that the IART has maybe 3 - 5 hours once a month. LTC Knott stated that his point was that the IART meetings are to explain the technical part of the study with the goal of getting responses from the citizens, so EPA can tell the Guard what to do next as far as clean-up for the groundwater study.

    Mr. Hugus stated he has had to bring this up a few times since the study began three years ago. Mr. Hugus noted that he does not see that it is the citizens business only to study technical questions having to do with groundwater, although that is the most important subject at the IART. Mr. Hugus said in the beginning it was called the "Impact Area Study". He stated he thinks the citizens reserve the right to discuss any and all subjects having to do with the Camp Edwards Impact Area, and he appreciated LTC Knott's tolerance for bringing up subjects that don't have to do entirely with technical questions on groundwater i.e., ASP. Mr. Hugus said he believes the subject matter to be related to the contaminant problem and LTC Knott may see some issues as a political issues. Mr. Hugus then suggested maybe to make a change in the acronym, the "IAStudy" would concern air missions too, but the IAGWSP acronym defines out some of the things that the citizens are concerned about.

    Mr. Zanis stated he believes this to be another example of changing the writing after something is discussed. He stated he has the original paper at home that calls the team the Impact Area Review Team, and he stated he believes that the Army states itself that everything is related to the groundwater and it is a protected sole source aquifer. He noted he believes everything that happens on the base on top of the ground has an effect on the groundwater, therefore, he believes that the citizens can talk about whatever they feel like if it is going to impact the water.

    Mr. Murphy stated that he believes people have been very free to talk about anything despite LTC Knott's feeling that too many other things are being talked about. He added he does not see that it has been an issue in the past.

    Dr. Feigenbaum stated that all the minutes and paperwork that comes out is under the heading Impact Area Review Team. He believes the Army might be calling its office the groundwater study office, but that circumscription is not binding on everybody else. Dr. Feigenbaum added that he believes there is a lot of activity going on in the 15 thousand acres at MMR, and this meeting is really the only public forum that the army is providing to the people of the Upper Cape to deal with a host of issues.

  7. Dr. Feigenbaum requests a written program that defines the north/northwest corner of Camp Edwards investigation.
    Mr. Murphy stated there is a handout about the North/Northwest Investigation, and it is going to be discussed during Ogden's investigation. He added that although it is not listed on the agenda, it will be covered during the Ogden's update.

  8. Mr. Hugus requests the United States Army Corps of Engineers (USACE) provide information on plans for its selection of future contracts, and for its mechanism for regulators and/or citizen input in the final decision-making process.

    Mr. Deleppo stated that very strict federal acquisition regulations have to be followed to select contractors. He said the IART can participate in by reading the request for proposal (RFP) for that contract when prepared, which includes evaluation criteria. Mr. Deleppo stated evaluation criteria describes what measures the USACE is going to use to select the contractor. He said the citizens will be able to review that information and provide comments.
    Mr. Deleppo stated that the actual selection process consists of a panel of people in the USACE Concord office. He said in the past, members from EPA have sat on that panel as non-voting members and were able to participate on the review of the proposals, however, the selection process is closed to public participation. Mr. Deleppo said the citizens can review the RFP and criteria used to select the contractors.

    Mr. Hugus stated that he believes the procedure should be more democratic, and the citizens want to be part of a decision making process in the choosing of a new contractor. Mr. Hugus explained that his idea of being part of the decision making process to be provided with a list of the potential contractors. Mr. Hugus suggested potential contractors come to an IART to present so the citizens can help decide who they think is the right contractor for the job. He added that would provide citizen input to the USACE. Mr. Hugus stated he does not understand where this is a violation of federal law.

    Mr. Deleppo stated that the USACE has to follow the regulations that are part of the law. He said that the USACE works with these laws and it is very important that when the proposals come in to the USACE that confidential information from the different contractors is maintained and not allowed to go into the public forum. Mr. Deleppo noted that he is trying to work with the citizens to get their involvement as best as the laws allow.
    Dr. Feigenbaum asked Mr. Deleppo to clarify that six to nine months down the road Ogden will not be involved. Mr. Deleppo stated it is possible, and the USACE will keep the citizens involved in how to best transition the contracts. Mr. Deleppo added that some day, yes, Ogden will be gone, the studies will be complete and the project will move into a different phase. Mr. Deleppo said Ogden is working on the investigation part of the project. He added there will be a design phase of the project and then there will be the actual execution of the work. Mr. Deleppo noted it is not likely for Ogden to be included in all of that, which could take 7 to 10 years.
    Mr. Gonser stated that he was a warranted contracting officer for a number of years, and what he believes Mr. Deleppo is trying to say is that every contract has limits, either time limits or monetary limits. Mr. Gonser said with the end of the scope, time, or money, a contract ends by definition. He added that he believes at some point the scope of the time or money will end for Ogden. Mr. Gonser explained that at that point what happens is another contract mechanism is created and Ogden, like all other contractors, would have the opportunity to participate. Mr. Gonser stated that contractors that have worked on a site and have good reputations are usually favorably considered, so there certainly would be no prohibition of Ogden to participate like all the other contractors who would want to bid on it. He said Ogden would not be excluded, but their contract by definition will end at some point because the requirement is limited by time, money and scope.

    Mr. Gonser stated that regarding Mr. Hugus's request, one thing the USACE can do is, check on the contractor bidders, call references, look at previous work, bonding capacity, management skills etc. He said that criteria can be presented to the team, so there is a way to get citizens thoughts on particular offers as the process proceeds, but there is a very strict regulations on the process and how USACE can do it.

    Mr. Hugus stated when the USACE was brought in by the Guard a couple of months ago it was a complete surprise to everyone and he believes that to be an example of how citizens have not been included in decision making. Mr. Hugus said he does not take that as a sign in confidence that the Guard is working with the citizens. Mr. Hugus stated he is asking for notice up-front about contractors and who is being considered. He said if the only issue is that there are restrictions on citizens hearing confidential information of contractors, he would be willing to waive his right to hear that information, but would like to know the contractors history, where they have been before, what they have done and weather they have cleaned up groundwater with explosives in it before. Mr. Deleppo stated all those requirements are in the selection criteria.

    Mr. Cambareri stated that he believes Mr. Hugus would like to have an opportunity to see presentations by the perspective bidders for this project. Mr. Cambareri asked if it is possible for the bidders to have a "face to face" with the community.

    Mr. Deleppo confirmed Mr. Cambareri's request for the team to observe presentations by the firms that are proposing. Mr. Cambareri said yes. Mr. Deleppo stated he will look into that as an action item.
    Mr. Cambareri noted he was reading an article in a magazine that stated that Foster Wheeler has been awarded a 60 million dollar contract by the USACE to provide work for engineered planning, execution of projects or unexploded ordnance or other contaminents present. Mr. Cambareri asked if Foster Wheeler is under the contract with the Huntsville, Alabama section of the USACE to start to do some of the support work for the USACE at MMR. Mr. Deleppo stated that contract was not for the MMR project.

    Dr. Feigenbaum said he wanted to repeat that he heard it very clear that Mr. Deleppo said in six to nine months Ogden was not going to be here, although Mr. Gonser has clarified what that means, Dr. Feigenbaum stated he is concerned with the way it was verbalized. Dr. Feigenbaum stated he thinks it indicates Mr. Deleppo's intent. Dr. Feigenbaum said he does not want to be bothered by months of examining various corporate resumes. He said he believes Ogden has the track record and the capability to do the job, and since they have done an excellent job at the MMR, he thinks the preset position should be Ogden to continue with the job.

    Dr. Feigenbaum stated that for the JPAT, Jacobs Engineering is there for all phases of the project. He believes that their contract comes to an end, but gets renewed without any notice showing. Dr. Feigenbaum stated he does not understand what is going on. He said the USACE shows up and all of a sudden there is going to be a bunch of changes. He then asked Mr. Deleppo if the USACE has worked with Ogden or Jacobs engineering before. Mr. Deleppo stated he does not know the answer to that question off the top of his head.

    Mr. Gonser stated that he believes Ogden probably has a USACE contract somewhere because Ogden is a large company. Mr. Deleppo repeated that his original intent was to let everyone know that the contracts will eventually change. He said the job of the USACE is to maintain continuity between all the phases of the different contracts and subcontracts.

    Ms. Grillo stated that AFCEE was brought on because of their contracting flexibility, and asked if the USACE has the same type of flexibility in their contracts. Ms. Grillo stated it was something that can be reported back at a later time. Mr. Gonser stated he will not answer for Mr. Deleppo however, the USACE has tremendous flexibility and a lot of capabilities.

    Mr. Murphy stated that he will move the IART forward because MADEP has another meeting they need to present to tonight. He invited Ms. Garcia-Surette to respond to the agenda item regarding follow-up letter sent to IART regarding Background Soil Concentrations Methodology. He then stated the IART would return to finish the answers to the action items after MCP reporting is completed.

    Ms. Garcia-Surette thanked the Team for giving MADEP the opportunity to speak tonight. The presentation, she noted, is entitled "Numerical Standards in the Massachusetts Contingency Plan (MCP)." She introduced Mr. Locke who is the Chief technical person at the Office of Research & Standards, and Mr. Moran is the Policy Division Director. She stated that she received a letter from Mr. Hugus, with respect to the MCP. She said the MCP is a state superfund by Statute Chapter 21.e; regulation 310cmr 40.000. The MCP in combination with the Safe Drinking Water Act (SDWA) are the two main regulations implied at the Camp Edwards Massachusetts Military Reservation (MMR) Impact Area. She said that the state employed the MCP as a program that is mainly a privatized program. MADEP has Licensed Site Professionals (LSP) to make MCP decisions. She noted that MMR is a Tier 1a site; which means that it is one of MADEP's top priority risk sites. She stated that MADEP has direct oversight of the MMR.

    Ms. Garcia-Surette stated that Mr. Hugus's letter had valid questions such as; what the numbers are that MADEP staff use to make determinations of requirements for notification, how are the numbers derived, and what do they mean. She said that in addition, Mr. Hugus's questions included protectiveness issues, and also chemicals that may not be identified in the Oil and Hazardous materials list on the Appendix of the MCP. Ms. Garcia-Surette stated there are chemicals at the MMR that are generally rarely detected. Most of those chemicals are UXO related; e.i.; RDX, HMX, TNT.

    Ms. Garcia-Surette noted that MADEP is undergoing an MCP re-write. She stated that every 5 years MADEP revisits the MCP regulation, to determine what information need to be updated. Information would include: sessity data, improvements in technology, modeling, and also through the IART table the request came to incorporate valid chemicals to be recorded in the MCP. She stated that RDX and HMX are good examples.
    Ms. Garcia-Surette thanked Mr. Hugus for asking & giving MADEP the opportunity to present MCP reporting information for those who want to know more about the MCP. She said she encourages further dialogue with citizens regarding jurisdictional boundaries that MADEP working-out.

    Ms. Garcia-Surette stated that the technical meetings held weekly ensure coordination is maintained of the requirements set forth in the administrative order. She said MADEP LSPs have to meet these requirements to give proper advice to the respondents or potentially responsible party (PRP) of EPA administrative order.

    Agenda Item #3. MCP Reporting

    Mr. Locke stated that there is a terminology acquired when working with the language of the Massachusetts Contingency Plan (MCP) on a daily basis, and invited people to interrupt him if they do not understand some terminology he may use.

    Mr. Locke stated MCP numbers are broken down into two categories: notification triggers and cleanup standards. He said notification triggers are the numbers or values of a chemical found at a site that exceed established numbers in the MCP. If a sample exceeds a notification trigger, then the PRP is required to report to MADEP.

    Mr. Locke explained that cleanup standards or values are called Method 1 standards in the MCP. He added that there are also numbers in Method 2, and Method 3 Upper Concentration Limits. He said there are so many numbers that it is easy to get confused so he is going to help make some sense out of it tonight for the IART.
    Mr. Locke referred to "The MCP Process…Simplified" slide projection and reinforced the fact that the MCP is not simple. Mr. Locke said MADEP has about 500 LSP's who help guide PRPs or responsible parties through the MCP reporting process because it so complicated. He said he will discuss notification, what happens at the time of notification and how the cleanup standards are derived, used and implemented.

    Mr. Locke stated that outside of the MCP a lot of locations gain information about concentrations of oil and hazardous material in soil. Under the MCP process the state of Massachusetts (MA) does not require sampling if you are outside the MCP. He said many states have requirements at different points in time where samples must be taken, such as in a real estate transaction, but MA does not. Me. Locke said that MADEP's process is triggered by someone acquiring knowledge.

    Mr. Locke stated that MADEP has a list of reportable concentrations in the MCP. The criteria has to be very clear, unambiguous or "black and white," the sample is either above or below the MCP number. He said at this point in the MCP process there is no LSP involved, however, if one sample exceeds an MCP value or concentration, notification to MADEP is required. Mr. Locke explained that when notification is required, the numbers, or values used are Reportable Concentrations (RCs).

    Mr. Locke stated that if the concentrations in a sample are less than the MCP value, there is no requirement to notify MADEP at that point in time. It does not mean the site is clean, or does not pose a risk to health, safety, and the environment. He explained that it means given the knowledge gained from taking the sample, there is not at this time, a notification requirement. The purpose of the RCs is to determine whether a concentration of a contaminant has to be reported to MADEP.

    Mr. Locke stated there are still things that can initiate the - an assessment and remediation process beyond RC's. He said it is possible that at some point in time, even though concentrations may be below the RCs, there might still be a significant risk of harm, and a regulatory and statutory obligation to remediate that site. However; for the purpose of the MCP, the decision is very clear whether the concentration is above or below the MCP RC's. Mr. Locke explained that the MCP is one tool that can initiate an assessment or remediation of a site, however, it is not the only tool.

    Mr. Locke stated that if an RC is exceeded MADEP has to be notified. The MCP process begins with a site assessment. A site assessment includes, gathering more information to get a better understanding of what the contaminents are, where they are going, what media they are in, who is being exposed, and how they are being exposed. He stated the next step is the evaluation of risk.

    Mr. Locke stated that in the MCP there is a flexible risk characterization process. He explained there are three approaches in determining how significant the risk is at a site. He said that the public pushed the MADEP to form three approaches, versus having only one option of detailed site specific risk assessment.

    Mr. Locke said MADEP has a lot of sites that are straightforward, with contamination limited to soil and/or groundwater where it is relatively easy to understand the contamination. He said for this reason the public pushed MADEP to form simple steps of cleanup requirements so that they do not have to go directly into the risk assessment process.

    Mr. Locke explained that MADEP derived two approaches, Method 1 and Method 2, to give people a more straightforward way to evaluating how bad a site may be. He said Method 1 is the generic list of cleanup standards. These levels are published in regulations, and risk characterization determination is made through a simple comparison of site concentrations to the Method 1 standards. He explained if the concentration is above the Method 1 standard, then remediation would be indicated; if the value is below Method 1, it can be determined that the site is clean enough, the next step would be to proceed to get out of the MCP system.

    Mr. Locke stated that Method 2 is an "in-between" approach. He said originally, in 1993, MADEP provided the simple approach of Method 1 standards. The other choice was the more complicated approach of doing a comprehensive site assessment. Mr. Locke said that the Division Director of the office at that time, wanted to give the people a middle-ground between the two extremes. He added that in a lot of cases there are sites that have Method 1 standards, but have detected one or two chemicals for which MADEP have not published a standard.

    Mr. Locke stated there about 120 generic standards at this time in the MCP under Method 1. He said about 85 percent of sites in the MADEP system get out of the MCP process by using Method 1. He noted that those standards are covering the vast majority of sites and is working effectively because the right chemicals are being targeted. However, some sites may detect chemicals that are not on the Method 1 list, that are not typically found at hazardous waste sites, that MADEP did not develop a standard for.

    Mr. Locke described that Method 2 has regulations in place, strict guidance and mathematical equations, which lead people to generate a new standard equivalent to Method 1. He noted this is basically filling in data gaps. If a contaminant is found which does not have a standard under Method 1, the step-by-step guidance and regulations lead to the development of a standard which would be the functional equivalent to Method 1. He explained the calculated number would be used as a simple comparison just like in Method 1.

    Mr. Locke stated that all of the standards are set at a cancer risk levels of 1 in a million per chemical, or non-cancer risk level of an EPA hazard index of 0.2. These levels are low enough so that multiple and/or cumulative impacts from having multiple chemicals or exposures would not result in a significant cumulative risk.

    Mr. Locke stated that Method 3 is the traditional site-specific risk assessment. MADEP would assess exposure, how people came into contact with the contamination. The Risk calculations that come out of that assessment are either a cumulative cancer risk and a cumulative non-cancer risk. In the regulations there are strict limits of 1 in 100,000 for cumulative cancer risk, and a hazard index of 1 for non-cancer risk.

    Mr. Hugus stated that when he asked Ms. Garcia-Surette for a presentation on this issue, it was not to get an exhaustive description of the MCP process. He stated what he is interested in is why MADEP's reportable concentrations for RDX are so low. Mr. Locke said that he will explain Mr. Hugus's question, but while he is here at the IART he is going to give his presentation.

    Mr. Locke stated there are other MCP considerations established when remediation is necessary. He said that "Risk of Harm to Safety" does not exist in numerical standards, and has to be evaluated separately. He noted that UXO would fall under "Risk of Harm to Safety" under the MCP.

    Mr. Locke stated another MCP consideration is the "Elimination of Any Continuing Sources". This requirement is simple and includes a requirement to remediate to background where it is feasible. He said the MCP is risk-based but risk assessment is not the only thing that derives the cleanup requirement.

    Mr. Locke stated he will only present one of the two examples he prepared to show where the cleanup numbers come from. He said there are three groundwater categories, and he believes the groundwater at MMR is a groundwater 1 (GW-1) area which means that it is being protected for current and future use of drinking water.
    Mr. Locke stated that GW-1 standards are derived two ways. One is an overriding rule that if there is a MA maximum contaminant limit or a guideline set by MADEP, it is adopted so that cleanup requirements remain consistent within the MCP and the MADEP Water Supply Program.

    Mr. Locke explained that noncancer risk and cancer risk concentrations are looked at, as well as potential odor impact, public welfare, quantitation limits and background. He said they do not want to set standards that are below background. MADEP has a statutory requirement to cleanup to background; however, they do not have a statutory authority to require to cleanup beyond background.

    Mr. Locke referred to quantitation limits which are for contamination that can not be measured. He said if you can not measure it, you can not set a standard for it. Mr. Locke stated that next step is to incorporate the highest of the three concentrations: noncancer risk based, cancer risk based, quantitation limits, with ceiling concentrations. He said that ceiling levels were established as an upper limit on how high (inaudible) calculated standards could set. Then the lower of the 2 concentrations are adopted as MCP GW-1 Standards.
    Mr. Locke stated that for all of the chemicals MADEP goes through this process. The assement of drinking water, volatilization indoor air, ecological impacts receiving surface water bodies. He said for soil there is a similar assessment, but what is different for soil is leeching based concentrations.

    Mr. Locke explained that when soil standards are being set, MADEP looks at the potential impacts of groundwater as well. The soil standard will vary depending on what kind of groundwater underlies it. He explained the kinds of groundwater include drinking water, sole source aquifer, ecological impact in discharge of surface water, volatilization indoor air, in addition to the noncancer and cancer risk of direct contact with the soil.
    Mr. Locke moved forward to discuss how the RC's are derived. He explained there are 10,000 chemicals on the MA oil and hazardous materials list, and 120 calculated Method 1 standards. He said if a detected contaminant is one of the 120 chemicals in the MCP, generally it is based upon the Method 1 standards.

    Mr. Locke explained that if there is not a Method 1 standard for a contaminant, RCs should not be considered as specific indicators of risk, i.e., they are not risk-based. Mr. Locke stated that these numbers come from reportable quantities. He clarified that reportable quantities are values that are adopted with modification from EPA RQ's, or derived through an algorithm.

    Mr. Locke stated that MCP cleanup standards are protective standards, and that MCP provides a methodology for the derivation of site specific cleanup standards. Mr. Locke said that MADEP is specifically adding cleanup standards and thus calculating reportable concentrations for RDX and HMX, to expand the list of chemicals concerned at MMR. Mr. Locke stated there is a handout available that provides more detailed algorithms relating reportable quantities to RCs.

    Mr. Hugus asked to add nitroglycerine to the list along with RDX and HMX. He stated that nitroglycerine is something that has been detected in high levels in the impact area. Mr. Hugus then asked what is MADEP using as RCs in lieu of setting a standard for concentrations of RDX in soil.

    Mr. Gregson stated that the numbers are 100 ppm in soil for RDX, that is the RCs, there is no Method 1 standard for RDX. He added that in groundwater it is 1 ppm for RDX. Mr. Hugus asked why the standards are so low when we know RDX and HMX leaches into soil and into groundwater and he believes that the standard should be much higher that 100 ppm.

    Mr. Locke stated Mr. Hugus may want to suggest a lower standard, because lower standards are more protective. Mr. Hugus agreed, and stated that the standards should be ppb not ppm. Mr. Locke stated that draft numbers will be out and finalized by this spring for RDX, HMX.

    Mr. Locke stated the revised MCP went into effect in 1993. He said there was a review process which began in 1998, and MADEP is currently in the second wave of regulations coming out of that review process.
    Mr. Hugus stated that all he can do is urge MADEP to make better standards in soil in light of what is being found at Camp Edwards. He said that he believes the Guard is appealing to MADEP standards because they are not as stringent as EPA standards and that that the MMR should be proof to the regulators of the need for more stringent standards.

    Mr. Locke stated that Mr. Hugus probably heard that the indicated RCs will be new to the MCP and the actual RCs will be different than what they are now, but in all likelihood they will be lower than current RCs which are default generic RCs, not specific to those chemicals, and do not take into account toxicity or migration potential; however, they will come this spring.

    Mr. Moran stated that he is present to monitor Mr. Locke and believes Mr. Locke is doing a great job presenting. Mr. Moran stated he does not have anything to add other than to encourage the public process during the right development of the numerical standards. He added it is great to have IART input but wants to caution that in setting state wide policy it is valuable to learn lessons from individual sites, but there is a need to keep an eye on the big picture of where the majority of the cleanups and customers are for the MCP program. He said all sites are not necessarily as unique as MMR. Where MADEP can accommodate new standards and direct resources in their development, MADEP will, however, in terms of trying to address other contaminents of concern (COC) may be more challenging for MADEP.

    Mr. Dow stated one of his concerns in setting cleanup standards and reportable concentrations based on loosely or tightly ecological risk assessment, is that many of the plumes at the MMR not only have RDX and HMX, but have heavy metals, pesticides and other COCs. Mr. Dow stated he heard they set a cleanup standard based upon a single chemical which seems to pose the greatest threat to public health and ignores the fact that there is a toxic mix and not just one chemical. Mr. Locke stated that this presentation was the MCP process simplified; however, in simplifying the process, certainly a number of factors are left out.

    Mr. Dow stated he believes the real concern is the drinking water, and whether all the bad stuff is going to be removed when treated at the well head. Mr. Locke stated that MADEP needs to maintain consistency with the federal drinking water program, federal maximum contaminant level (MCL), and the MA drinking water program. Mr. Locke added that to the extent possible, MADEP is adopting the standards from all the above programs.
    Mr. Judge stated that he is surprised that the IART has not suggested background levels in the methodology. He said he was looking at methodology levels that seem to indicate that reaching background levels are unattainable by either expense or technologically not feasible. He stated he believes that the challenge is when the base was leased to the federal government the lease says this land shall be returned in its original condition to the original department who was in charge of it.

    Mr. Judge stated that he believes that "original condition" is not equivalent to MCL's, and he believes that original condition means background. Mr. Judge said he understands that what is being said is that the concern, in regards to the health of drinking water, is that MADEP is going to have to follow certain procedures and not clean up what is there. Mr. Judge stated that regarding the issue of technologically and economically feasible, he believes the technologies developed at MMR in the past 2-3 years are light-years ahead of what we had 5-10 years ago. Mr. Judge stated he believes that in 5 - 10 years from now, MMR will fall off the technological map because MMR will be so advanced in what they are doing. He said it will also prove economically feasible over the next couple of years because the cost of water on the cape could potentially skyrocket. He then asked if the economics being discussed are including the health effects, the cost of future water supplies.

    Mr. Locke stated that he believes Mr. Judge's questions should not be directed toward him because they are questions specific to military contracts. However, Mr. Locke said he can speak to MADEP's general approach that under the MCP MADEP does have statutory requirements to remediate to background and feasibility does take into account the health impacts. He added that the minimum requirement is that MADEP has to eliminate significant risk.

    Mr. Cambareri asked who determines significant risk. Mr. Locke stated significant risk is determined through the risk assessment process. Mr. Locke explained the regulatory requirement is to reach statutory goals and the statute, chapter 21E, requires remediation to background where feasible. He said MADEP does not have the legal authority to require anything beyond that statutory requirement.

    Mr. Judge stated feasible is the word that he is speaking about. Mr. Locke stated feasibility takes into account technology and cost, as Mr. Judge described. Mr. Locke reiterated that he is not the person to direct these questions to for two reasons. The first reason is that he is the risk assessment specialist, not the feasibility specialist. Secondly the contracts that the Guard have to return the base to its previous owners and conditions, is an issue outside of the MCP process.

    Mr. Judge petitioned Mr. Locke, that it will not be outside of the MCP process in the future. Mr. Judge said right now the National Resource Trustee council is putting together a payment to be made by the federal government to the state based on the damage that has been done. Mr. Judge stated when Mr. Locke talks about returning to certain levels, the citizens need to know exactly what they can not get because the federal government will be responsible to make up the difference in a claim to the state of MA when the whole process is over with. He added that his original intention for speaking is to remind folks that they should expect to return the base to the way it was. And believes it can be done and should not expect anything less.

    Mr. Locke agreed with Mr. Judge that the default position from the state is in the regulation statute that remediation to background is the goal. Mr. Locke said that only with a justification that it is not feasible to do so, that it is not acceptable to consider allowing residual levels above background to remain at MMR.
    Mr. Borci stated that the issue of cleaning up to background is important to everyone. It is in the MADEP regulations and is written in the administrative orders and is the goal at the MMR for this program.

  9. Mr. Schlesinger requests an answer to the question of whether or not the USACE has resources to support the attendance of IART citizen members at the technical meetings.

    LTC Knott stated he is prepared to give an answer, but prefers that Mr. Schlesinger was here to receive the answer. However, LTC Knott said de did not coordinate with EPA and MADEP on this so the written response is incorrect. He said that based on the TOSC members schedules, they can not attend nor teleconference to the Technical meetings. LTC Knott stated he is proposing for the Technical Team to amend their time to better allow the TOSC members to be there because they represent the IART team members that are citizens.

    Mr. Borci stated that he understood the request differently. He said the request was for funding. The TOSC members do not have the time to devote, so moving the meeting time will not solve this issue. Mr. Borci added what was going to solve it was giving funding to a contractor that the citizens could use as a full time resource to review documents to provide input on technical issues. Mr. Borci stated that he and LTC Knott will talk to USACE to get a contractor for this task.

  10. Mr. Hugus requests that MADEP ask the Executive Office of Public Safety (EOPS) not to allow the usage of ranges on Greenway Road. MADEP will research the usage of the Greenway Road ranges.
    Mr. Pinaud stated MADEP has communicated with EOEA on the issue, and the EOEA requested further research. However, Mr. Pinaud said he has hand-outs for review and suggested either discussing at the table tonight or waiting for the next meeting where Mr. Pinaud may have more information.

    Mr. Pinaud said the EOEA asked him to look at the laws that are on the hand-outs regarding Mr. Schlesinger's and Mr. Zanis's concerns about hunting and shooting range regulations. Mr. Pinaud added that during their conversations with EPA noise issues were brought up. Mr. Pinaud stated MADEP researched all of the issues and he will quickly review them.

    Mr. Pinaud passed hand-out materials around the table. He said he can make more copies of the information, and if anybody wants more information it is accessible via internet, he can provide the web address.
    Mr. Pinaud stated he spoke to Mr. Steve Grilly from the Division of Fisheries and Wildlife, who provided 3 Laws regarding hunting ranges and shooting ranges. The Law states that there will be no discharging of a firearm across a roadway or within 150 feet of a paved road. Mr. Pinaud stated his interpretation is that the Ranges are set up for target practice, so this does not apply.

    Mr. Pinaud stated the other issue the law addresses is that the law of hunting or possessing of a firearm on land of another within 500 feet from a dwelling in use, and the law only applies if you are hunting on somebody else's property. Mr. Pinaud stated that at the Ranges they are target shooting, not hunting so this does not apply. He added that the property is owned by the Commonwealth of MA and is actually leased by the Army. And essentially, the Army have a lease to do this shooting activity.

    Mr. Hugus stated the homes on Greenway road are within 200 feet of the ranges at Greenway Road. Mr. Pinaud stated the ranges are set up as target ranges and they are not on somebody else's property. . Mr. Pinaud added that his interpretation is that the law states you have to be on somebody else's property, and the Army is not, so in Mr. Pinaud's opinion, it does not apply.

    Dr. Feigenbaum stated that he thought Mr. Pinaud said you can't discharge a firearm within 150 feet. Mr. Pinaud pointed out that the law states across a roadway. Mr. Pinaud repeated: 500 feet from a dwelling in use but you have to be on somebody else's property. Dr. Feigenbaum stated he thought that Mr. Pinaud said something about 150 feet. Mr. Pinaud said that he said within 150 feet of a paved road. Dr. Feigenbaum then asked about Greenway road. Mr. Pinaud stated that in his reading of the law, it states across the road, if you are not firing across the road, his reading tells him the distance to the road does not matter.

    Dr. Feigenbaum stated that he read it as a discharge of a firearm across a roadway or 150 feet from it. Mr. Pinaud stated Dr. Feigenbaum has a good point, he said one thing he did not do was he did not measure the distance from the firing ranges to the paved road, so that is one thing MADEP still needs to check on.
    Mr. Pinaud moved on to the next law Chapter 269 which is Discharge of a Firearm, and stated the following are exemptions. Mr. Pinaud said that the MA law reads, "you can not discharge a firearm within 500 feet of a dwelling in use without permission of the property owner", however, he added it does not specify if you have to be physically on the property or adjacent to it. Mr. Pinaud stated what the exception reads is, "persons using target ranges with consent of the owner or legal occupant of the land", Mr. Pinaud interpreted this law and said that if you are the legal occupant of the land or have the consent of the owner than you have an exception. Mr. Pinaud reiterated that the Army has a lease for the property, and Mr. Pinaud's reading of the law gives the Army exception. Mr. Pinaud stated he included another law that he will not discuss which talks about shooting galleries and it probably does not apply but he is including it because Steve Grilly sent it with the package.
    Mr. Pinaud said the last issue he needs to discuss is the MADEP noise policy. He explained The Division of Air Quality Control writes policies, which are not laws, but they help interpret how MADEP applies the law to the regulation. He continued with this section, which reads, "there is an exemption for police fire, civil and national defense activities." Mr. Pinaud stated that his interpretation is that there is an exemption for the Army with regard to national defense activities for noise.

    Mr. Pinaud explained he did not investigate whether there are other environmental issues, i.e., contaminents; one of the things recently sent to Mr. Pinaud by Mr. Zanis is called "Emissions Related to Munitions Firing" it is a case study which Mr. Pinaud stated he intends to read. Also he said Ogden will be presenting some information on the Small Arms Firing. He stated that is where MADEP is at in answering some of the IART questions.

    Mr. Hugus said that maybe the action items can be added to the Agenda so the IART does not automatically run behind in discussing the action items. Mr. Murphy clarified whether he meant to give the Action items discussion a longer time. Mr. Hugus stated yes.

    Mr. Hugus stated he wanted to make a point that he does not think IART should quibble about the General Laws of MA and whether they are applicable to the ranges on Greenway Road. Mr. Hugus stated that he believes all the activities at Camp Edwards that have led to the damage that has been found to the environment have been legal activities. Mr. Hugus said that in the past the laws had to change. Mr. Hugus said For example, it used to be legal to fire artillery, pyrotechnics, to demolish weapons in open air and open land. Mr. Hugus added that had gone on up until now without any conflict with MA General Law.

    Mr. Hugus stated he believes that the military should not be firing rounds right next to homes that children live in on Greenway Road. Mr. Hugus stated he does not expect there to be a solution to this problem through legal means or through appeals to BG Keefe. He stated this solution will be a political one and he urges people who represent political leaders in this region to pay attention to this issue. Mr. Hugus stated they have been trying to get a promise from BG Keefe to stop firing on Greenway Road, or to certify that it will not happen, and he hasn't been able to get a commitment.

Agenda Item #2. ASR Team Update

Ms. Daehn introduced herself as the Project Manager for the Archive Search Report (ASR) Integration and Enhancement Project. She stated she would like to provide a quick overview, describe what has been completed so far, and provide a rough schedule of major milestones.

Ms. Daehn stated the project was initiated at the end of August with a kick-off meeting with EPA, NGB and MADEP. Ms. Daehn stated there are two main purposes of the ASR project. The first is to collect additional information to support the ongoing environmental work, Groundwater Study and UXO Investigation project, to supplement the information collected in a draft ASR which was originally developed by the USACE. She added that as information is gathered it is shared with the ASR team.

Ms. Daehn stated the second purpose is to present their findings using GIS based tools. These will help to guide future work and will be available to the public as an information source. She stated some of the activities they have been working on include addressing comments that were made on the draft ASR, primarily from EPA and some from MADEP. Ms. Daehn stated focusing on the comments and attaining some aerial photographs (as were addressed in some comments) will result in a more complete document.

Ms. Daehn stated some other ASR related tasks include conducting additional interviews. She said Tetra Tech has hired a Private Investigator who has contacted people who have some knowledge of the NGB to try to gain some more information. Ms. Daehn stated they also have hired a military historian who is researching some of the activities that have occurred on MMR to try to gain more information on that. Ms. Daehn stated Tetra Tech is researching defense contracts to try to obtain copies of contracts that were issued between the Department of Defense (DOD) and various contractors who did testing and other activities on the J Ranges. She added all of this data is being mapped using the GIS to compile all this information into a single source.

Ms. Daehn stated that research has been completed on all of the documents available in the Washington D.C. area and is ongoing. She said that the Private Investigator is presently interviewing people who may have info on MMR. He has completed 11 interviews and conducted some follow-up questions based on comments by EPA She said as he gathers information he shares it with the ASR project team so that the team remains informed. She added that he uses a detailed questionnaire that was developed by EPA. So far he has interviewed National Guard employees, people who were stationed at Camp Edwards, and some people who have worked for some of the contractors who have conducted testing. She said it is anticipated by the end of April 2001 that they will have a final report detailing the results of the interviews.

Ms. Daehn stated Mr. Dan Eddinger of Tetra Tech is the military historian for the project. He is researching what units trained at MMR between 1911 and 1998. He contacted by telephone potential archival sources of information to investigate whether those sources were worth while to physically go obtain those records. She said he reviewed "Request of Train" records at Camp Edwards which describe who was at Camp Edwards during what timeframe to conduct training. Ms. Daehn stated that in addition he reviewed information from military pay records, contacted state and archival sources, military history museums, Director of the MA National Guard and has a scheduled visit to a military history museum located at Camp Edwards. Ms. Daehn reiterated that this work is ongoing and it is anticipated by the end of April 2001 they will have a final report detailing the results of the research.

Ms. Daehn stated that the ASR team is researching contracts that were issued between the DOD and contractors who worked at the MMR J-Ranges. Ms. Daehn said there are several locations and agencies that had issued contracts, some were issued out of Piccatiny Arsenal in New Jersey which have been contacted and are going through a process of obtaining those records from them. Ms. Daehn stated once the contracts are obtained they will be provided to a contract attorney who will provide a legal interpretation of the legal information contained in the contracts.

Ms. Daehn stated that in addition they are researching corporate histories consolidacy, how companies have changed hands over time. She said that finally, they are reviewing CERCLA and RCRA information request responses for any information that might be pertinent. The information requests provide information about what activities were conducted which would lead up to what chemicals or contaminents may have been left behind. Ms. Daehn stated the ASR Team expects by June 15th, 2001 they will have a final report detailing the results of the contracts research.

Ms. Daehn stated that once all these processes are completed, the ASR Team will revise the entire ASR. The revised ASR document will incorporate all of these elements along with the integration of EPA's comments, by September 30, 2001.

Ms. Daehn introduced Mr. Rust who leads the GIS effort to discuss GIS mapping. Mr. Rust stated he is developing the Geographic Information System or "GIS" for the ASR. He said the GIS will combine data from the ASR with other sources and make it available to the public. It will consist of three parts. Mr. Rust explained the first part is an electronic copy of the ASR which can be searched using a key word, or using a geographic coordinate. Mr. Rust stated the second part is a web-based data archive and the third part is an Arc View project.

Mr. Rust demonstrated, by projection, what a person would see when the log on to the website. He explained the information is broken down into 5 libraries and the user can go into any of those libraries and download GIS data from that point. He stated the user can access a data-viewing tab where the user would go to get a viewing tool which is freely available and can be downloaded from the website. Mr. Rust demonstrated how the website is part of how they are integrating the information from the ASR with features shown on a map, info relevant to that area will pop up in the form of text or photos.

Ms. Daehn stated she wanted to reiterate this project is ongoing, and she is trying to share information continuously with the project team, and would like to come back in February to provide a three month update.

Mr. Hugus stated that one of the astounding things about the Impact Area Study is that so few personnel from the military and private contractors have been willing to step forward on their own to provide information about improper disposal activities. Mr. Hugus stated for that reason he is glad to have a Private Investigator who has an active approach to go out and ask questions. He asked if the Private investigation has any legal power behind it. Mr. Hugus asked if the Private Investigator has the right to subpoena somebody.

Mr. Martin Blake introduced himself as the Private Investigator for the project. Mr. Blake stated the courts issue subpoenas, Mr. Blake does not. He stated all the information he gets is voluntary.

Mr. Hugus asked if he has any evidence of records that may be missing or destroyed for no particular reason. Ms. Daehn stated there are policies that have actually required destruction of some records. They are finding that with some of the contracts records research that various contracts had policies where they were required to be destroyed after a fifteen year period. The ASR Team is trying to find records that may not have been destroyed, but it is a difficult process.

Mr. Hugus referred to the finding of buried munitions at the J Range area. He stated he believes somebody buried those munitions, it was not that long ago, the military was involved with the contractor at the J Ranges, either the military or the contractor did the burial of thousands of mortar rounds but nobody knows who did it. He asked if Ms. Daehn or Tetra Tech have found out who is responsible for this burial of munitions. Ms Daehn said the ASR Team is trying to gather that information through Marty's interviews it seems there are some people who are aware of those burials and they are trying to get that information.

Ms. Adams stated that, as indicated, Mr. Blake has conducted 11 interviews. She does now how many of those 11 may or may not relate to those burial, but there is some concern about verifying information before it is released. The EPA has been involved in reviewing information as it is coming in. EPA has asked the NGB to hold off on disclosing it until the EPA gets to the verification of a lot of the details. Then EPA plans to make that all available to the public. Ms. Adams added that EPA also needs to address the issue of respondents who have asked not to be identified. The goal is to have all the information revealed to EPA be made available to the citizens. However, there are some delicate issues making sure that people actually feel comfortable in speaking to EPA that EPA is trying to work through. Hoping to make progress in the next coming months.

Mr. Zanis questioned the accuracy of the information. He stated that if it is found that the GIS system is inaccurate and can prove otherwise is there a form for changing that, in updating the information to keep it accurate. Mr. Rust stated he does not know the answer to that question, this website is not going to be delivered until after the ASR is completed, and the accuracy of all of the information is going to be documented to the extent that it can be.

Ms. Adams stated she had a similar question on how to account for public feedback on the GIS system generally. There may be information where people may have additional information or contrary information to and there should be a mechanism to address that. Ms. Adams stated with respect to the usability of the system, she assumes there is a mechanism where people can say "This function doesn't really work right, can you adjust it?"

LTC Knott that is exactly what we'll have on the February update at the IART will go ahead and explained how that system works, what it is, including updates or new data that come in that may prove the original data incorrect, locations, whatever. We will have that close loop return comment how we respond how we direct information and we will present that information at the IART in February. It will also be discussed with the EPA and DEP at the Tech Meeting.

Mr. Zanis stated that a lot of this data presented will be official National Guard Data. Mr. Zanis stated his concern is the writing of the information on the internet. He expressed that he hopes the ASR is worded so that the public have a full and real sense of what was going on at these sites.

Mr. Borci stated that is why the original ASR was so fully revised because there were so many comments on it. That incorporated everything the group has said, especially Mr. Zanis, about different ranges,& activities that occurred. Mr. Borci said he believes this is meant to be a "Living Document" as we continue the investigation this is going to continue to be updated. Changes and comments will always be welcome. Mr. Borci said it will be as user-friendly as possible and from what he has seen se far he thinks it is going to be a great product.

Ms. Daehn stated that the great thing about mapping all of the data in GIS is that you can see where there is correlation because inherent in this process there are flaws, but you can see if there is correlation if different things. Where if you found the same information in different sources and they overlay, when you map the data you have a much higher confidence that that data is accurate. She added that the GIS element greatly enhances the data that is being collected.

Mr. Zanis asked if we all need to buy new computers to download the information. LTC Knott stated there are computers provided in the libraries.

Agenda Item #4 Munitions Update

Dr. Montroy stated that this update will be similar to last month. He said what has been done so far is chopping down trees and removing surface UXO. There is not a lot of new information; however, they are moving forward

Dr. Montroy stated that the process of the Munitions survey is to detect potential burial pits or burial sites, locations where munitions may have been inappropriately buried. He stated this is being done via a comprehensive set of steps using subsurface geophysics. The next phase is to physically go in and validate whether the anomalies they find are buried munitions.

Dr. Montroy displayed a slide projection of the J-Ranges, Greenway road, the high use target area (HUTA) and the Impact Area. He stated that in the J-1 Range, which looks like a long strip, has been cleared and ready to start subsurface geophysics survey. In the J-2 Range they have kept the mature trees, however most of the scrub and debris has been removed for the geophysical survey.

Dr. Montroy displayed some aerial view photos of the J-3 Range from May. He stated it is physically different than J-1 and J-2 because it was most recently an actively used research base. He pointed out structures that have not been seen in J-1 and J-2. Dr. Montroy stated that the Munitions survey is looking at discrete sites within and not the entire J-3 Range.

Dr. Montroy stated 55 acres was cut with the brontosaurus in the J-1 Range and cleared UXO, however, there is still some brush to be cleared by hand because of slopes on the surface. He said that about 30 acres is almost cleared. He said they have started J-3 recently, and have cleared about 15 acres. Dr. Montroy stated the subsurface Geophysics will begin in January.

Mr. Zanis asked to clarify what they are doing when they say they are clearing debris. Dr. Montroy stated they are removing vegetation and surface debris that can readily see is not ordnance related. Mr. Zanis asked if the cleanup has started and Dr. Montroy said yes.


Dr. Montroy stated the purpose is to characterize how UXO, UXO related material (UXORM), might be distributed in an impact area where ordnance is coming down in a ballistic trajectory. Dr. Montroy clarified that they are trying to understand how it might be distributed, how far it might go, how far down it goes, how far it explodes out - just to get an idea how the UXO acts in an impact area.

Dr. Montroy stated an area was picked that was upgradient from MW1, they are working in six 10,000 square foot test plots and just like an archaeological dig, they are taking 3 feet at a time, sifting and sorting, and characterizing it.

Dr. Montroy showed a slide that he said he thought was a good illustration of subsurface geophysics that he talks about. He said all the colors red and pink show items below the surface because all the surface items were already removed. He said this was done by brush cutting and surface clearance. He added they are going from fairly low density areas to increasing density areas.

Dr. Montroy said test plot (TP)1 excavation is complete. Three 1 meter lifts were excavated down to about 9 feet. He said that the protocol states if the surveys do not find anything in the last lift - another geophysical survey is done down to 3 feet. Dr. Montroy said if they still do not find anything at that point, they stop the digging. Dr. Montroy said extensive sampling is being conducted in the soil for residual explosives under UXO and UXORM.

Dr. Montroy stated that same work has begun in TP 2. He said they stacked up where they have found stuff and he displayed the red shows UXO, green shows UXORM and blue shows debris. The colors on the slide were scattered and Dr. Montroy stated that displays the "waviness" of the top of the surface, the craters and so forth.

Dr. Montroy reported that he expected to find materials down to 6-10 feet but did not in TP2. He said most materials are clustered in on the top of this particular test plot and there was not much material found below1 meter from the surface.

Dr. Montroy reiterated that the goal of the Munitions survey is to get a picture of how UXO behaves or disperses itself when it detonates. He stated that in the next TP excavation the UXO distribution pattern will be different. He added that may be because of the distance from the target, or lots of other different reasons.

Mr. Zanis asked if there was any research done on the trajectory angles of the ordnance that was fired into the impact area before this had begun. Dr. Montroy stated that research process is being done now as part of the ASR research. Dr. Montroy added that the Munitions Survey is part of the ASR report that was presented to the IART earlier.

Dr. Montroy stated they are going to try to identify gun point (GP) positions. Mr. Zanis stated a lot of the artillery gun positions fired at such a low angle and such as low charge that it wouldn't even penetrate the ground. Mr. Zanis said they would bounce off- porpoise and skid to a stop and a track 20-30 feet long would remain visible.

Dr. Montroy stated that on the contrary, there were artillery that were fired from GP 14 & 16 which used a large charge, that might have a higher trajectory and might be found. He said it is unknown which ones they are, however, those deeper and in a different test plot might be found more easily. Dr. Montroy reiterated that it is unknown and is the purpose of the Munitions Survey. Dr. Montroy stated that next month will consist of the continuing with TP 2, including brush cutting and surface clearance and at the J-1 Ranges geophysics will commence.

Mr. Hugus stated that he is trying to get an idea of the big picture as far as UXO clearance and the impact area. He asked if while concentrating on the HUTA and J Ranges, if there is any other area that UXO survey is being done.

Dr. Montroy stated they picked the HUTA as a good "Worst Case" scenario. It is not representative of 2200 acres in the Impact Area. The Air Mag survey is being completed and explosive ordnance personnel will go out into the field to find the things the Air Mag showed with the idea that we might be able to estimate the "Footprint" the surface area of the impact area that is more like the HUTA than unlike the HUTA. Dr. Montroy stated that yes, it is the long term aim, and these areas are high density areas, others are low density areas. Dr. Montroy reiterated that it is unknown and is the purpose of the Munitions Survey.

Mr. Hugus confirmed that Dr. Montroy was discussing the 2200 acres in the impact area and the J-Ranges. Dr. Montroy stated yes, the impact part of the Ranges. Mr. Hugus stated that since Dr. Montroy gives an update every month, is it possible that next month to provide an overall map of the areas that have been investigated and that you are investigating so the IART can get general ideas of the overall project.

Mr. Borci stated that all this information is a UXO feasibility study under the administrative order when it comes to what areas will be investigated, it will be the entire impact area and training ranges. It is just a matter of determining what to go out to look at based on the air mag and ground data. He added that surface clearance is not only done by Tetra Tech, Ogden also does surface clearance when installing wells.

Mr. Borci stated that in the impact area any surface UXO was cleared out of the slit-trench. The HUTA was cleared and Ogden has looked at least 20+ targets in the central and north central impact area. He noted if you add up all that area, it represents a large area that has been at least cleared of surface UXO to this point.

Mr. Hugus asked what was found in the slit-trench. Dr. Montroy stated what was found was primarily trash. He said there were car axles, parts of automobile bodies, scrap iron, stoves, empty cans of oil & anti freeze. Also found were some ends of 105mm cartridges that had been sawed off, so what remained was the flat end of the primer point of the 105mm cartridges. He added that there were no UXO found.

Mr. Hugus asked if there was any evidence of whether the empty cans of anti-freeze and oil were empty before they were thrown in or not. Dr. Montroy stated his guess is that they were empty because it was all trash and they were opened at the top.

Mr. Zanis asked if the HUTA is upgradient of MW-1. Mr. Borci stated the HUTA is north of MW-1. He added that the HUTA was placed on a number of things, old aerial photos, current groundwater information, all wells on Turpentine Road had hits but some had relatively high hits compared to the others, and that was part of the genesis of where to place the HUTA.

Agenda Item #5. Investigations Update

Mr. Grant stated Ogden Environmental has sold their environmental group to a company called AMEC Earth and Environmental, which will be referred to as "AMEC." He added there is no change in term of the players doing the job, still the same group with a different company name.

Mr. Grant stated the IART should refer to the maps at the back of the handout which are the ones he will be displaying by projection that are smaller and hard to see. He stated the hand out includes maps of all detections of all analyte groups which are at the table for the IART, but they are not publicly available.

Mr. Grant stated since October 19 they have installed wells downgradient of the impact area. Mr. Grant displayed a map showing the south end of the western impact area, MW-15, MW134 & MW138. They have installed MW-135 downgradient of the CS-19 area, and installed MW 133 downgradient of previous detections at MW-50.

Mr. Grant stated that in the J-Ranges five wells have been installed. The locations include MW-130, 137 on J-2, MW-131 and MW-136 on J-1 Range and MW-132 on J-3 Range. Mr. Grant stated the MW's installed at Demo Area 1, which is the last of the current Rapid Response wells MW-139 at western downgradient extent of the RDX plume.

Mr. Grant stated that currently drilling is being done in the J-Ranges, L-Ranges, impact area and starting at phase 2b locations. Mr. Grant displayed a map of the J-1-3-L work plan to show the original plan for the J-Ranges. He said all the wells in red have been installed which are called stage 1 wells. Mr. Grant stated they are in the process of contouring the water table information from those wells to fine tune where the orange colored wells are going to be installed. He said the Orange wells are stage 2 wells and there about 20 of them.

Mr. Grant stated that in the impact area response well P-31 anticipated to be completed within a month. Well P-30 is on hold for a short time because it is in an exclusion zone for UXO from HUTA operations. Mr. Grant added that not all Phase 2b well locations are displayed on the map, during the weekly progress reports the well locations will be added. He said the wells presented are the gravity anti-tank Range well, and proposed locations at Demo Area 2, GS-8 north of the center transect RDX response wells, BA-1, former Demo sites, and others they need to add including the former ASP well.

Dr. Feigenbaum asked to discuss the proposed well fence inset B, he stated he would like to know why are they are all so close together. Mr. Grant stated that the theory behind the indicated series of wells is to try to set up a very closely-spaced monitoring well network downgradient of the J-3 Range. He stated some wells are actually positioned on a supposed particle track from a location in the J-3 Range. Mr. Grant said he thinks there is probably a fair amount of variability in the groundwater flow directions under the J-3 Range because it is so close to the top of the water table mound. He said that setting up a lot of wells in that area AMEC is hoping to capture anything that may be coming out of the J-3 Range.

Dr. Feigenbaum asked if they will be testing for all contaminents. Mr. Grant stated yes, they will complete a profile for explosives and volatiles, then the wells themselves will be analyzed, as well as radiological analysis and perchlorate. Dr. Feigenbaum asked to what depth. Mr. Grant stated they are fairly deep wells to about 250 feet below water table, and some shallow wells also.

Mr. Hugus asked that regarding the issue of not being able to define groundwater flow direction because it is at the top of the aquifer, would that mean the wells should go 360 degrees around the J-Ranges rather than just focus on the small southern section. Mr. Grant stated that is true if you had a source right at the top of the water table mound. Basically that water could flow in any direction from that point. Mr. Grant added they need to get a draft map for the agencies to look at; however, it looks like the top of the mound is more off to the side of the J-3 Range which tells them the groundwater will be going in the southerly direction.

Ms. Adams stated that given that uncertainty, EPA has instructed the Guard to install wells in a circular fashion approximately 1,000 feet apart. She added that there are wells that are going to be ringing all the ranges, not just those few clusters along Greenway road.

Mr. Grant displayed a projected slide of the status of groundwater sampling for the present month. He said there was not much change from last month, however, they have started the December long term monitoring rounds. All the older wells that have been sampled five times will now be sampled six times in next months update.

Mr. Grant stated that there have not been a lot of detections in the sampling results and no new explosive detects in the impact area. MW-118 and MW-123, MW-124 wells are confirming the profile results which suggests that there are not any explosives at those locations. J-2 Range wells MW-117, MW-119, MW-120, MW-121, MW-122 so far are non-detect for explosives. Mr. Grant stated that there are three J-1 Range wells installed and he is awaiting the results from those locations.

Mr. Grant stated that on the J-3 Range profile detects were found at the Demo pit. MW-132, which is installed at this location came up non-detect for explosives, is a short distance away from the profile detects. Mr. Grant stated there was a monitoring well positioned downgradient, installed a couple of soil borings right through the center of the demolition pit, then collected a profile sample at the bottom of the soil boring. Mr. Grant said that it appears that they need to come up with a better monitoring program to gauge what the water table is.

Mr. Hugus stated he was not aware that there is a Demo pit at the J-3 Range. Mr. Grant stated the Demo pit is a 10 to 20 feet squared area in the vicinity of some concrete targets. The concrete targets were set up with a demolition pit behind them but not deep, only 3-4 feet down. Mr. Hugus asked what was detonated there. Mr. Grant stated he does not recall off-hand. Mr. Hugus stated he would like to find out more about this for the next meeting.

Ms. Adams stated it is discussed in the Textron Information Response. She said EPA can provide it to the citizens if they want. Mr. Grant stated there is also a paragraph on it in the J-3 Range work plan. Mr. Hugus stated he will look it up. Mr. Grant stated that the detections were about 8ppb at the Demo pit.
Dr. Feigenbaum asked Mr. Grant to explain again the detects in Demo pit at the J-3 Range, and Mr. Grant did.

Mr. Zanis asked if Mr. Grant could use the presented data as research to find out how much RDX in soil leaches into groundwater and causes how much contamination in the groundwater. Mr. Grant said yes, this is a situation where there is a good connection between the soil and groundwater data, and it can be used to calibrate unsaturated zone model, which estimates what the soil contribution is to groundwater. Mr. Grant stated the future intent is to develop a model which would have to agree with this specific site in order for it to be an effective model. He added that this is part of the current plan for modeling.

Mr. Grant stated the latest soil data is mainly for the J-2 Range, sampling has been completed about 75 percent of the results are back. He said mainly it looks like propellants, there was 2,4 DNT detected. Mr. Zanis asked if Mr. Grant was discussing firing points that have not been used in years. Mr. Grant stated that is correct. Mr. Zanis stated they have not been used in years and they are still contaminated. Mr. Grant confirmed.

Mr. Hugus asked if that came from bag burning or something else. Mr. Grant stated he does not know for sure. Ms. Adams stated that from the interviews it was suggested they burnt propellants at that position where firing points three and four are and extending about 200 feet up the road.

Mr. Grant stated there was also a propellant detect at disposal area 2 which is close to the impact area. Mr. Grant stated there was HMX detected at berm 3 and TNT and RDX detected at the melt pour building. The detects were all about 100 - 300 ppb. He added there were also elevated levels of metals detected for copper, lead, beryllium and zinc at disposal area 1 and 2 at the J-2 Range.

Mr. Grant stated that AMEC is working on an analytical method for halo waxes. These compounds are polychlorinated naphthalene's. They show up two ways, one as an interference peak in the pesticide analysis and another as a tentatively identified compound in the semi-volatile analysis. Mr. Grant stated they are in the process of figuring out what toxicity levels they present, and then coming up with an analytical method that will measure or quantify these levels.

Dr. Feigenbaum asked how they arise. Mr. Grant stated they are present as constituents of waxes, however, he is not sure if those are waxes from inert or high explosives (HE) rounds. Mr. Zanis stated it is news that these TICs (Tentatively Identified Compounds) are being identified. Mr. Grant stated from the TIC analysis on the semi-volatile method they can get a general sense but can't say whether it is a particular one.

Mr. Borci stated that in order to be accurate, the only reason EPA went back and reviewed the semivolatile organic compound (SVOC) for the TICs was because they had some interference with the pesticides and the analytes identified these as not a pesticide, therefore they identified it as a halo wax.

Dr. Feigenbaum asked if there is evidence that these waxes were used in the manufacture of the ordnance or simulation devices. Mr. Grant stated he thinks they were present as an ingredient. Dr. Feigenbaum, stated if the analysis is showing it and that is what the manufacturer said it was in there then there should be a pretty good idea that that is what it was. Mr. Grant stated the problem is at this point is that it has been around for a very long time and has weathered and it is difficult to compare the weathered sample to a pure sample of halo wax.

Mr. Borci stated that looking at other sites EPA has dealt with in the region where these compounds have been found, they are physically treated in the same fashion as polychlorinated biphenyl (PCB)'s.

Mr. Grant stated the final comment on the J Range soil sampling is that they are about 40 percent complete with J-1, J-3 and L Ranges. He added that the J-2 Range data is about complete.

Mr. Zanis asked if the orange stuff he showed Mr. Grant a long time ago was a halo wax. Mr. Grant stated it was not. Mr. Borci stated the Guard has sampled two different waxes that have been seen in the J Ranges, and EPA is awaiting the results.

Mr. Hugus asked why Mr. Grant thinks they found such high levels of explosives near the melt pour building. Mr. Grant stated he does not have that information. Ms. Dolan stated she believes the explosives were detected in discrete samples which were collected just off the concrete pad where the melt pour skeleton exists now, however, the means by which the explosives got there is unknown. She stated she believes it is interesting that there were no explosives detected in the groundwater at that location.

Background Soil Concentrations Methodology
Mr. Grant stated to summarize a point made during discussion of background in the MCP presentation, he said it is necessary to know what soil background is because that is one of the remediation goals; to try to cleanup to background to the extent feasible. Mr. Grant stated he believes most people are familiar with the attempt in phase 1 to establish soil background levels. He said there were a number of criticisms levied at that attempt. Mr. Grant said that using the criticism, they have come up with a 4 step method that has been described in tech meetings and with the TOSC.

Mr. Grant stated the four step process takes a look at all the soil data for the entire study. It is not limited to background locations, off-site, etc… it looks at every single soil sample they take. The goal is to figure out which analytes are possible candidates for background, and can background concentrations be generated based on looking at how existing data falls with respect to spatial patterns. He stated it is a very complicated process.

Mr. Grant said the first step is completed, where they tried to determine which compounds they can make the evaluation for. There were 217 total analytes that were looked for. In Step 1 it was said that 99 of those were potential candidates for background. For example, some were totally inappropriate such as explosive compounds where there would not be a background number. Or compounds that were detected at such a low frequency that there is no statistical way to generate a background concentration for it. Mr. Grant said that step 1 was a narrowing down of the possibilities that they can calculate as a background.

Mr. Grant stated that some of the numbers that got removed from step1, now have a background essentially of detection limits. He added that you can't calculate a background for them so at present background right now is detection limits for those. Mr. Grant stated that out of several thousand soil samples, there was an additional screening for low detection frequencies, which then screened out another 36 analytes He said they are now down to 63 analytes that they are going to try to calculate numbers for.

Mr. Grant stated that the compounds retained from step 1 were taken to step 2 which is a series of statistical analyses. Out of those 63 remaining compounds the 29 were metals, 23 were semi-volatile organic compounds, 6 pesticides and 5 herbicides included in the total list of 63. He stated they are starting step 2 where a statistical evaluation is done to try to look at different groupings of data, if those 63 analytes are spatially distributed in any particular way. If so, it would suggest they are present because of a release and background can't be calculated using this data.

Mr. Zanis stated it sounds like a lot of the pesticides and herbicides are being eliminated. Mr. Grant stated that for the most part they are using detection limits for background for those. In other words, there is no anthropogenic background, no background caused by natural processes or manmade processes outside of MMR. However, five or six exceptions may have a real background concentration that can be measured above detection limits such as DDT and DDE.

Update on Demo 1
Mr. Grant stated that they are installing wells sequentially starting on the southern side and continuing on the western end of the Demo 1 downgradient plume. The last well MW-139 was thought to be representative of the western limit of the RDX plume, and there are no well results from that location yet, but the profile results are 0.3 and 1.5 ppb RDX so they are not above the health advisory. Mr. Grant stated that based on this series of wells the western edge of the RDX plume is about 3500 feet from Demo 1.

Mr. Grant noted an interesting thing is that the plume appears to be heading further south than what they had originally projected. He said that in the vicinity of Opening pond further downgradient the plume id bending further south. Mr. Grant stated it is not clear if it is an influence from Opening Pond or something else, but is moving about 200 feet south of the regional particle track.

Mr. Zanis asked if any additional wells are going to be installed. Mr. Grant stated that at this point they have to re-draw the plume and have the agencies approve them. He said by doing that they can identify data gaps. What is clear is that they have not reached the western extent yet.

Mr. Borci stated that there are a couple of things EPA is looking at. One thing is to look at monitoring history to check for pulsing, also during wet season and dry season contaminents can get flushed through the groundwater. He added that particle tracking is the best scientific guess. Mr. Borci's third point was that the issue of additional monitoring wells leads into another issue that Mr. Grant will discuss.

Mr. Grant stated that there is a new contaminant that was detected, perchlorate. He stated perchlorate is contained in a variety of different things such as fireworks, fuzes, possibly some munitions. Mr. Grant stated this material was looked for at a variety of places and the only place it has been found so far is at Demo 1. He stated that the only number to compare detections to is a California State promulgated health advisory number which is about 15ppb. Mr. Grant said MMR has detected levels 40 to 100 ppb in 4 wells in Demo 1.

Mr. Grant stated the next step will be to sample all the wells in Demo 1 to see where the perchlorate is. Mr. Zanis asked why the IART has not heard of this chemical before. Mr. Borci stated that they had a lot of rocket plants where they made rocket engines and did rocket compulsion testing. They started testing their water and started finding it everywhere. Mr. Grant stated that the evidence that it is sort of a new concern is that there is not a federal level for it. So far California is the only one that -

Mr. Zanis asked if the KD Range would be a place of concern where they fired a lot of rockets. Mr. Borci stated what they are in the process of going back to look at where they have already sampled for perchlorate and then take a look at potential point sources to see if there are additional wells. He added that regarding a national standard for perchlorate, the current guidance from EPA Nationally is they are probably are going to promulgate a 32ppb health advisory. In the meantime we are going to use the California number.

Dr. Feigenbaum asked what exactly is perchlorate, and suggested it is a radical. Mr. Grant stated yes, it is a chlorine with four oxygen's attached to it. Dr. Feigenbaum asked what it is attached to where is it arising from. Mr. Grant stated potassium perchlorate is the ingredient that is used and perchlorate is what ends up in the water. Mr. Borci stated that it is used as a component in the munitions, typically in the propellant. It boosts the energy of the propelling charge.

Mr. Hugus stated he asked for perchlorate testing at the J Range area also. Mr. Grant stated that is underway. Mr. Hugus asked if any perchlorate was detected. Mr. Grant stated that results are not back from that area yet. The J-2 Range wells have been submitted for perchlorate, and the J-1 and J-3 wells have as well. It is usually a four week turn around for perchlorate analysis. Mr. Grant added they will probably be getting more results for perchlorate back in the next month.

Mr. Hugus asked that in all the testing that has been done on the study, perchlorate was not on the analytes list. Mr. Grant stated not until August. Mr. Hugus asked if it is going to be added routinely. Mr. Grant stated that the results at Demo 1 pointed out the need to add it for any additional Demo 1 wells installed. The analytes had been added for the J-1, J-3 and L Range wells. Mr. Hugus asked why it was added to the Demo 1. Mr. Grant stated it is being added to Demo 1 because of the four detections. Mr. Grant explained that in August they selected a range of wells covering the entire base in areas where explosives, RDX and HMX, were detected thinking that perchlorate may also be present.

Status of the Small Arms Range Study
Mr. Grant stated the Small Arms Range Study included three ranges for soil sampling and one range for air monitoring. The air monitoring was conducted at the Sierra East or SE Range at the September 23 firing event where squad assault weapons were used. Mr. Grant said that the not validated results for soil and air are now available however, there is not a handout because it is still not validated data.

Mr. Grant provided a summary of results for soil. There was an initial Guard proposal to follow standard impact area type sampling grid which is a five point grid. He stated that was modified by the IART to include additional sampling notes along the line of fire and slightly set off by a couple of feet to the side. He said they sampled both the tri point grid and nine discrete points

Mr. Grant stated that they found some detections in soil propellants. Four compounds detected ethyl centralite, 2,4 DNT , di-n-butylphthalate, and N-nitrosodiphenlamine which is a combustion product. These concentrations did not exceed the reportable concentrations. There were three other semi volatile compounds detected, none above reportable concentrations. For metals they had detections of 12 analytes above background. Copper, manganese, and nickel had average levels above background.

In the air samples they had five metals where downwind concentration was greater than the upwind concentration: antimony, barium, copper, lead, and zinc. Mr. Grant stated at this point they are trying to draw a connection between soil and air data. He pointed out that copper is in both air and soil samples. He stated that he is waiting for results from the Gulf and India Ranges and those results are expected soon. Mr. Grant stated that a report will be prepared describing all the results and what we think the potential impacts are for groundwater due to the small arms range firing activity.

Mr. Hugus asked what compounds were above reportable concentrations that were the most significant. Mr. Grant stated there were not any in this case that were above reportable concentrations.

Mr. Hugus stated that there was some discussion a couple of months ago on how the collecting would be done on the soil. Mr. Hugus questioned the method that they used to collect the data. He asked if it reflects just that days firing or a long-term use of that range. Mr. Grant stated that the decision was made to sample after firing because that is what the IART requested. He added that he believes these types of compounds are probably going to be present for a period long time, and is not a result of this particular firing activity but is the result of what has built up over several years. He added that once the results are back from Gulf and India ranges, they may have a better sense of whether it was long term impact or not.

Mr. Hugus asked is Mr. Grant is ready to comment on the concentrations air detects. Mr. Grant stated that the detect followed a pattern of air release. It is difficult to determine if that was detected from the release of air release from the gun itself versus a release from the ground surface which may have had soil containing these metals.

Mr. Hugus asked if any concentrations were above RCs. Mr. Grant stated there is no RC for air, so there is not a good criteria. Mr. Hugus asked how we know what is good or bad. Mr. Borci stated that there are Occupational Safety and Health Administration (OSHA) and NAIA regulatory agencies have permissible exposure levels and there are concentrations that can be compared to. Mr. Hugus asked if this report will be available soon. Mr. Grant stated that the air validation is underway right now and should be completed fairly soon. He added that he is not sure about the soil results from the last two ranges, but certainly by the next IART meeting.

Mr. Hugus asked if the IART will get a report in the mail. Mr. Borci stated yes, if there is time, it is his preference to get the report to the team before the next IART; however the lab is very busy right now with soil sampling and has been a little slow in getting information back.

Dr. Feigenbaum stated he believes it would be prudent to do air monitoring when there is no firing to resolve that question. Mr. Grant stated in order to do a controlled study the same actions would have to be duplicated in terms of the people firing laying down or kneeling. There are many factors that would need to be simulated.

Dr, Feigenbaum asked whether Mr. Grant was saying that the exhaust from the gun kicked up the soil. Mr. Grant stated what he said was that is another possible contributor to the downwind. Dr. Feigenbaum stated that if we looked on a similar day to see what is there it may help. Mr. Borci stated that is you assume the worst case, that the firing did produce these contaminents, then work from that. Dr. Feigenbaum stated that as long as people are casting doubt on that then it needs to be resolved.

Mr. Borci stated that it is too early to say anything right now, until there is a comparison to air regulatory numbers and the data from G and I ranges come back, then sit down with the Guard and see what their take is on it. He added that when you see stuff in the air so if you assume worst case you assume there is something being put out at each event then you look at soil data is elevated above background but the question remains is that a leeching threat to groundwater.

Mr. Zanis asked what the five metals were in air. Mr. Grant stated antimony, barium, copper lead and zinc. He added that the three in soil that had averages above elevated background were copper, manganese and nickel. Dr. Feigenbaum stated they are different. Mr. Grant said that copper was the common thread. Dr. Feigenbaum stated that it doesn't support the theory that it was kicked up from the soil. Mr. Grant stated it is also difficult to say that the air is contributing to the soil, because antimony is being seen in air, not soil. Mr. Borci stated this is why he wants to wait until the next meeting, because it is too early to tell.

Dr. Feigenbaum asked what the four propellants were. Mr. Grant stated they were ethyl centralite, 2,4 DNT, di-n-butylphalate and N-nitrosodiphenlamine. Dr. Feigenbaum asked if these were what they expected to find. Mr. Grant stated that is correct. Dr. Feigenbaum asked what were the SVOC's. Mr. Grant stated the three SVOC's were bis-2-ethylhexylphthalate, benzoic acid and 2 nitro diphenylalanyne.

Dr. Feigenbaum asked who's reportable concentrations are we talking about. Mr. Grant stated the MADEP number. Dr. Feigenbaum stated that number is problematic to begin with. Mr. Grant stated that MADEP has a real risk-based number for 2,4 DNT. Dr. Feigenbaum asked if Mr. Grant would tell what the concentrations are. Mr. Grant stated he prefers not to give out the concentrations because they are not validated, but they are a factor of ten lower than the RCS 1 for 2,4 DNT, and the RCS 1 is 700 ppb. Mr. Borci confirmed the RCS 1 is the cleanup standard.

Mr. Borci stated that to be clear on the MADEP presentation, when Marc presents the data the important fact is that for propellants it is non-detect. The fact that it was detected is the relevant part. Dr. Feigenbaum asked what other results have been seen at MMR for 2,4 DNT. Mr. Borci stated they have seen up to 10,000ppb and IRP on CS-18 had a maximum of 17,000ppb.

Mr. Zanis stated there were two soil sampling plans, the IART members plan and then the Guards. Mr. Zanis stated he would like to review and update the IART plan. He added he believes it was not right and he was too busy at the time to put his two sense in. He asked to review it amongst the citizens before there is any more soil sampling. Mr. Borci stated that for now this is what was scheduled and the data will be provided at the next IART.

Mr. Grant stated that when the results are presented, they will compare the different grids results. Mr. Grant stated this concludes what was prepared and it is up to the IART if they want to discuss the handout on the Northwest Corner of MMR.

Mr. Hugus asked that on the small arms range sampling, he wants to underscore the fact that MADEP's credibility when it comes to RCs, Mr. Hugus believes, is not high. He added that Mr. Borci's comment on what compounds were found above background is what should be concentrated on.

Mr. Pinaud stated there still seems to be some confusion about the RCs 1. The reason it is there is because MADEP wants to make sure that AMEC is flagging contaminents that could be reportable to MADEP. He added it is not a clean up standard, and can't be used as a cleanup standard. Mr. Pinaud added that the SDWA does not have cleanup standards for soil either, so they have to use the MCP methodology to actually determine what the cleanup standards are, or their methodology from CERCLA. Mr. Pinaud stated he believes Mr. Hugus made an unfair criticism of the MCP.

Mr. Hugus stated that the way he understands it, all the stuff found at this range does not have to be reported to MADEP so this is of no concern to Mr. Pinaud. Mr. Pinaud stated that is not true at all, it is a flag for whether we need to follow it administratively through the MCP. He added that Mr. Locke discussed earlier that AMEC for the Guard still have to determine if there is a risk, and if there is a risk then they need to do something about it; however, they just don't have to go through the formal MCP process.

Mr. Hugus asked if it makes sense that if something is below the RC they don't need to report it. Mr. Pinaud stated it is an administrative piece, MADEP is at the table and get the information, and don't forget about it because it is less than a RC. Mr. Hugus asked if the Guard is obliged to report these things to MADEP even if they are not reportable. Mr. Pinaud stated they get it as part of the information package just as everyone else gets the information. MADEP does not "pretend" that it does not exist just because it is below a reporting concentration. RC only means to MADEP that they need to take action and also the Guard needs to take action to be in compliance with the MCP. It really is an administrative piece that MADEP needs to flag. Mr. Pinaud stated if MADEP does not do that then their not in compliance with the MCP, and then MADEP would have to take enforcement action against them and MADEP wants to make sure they stay in compliance with the MCP. He added that they probably shouldn't even put it on the table because it is flagging an administrative thing that the DEP and the Guard need to comply with.

Mr. Hugus stated that he does not believe there is a good idea of what concentrations of these chemicals are safe in terms of human health. He said that as Mr. Locke said there are thousands of chemicals in the environment that haven't been defined in any way, and Mr. Hugus believes MMR is dealing with some of those, and shouldn't dismiss chemicals that have been found on the basis of what regulatory agencies have arrived at through theoretical means.

Mr. Gregson stated most of the compounds detected at MMR and certainly a good number of the metals also have Method 1 cleanup standards under the MCP which are the risk based standards and were below those standards in every case where they exist.

Mr. Hugus said he does not believe Mr. Gregson. LTC Knott said Mr. Gregson is lying to him. Mr. Gregson agreed with LTC Knott, and stated he is lying and wants to clarify. He said the metals have standards, the 2,4 DNT has a cleanup standard, the other propellants and some of the SVOC's do not.

Dr. Feigenbaum stated that first of all he does not want to criticize his friends from MADEP, but it is a confusing nomenclature and believes that it needs to be worked on and is not helpful. He stated that the discussion is not only about the concentrations of these contaminents, but also over the area which it occurs. He added that this is a "toxic cocktail" in terms of soil and air in terms or a dozen or so problematic chemicals.

Mr. Murphy stated that he would like to go on with the SERDP presentation because there are a number of people from out of town here. Mr. Borci stated he believes the best thing to do is to have everyone review the handout on the Northwest corner for the next meeting and it can be discussed then.

Agenda Item #6. Other Issues

LTC Knott stated he wants to give the group a good idea of the benefits the 8 million dollars that Senator Kennedy added on to the defense bill for this year. SERDP which is a duty agency has that money, plans to put an announcement to the Cape next week that these 8 Million dollars will be constructing 2 sites within the Unites States to test UXO detection technologies. One of the sites that have been picked for those 2 is MMR.

LTC Knott stated that his understanding is that the Environmental Tech center will play a major role in this process. The major point is that MMR will be one of the two places in the country to test use of detection technologies, make them better, to help with the groundwater study, munitions survey, and ultimately, the United States Department of Defense.

Mr. Hugus asked if that was eight billion or eight million. LTC Knott said eight million.

Upper Cape Water Supply Project
Mr. Gonser stated he will give a quick rundown on the water supply project. He said from previous briefings on the project that the goal is to develop a water supply system that will provide approximately 3 million gallons to the base and the surrounding communities of drinking water. The target for completion of the project is July 2001.

Mr. Gonser stated he would like to discuss those aspects of the project that may be related to the Impact Area Groundwater Study and thus of interest to the IART in particular; well locations, what has been found to date in the sampling done that has been shared with the regulators, what the Zones of Contribution (ZOC)'s are and what the schedule of activities is.

Mr. Gonser said there are five well locations that are included on the Ogden Maps. Currently they are concentrating on three wells in the Northeast corner of the installation, MMR, to get the 3 million gallons.

Mr. Gonser stated a number of sampling events have been completed. When exploratory wells were drilled water samples were taken and tested for all the SDWA COC's as well as radon and explosives. The results all came back under the SDWA standards. He said the results were provided to the guard and the regulators.

Mr. Gonser stated that pumping tests were then carried out in the timeframe of June-July-August. The wells were pumped for 5 days as a pretty good rate, at least one half million gallons a day. He said samples were taken at three points during the pumping. The samples were taken in the beginning, near the end and at the midpoint of the pumping tests. Mr. Gonser stated that all the tests results also came back under the SDWA and were shared with the regulators and the Guard. Mr. Gonser indicated that they did find very low levels of chloroform that was found in wells installed by the IAGWSP. He said this information is available to the public and is all the sampling they have done to date.

Mr. Gonser said that part of the project includes the construction of additional chemical monitoring wells. He said they will be relying heavily on many of the far field wells that were installed under the 3MGD program. Some wells are not located properly for the 3MGD purposes, thus additional wells will be put in the ZOC. He also said two or three chemical monitoring wells will be installed near Well Site 1.

Mr. Gonser said that in late December, 00 - early January, 01 they will install these wells based on input they get back from MADEP. In the January - February timeframe the wells will be installed, sampled and the information will be made available to the Groundwater Study for purposes in studying the aquifer.

Mr. Gonser pointed out tentative ZOC's on the map projection, where they were getting 1 million gallons a day. He added he had hoped to be further along in the finalization, but a meeting with USGS last Friday they were asked to go back and look at some aspects of the modeling. He stated that he does not anticipate that the ZOC's are going to change significantly from what is currently identified.

Mr. Gonser stated that the ZOC well locations were agreed to be installed to avoid any known contamination from the IRP or the IAGWSP, or anything else that was in anybody's database. He said MW-57 from the IAGWSP hit a low level of perchloroethylene (PCE), is being tracked. He added that the Groundwater Study's MW-18 also had a small hit of TCE which is far from the ZOC but the 3MGD project wants to be aware of everything going on around them.

Mr. Gonser said the next step will be the installation of the chemical monitoring wells in January and they will report back with their results of sampling. He added that they will keep tracking the IAGWSP to make sure there are no new discoveries that would be of concern to 3MGD as they go through the new source development process. He said as he gets more information he will share it at the IART.

Mr. Hugus stated he noticed that something related to this is that a couple of meetings ago, he said Jan Larkin from the Joint Program Office said that she was going to try to incorporate into the maps that were put out by the IRP all the Groundwater plumes in the Impact Area. He said he would like to see the maps of all the known problems including plumes in the impact area. He stated he believes this map will give a good idea where all the ZOC's are and in problem areas are close to potential water supplies.

Mr. Gonser stated that is their intention. When the zones are completed they intend to give the data to Mr. Grant so he can put it right on the other maps electronically so that all the data is in one picture. He added that he is interested in seeing that map as well. He stated there has been a few meetings on it, it was discussed in the Pentagon on Monday with the Board of Directors. He said he hopes to have something very soon, has not seen a draft of it, but he thinks all the parties together have laid out what it is going to look like.

Mr. Cambareri asked what the overall project schedule would be? Mr. Gonser stated they are still on schedule and they hope to award contracts in the January time frame which would allow that contractor about 6 months construction time. He added that the designs for the pipelines are complete, but not for the wells and the pump stations yet, but that should come in the next couple of weeks. Mr. Gonser stated the southern water main in under construction now, they have installed from the Falmouth gate up to just short of the air field.

Mr. Cambareri asked if 3MGB was going to do profiling on their wells. Mr. Gonser said that profiling is a technique that is used for a very different purpose, so it can be reviewed by 3MGD, but the process right now is to follow the standard Resource and Development process that towns would do in their procedures.

Mr. Cambareri stated that because of the location of the 3MGD project being so close to the Impact Area that he believes that there is justification in his request to do profiling; regardless of how the two programs are different and urges Mr. Gonser to reconsider the project.

Mr. Borci stated that EPA views profiling wells as an economical and the most efficient way to get some additional data in an area where there are a lot of questions. He added that despite MADEP's response that it is not part of the new source approval, EPA is still going to urge the JPO to do profiling on their own. It is a water supply well and it is in the immediate vicinity of that well.

Mr. Zanis stated there are a lot of old ranges out there. He added that of all those 15,000 acres that they are taking water from off-base. Mr. Gonser stated they looked for the best locations and given all the restraints, the locations identified were ones that qualified. He added that there were a lot of constraints, the contamination, surface water bodies, location of the mound, it was hard to come up with good locations.

Dr. Feigenbaum stated that he heard the county agency saying that there is a need for more protective action for profiling and he said he hears the Federal agency is saying the same thing. He then asked if it is Federal money that is being used and said that because this is right at the border of MMR so why not just do the profiling. Dr. Feigenbaum stated that FS-12 was discovered when EDB was found when Sandwich was looking for town water, they detected EDB and it was traced back to the base.

Mr. Gonser referred back to the original question that profiling is a different process. He said profiling does. It takes discrete samples to depth, it does not tell you about the portion of the aquifer that is coming out of the well. He added that in profiling the water might be flowing over or under a screen, however, he acknowledged Dr. Feigenbaum is interested in characterizing and protecting that aquifer that is going to be coming up out of the well, and you want to be given advanced notice.

Mr. Gonser stated there are a number of options exist if there are detections found . He said options include reducing pumping rate of the well, change the screen level of the existing well, the well can be abandoned, it can be treated, analyzed, he said there a number of options to carry-out of detections are found.

Dr. Feigenbaum said he believes the first three options will destroy the object of the 3MGD project because the water will not be being supplied, and the last options are what we want to avoid. Dr. Feigenbaum stated he is unhappy with MADEP's letter. He added it seems irrational to him for 3MGD to have a waiver of environmental impact review for the construction of the wells but not for the operation of the wells.

Mr. Dayain introduced himself as the Chief of Drinking Water Program at MADEP. Mr. Dayain explained that the letter says that MADEP has no technical justification to require the type of well that is being proposed by EPA. He added there will be a century well system installed as part of the new source approval process for the development of those wells.

Mr. Dayain stated that MADEP asked modelers to find locations that would exclude waste sites. ZOC's as USGS contribution delineates and area that provides water under steady state condition. He said that if there is information generated from the far field wells, MADEP will welcome it. He indicated that the people of the Drinking Water Program see that as a site investigation initiative, and through the new source approval process, MADEP does not have the technical justification to do site investigation.

Mr. Dayain stated that if EPA wants to encourage JPO or the military for that information, MADEP would welcome that information. He explained that MADEP can not technically justify requiring the information. Dr. Feigenbaum asked Technically or legally. Mr. Dayain said both, the regulations require MADEP to do certain things but the regulations also prevent.

Dr. Feigenbaum asked whether Mr. Dayain means that the state regulations from doing what would ordinarily be required in this case. Mr. Dayain said no, "I didn't say it would ordinarily be required in this case" what he is saying is that there is no technical justification right now for the drinking water program to put in site investigation wells in these areas. Mr. Dayain explained that 3MGD is looking at that portion of aquifer that would contribute water to a well under pumping condition. The aquifer would be screened in the vertical horizon so that if in fact that well would be threatened, it would be detected.

Mr. Borci stated that EPA asked for the three chemical monitoring wells that are going in just be profiled as they are put in wherever MADEP approves them to go. He said his second point is that the modeling was based on known source areas at that time and CS-8 has two distinct areas that are being investigated and one is a disposal area of several gun carcasses sticking out of the ground which is right on the edge of water supply 1 ZOC. He added a third point that the construction of a gravel path well, any contamination between that well screen and the water table is of some significance. EPA would want to know where that is and that is why EPA thought profiling gets answers for the water supply people, the IRP, the Impact Area answers. EPA thought it would be an economical and efficient way to get some additional information on an unknown area out there.

Mr. Hugus asked if there are any active arranges within the Zone 2 boundaries. Mr. Gonser stated there is a range on Gibbs road. Mr. Hugus asked MADEP if those ranges are appropriate for land use above a zone 2, or an active range while water is being pumped from that area. Mr. Dayain said no. Mr. Hugus asked then if Mr. Dayain is insisting that the ranges be closed. Mr. Dayain stated that MADEP will take a look at what risk the ranges present under the use of which it is proposed.

Mr. Cambareri stated the establishment of this whole program is under the SDWA, to evaluate, protect, and the community to take advantage of this area as a water supply. Mr. Cambareri stated he believes that profiling the wells to find contamination could result in a good thing if there was no contamination found. He suggested to have MADEP select the locations, do the profiling, and the best thing that could happen is that nothing would be found.

Dr. Feigenbaum asked if the sentry wells find contamination creeping up into the production wells, who is going to put the containment system in, and how are they going to make that happen. He asked if it would be under the SDWA or the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). He stated he believes that the CERCLA process may not accomplish what is needed. He added that he believes that MADEP has been "less than helpful" in the citizens concerns.

Mr. Pinaud stated he wanted to remind everyone that EPA has oversight on CERCLA issues.

Mr. Murphy stated that it is now 10:30p.m.and reminded Dr. Feigenbaum that he had asked the USACE about their experience with UXO. Dr. Feigenbaum stated he just asked for a list. Mr. Borci stated there is a handout but he does not believe that is what the citizens asked for.

Mr. Deleppo asked if Dr. Feigenbaum wants a local list, a regional list, or a nation wide list. Dr. Feigenbaum stated he requests a representative list that does not have to be every place dealt with UXO, but some of the major areas, what kind of UXO were dealt with, how they were disposed of, what numbers. He said for Mr. Deleppo to choose his cases.

Mr. Zanis explained the citizens just want some references where the USACE did a good job on, so the citizens can check on it.

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

Mr. Murphy stated the next meeting is scheduled for Thursday, January 25, 2001 and the location will be announced when booked. Mr. Murphy asked if the action items should be reviewed or sent in email. It was agreed to send the action items out in the email.

Agenda Item #8. Adjourn

Mr. Murphy thanked everyone and adjourned the meeting at 10:55 p.m.

Action items:
  1. The Environmental Protection Agency (EPA) agreed to communicate directly with BG Keefe regarding the issue of making the ammunition supply point (ASP) inventory available to the public.
  2. Dr. Feigenbaum requested the Army Corps of Engineers (USACE) to look into whether potential contractors can present their qualifications at an IART meeting.
  3. Mr. Hugus requested that the Massachusetts Department of Environmental Protection (MADEP) add nitroglycerine to their MCP reporting list.
  4. MADEP agreed to measure the distance from the firing ranges to Greenway road.
  5. Mr. Hugus requested that future IART agendas be revised to allow for more time to discuss Action items as a separate agenda item.
  6. The Impact Area Groundwater Study Program (IAGWSP) office will inquire whether or not the USACE has funding to support IART citizen members at Technical meetings.
  7. Tetra Tech agreed to provide a map that illustrates all current and future investigation areas for the Munitions Survey.
  8. The USACE will provide the IART a listing of their relevant UXO experience including, but not limited to, quantity and types of UXO, locations, and disposal mechanisms.
  9. The USACE will report an ASR Update at the February IART.
  10. The following item will be included on the January 2001 IART agenda:
  11. AMEC (formerly known as Ogden) will include the Northwest corner Summary of Investigations in their presentation
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