Area Review Team
#1. Welcome, Approval of September 7, 2000 Meeting Minutes, Review
Review of Action Items
Mr. Hugus referred to the usage of the Greenway Road ranges. COL Bailey replied this was referred to in a letter sent to the IART members from COL Carter. Mr. Hugus said he is in strong disagreement with COL Carter's letter which stated that usage of Greenway Road ranges up to three times per year would be appropriate. Mr. Hugus feels the firing ranges are too close to homes in Forestdale and the Army National Guard (ARNG) could use other ranges in Camp Edwards. He requested MADEP address this issue with Secretary Durand because the citizens need officials who represent them to try to get the ARNG to stop using these ranges. Ms. Grillo replied that she would pass along Mr. Hugus's concern to Secretary Durand. Mr. Schlesinger asked how far the ranges are from the houses. Mr. Zanis replied that some ranges are 200 feet. Mr. Schlesinger then asked if hunting is allowed within 200 feet from a house? Mr. Zanis's understanding was that there is no firing of a weapon within 500 feet of a house. Mr. Schlesinger followed up this question by asking if it is permissible for the military to fire contrary to that law in the state of Massachusetts. Ms. Grillo said MADEP would look into that.
Dr. Feigenbaum stated at the SMB he spoke with COL Carter and he said they would not use the Greenway Road ranges except in the event of a national call-up from catastrophic military emergency. Apparently, in the letter COL Carter then said they would be used no more than two to three times per year. It is a clear inconsistency. At the last Senior Management Board (SMB) Dr. Feigenbaum asked COL Carter to come the IART meeting to clarify and explain what he said, and COL Carter told Dr. Feigenbaum he would not be able to do that. Dr. Feigenbaum, for the record, would like to again request that the ranking personnel be here to speak to IART. COL Bailey stated the ranking personnel of the base is here tonight, he is Gen. Keefe's appointed representative and is the ranking person. Dr. Feigenbaum asked COL Bailey if COL Carter is senior to him. COL. Bailey stated that COL Carter is commander of Camp Edwards and is senior to COL Bailey in that respect; however, COL Bailey is representing Brig. Gen. Keefe here at the board. There might have been a misunderstanding on COL Carter's case, the policy as stated in the letter that went out in June is the correct one. COL Bailey stated he couldn't address a sidebar conversation that Dr. Feigenbaum had with COL Carter. For the record, COL Bailey stated the Greenway Road ranges have not been used this year and there are no plans to use those for the remaining Fiscal Year (FY) 01.
Dr. Feigenbaum complained of very loud noise coming from the base all weekend and questioned which ranges were used. COL Bailey replied almost all ranges except the Greenway road ranges. LTC Knott added that it is an Army base.
Mr. Murphy referred to the Facilitator discussion and feels the facilitator is doing a fine job. LTC Knott stated that ARNG is happy to support Mr. Murphy as the new IART facilitator, as well as Dee and Pam from CH2M HILL here to support the IART. The ARNG has a contract with CH2M HILL to do whatever work agencies don't have time to do, so whatever they need, IAGWSPO are here to support them. EPA supports Jim Murphy as well.
Agenda Item #2. Supervising Contractor Transition
LTC Knott introduced Mr. Deleppo from the New England District of the Army Corps of Engineers (USACE). He will be giving a presentation tonight for the IAGWSPO on the USACE becoming the supervising contractor for the IAGWSP.
to Guard at MMR
Mr. Deleppo discussed how the USACE is going to approach the project, what USACE experience is in this field and the current existing relationships built over the years with the regulators. The USACE would like to help LTC Knott and Mr. Gregson integrate all the different aspects of the project together; have all the contractors working together through the completion of the project.
Mr. Deleppo gave a brief description of his background, starting with his personal experience as the USACE Project Manager for the Fort Devens Base Closure Cleanup. This cleanup had complicated groundwater and ordnance issues and was as large as a town for about 6 years. During this time he met Mr. Jim Murphy of the EPA and the New England District of the USACE has assisted a lot of the Superfund clean-up work for the EPA Region -1. Some examples Mr. Deleppo gave were Sue Rosen in Lowell, MA; Beard Maguire Site in Norwood, MA; New Bedford Harbor cleanup in New Bedford, MA
Mr. Deleppo began to discuss how a team is going to be assembled to do the work. Using Slide #4 "Project Delivery Team" from the USACE handout, Mr. Deleppo explained LTC Knott, Mr. Gregson and himself are all put in the middle of the chart under the heading "Guard and Corps Leadership". Going around the chart starting with the "Field Office" stating there is a USACE office on Massachusetts Military Reservation (MMR). This office will be headed by the resident engineer Mr. Frank Fedelle who also oversees work on the bridges on the Cape Cod Canal. Nick Iaiennaro who works with the USACE helps support the UXO work. Also there will be a Project Engineer to help coordinate the Field Activities. Mr. Deleppo divided the IAGWSP work into two major components: the UXO and the Groundwater work. Christine Johnston who works out of the USACE office in Concord will be heading up the UXO effort working with the Huntsville Corps of Engineers on UXO safety issues and Innovative Technologies such as robotics, or a bigger CDC.
As a side note, Mr. Deleppo announced that subcontractors would do a lot of the work. The first step in the process is have the IAGWSP shift the administrating of the Tetra Tech and Ogden contracts to the USACE. The USACE will also manage those contracts for the EPA. Looking into the future, because contracts do not last forever, the USACE will transition to other contracts; if needed, to do the further studies, designs and cleanups as the project proceeds. Ogden will continue to lead the groundwater study but the USACE want to supplement that with expertise of USACE laboratories and the USACE technical engineers. The New England District of the USACE is one of the Districts across the country that is certified to do hazardous and toxic waste (HTW) type cleanup. "Support activities" include Community Involvement (CI) and Real Estate Issues. The USACE's role will be to support the effort LTC Knott has developed in the CI aspect of the project. Regarding real estate discussions, the USACE will be ready to assist in any activities or research needed to support the project.
Mr. Deleppo moved forward with time frame issue reiterating that the USACE is in the process of building their team. Presently the existing contracts and scopes of work are being evaluated by the USACE. The next step is to provide a proposal to LTC Knott on how the USACE plans to transition contracts. The proposal is due by mid-November, 2000. The USACE wants to have contracts transferred and be up and running as the supervising contractor by January 2001. Mr. Deleppo announced he will be the primary POC for the USACE and his contact information is included the Corps Support to Guard at MMR handout, then welcomed any questions.
Mr. Schlesinger referred to the "Project Delivery Team" graph and asked how long are the ARNG and USACE are going to remain in the "center" of operations. Mr. Deleppo responded that the ARNG will always be responsible as the respondent to the AO, and the USACE will work with them to organize it all. Mr. Schlesinger remained skeptical that it is just another layer of bureaucracy, but hopes it works. Mr. Deleppo stated the USACE is aware of that possibility, but what they want to do is to execute the project in an efficient way.
Mr. Stahl asked where surface soil contamination fits into the USACE "Project Delivery Team" chart. Mr. Deleppo stated it would be included under the "Groundwater" section of the chart.
Mr. Hugus asked whom the USACE foresees as being the contractor they will bring in the future. Mr. Deleppo stated that is yet to be determined. The ARNG has procurement out now for a contract specific to MMR. The USACE will have their own procurement for contracts to get together proposals and select qualified contractors. This process will take six to nine months. The USACE would like to get that process started so there is no lost time during the transition. Mr. Hugus asked if there is going to be a different source of funding for the project due to the USACE coming in as the supervising contractor. Mr. Deleppo said no, it would not change the source of funding. Mr. Hugus then asked why the USACE did not include the support of citizens in their chart. He recognizes CI is listed and asked Mr. Deleppo to explain what support for CI means. Mr. Deleppo stated it means that the USACE will provide resources to support a CI effort that the ARNG has working now. The USACE is not in an active role right now with the ARNG CI but the USACE will participate in any activities that are going on. LTC Knott used CH2M HILL people present at the IART as example of a USACE contract. He further explained that CH2M HILL puts the minutes together and does whatever EPA needs to support the IART. Mr. Hugus said that the citizens on the IART need a technical person to work on the number of documents the citizens receive each week. For the record, Mr. Hugus feels the paperwork difficult to follow and the citizens need their own contract. Mr. Hugus stated the USACE was the agency that originally gave the lease to the contractors who performed questionable acts on the J Ranges and asked if there would be a conflict of interest when it comes to follow-up on the Textron Company. Mr. Deleppo stated he does not see a conflict of interest. Regarding the permission for the contractor to use that land. The USACE acted as a real estate agent coordinating the transfer of real estate documents to make that lease happen for whoever requested it. Mr. Deleppo added that the USACE would participate in whatever research is required to address the real estate issue. To follow - up on Mr. Hugus' question, LTC Knott stated the Army Environmental Law Division have started to have meetings with Textron Lawyers. Textron gave some financial proposals regarding the clean up. LTC Knott expects to have a letter from the Army Lawyers regarding Textron so the issue can be discussed at the next IART. Mr. Hugus stated he is glad that the ARNG is trying to hold somebody responsible for all the munitions that have been being uncovered at the J Ranges; but the problem he foresees coming up is if Textron says according to their lease they did nothing wrong. That might mean the case would be against the USACE who gave the lease. LTC Knott replied that the job of the Army Environmental Law Division is to figure that out.
Mr. Schlesinger stated there might be some issues where the EPA will have to get more involved with the USACE on questions like conflicts and weather that is going to impair their ability to perform as supervising contractor. What is important to note is that the NGB is responsible for the clean up and there is derivative liability beyond that. There may be some secondary litigation that flows from the AO but the EPA does not intend for that to cripple in any way the clean up. Dr. Feigenbaum stated he thinks that the USACE got off on the wrong foot by their method of introducing themselves to the community on this issue. He feels that tonight would have been the right time to introduce themselves rather than slipping it in the last minute at the SMB meeting. The statutory authority is stemming from EPA's AO, which is the principal public involvement body, and then Dr. Feigenbaum asked Mr. Deleppo if it is clear to him that the USACE is under no obligation to report to anybody else in the community.
Mr. Deleppo replied that it is clear to him that when LTC Knott asks him to do something he typically does it.
Dr. Feigenbaum said that a lot of people who are concerned about environmental affairs do not necessarily regard the USACE as the safeguards of the environment. Dr. Feigenbaum feels that it is stronger than just a conflict of interest. There were conversations with Textron where the USACE were said to be complicate with Textron's activities. Dr. Feigenbaum thinks the USACE should recluse themselves of any involvement with the J-Ranges. Dr. Feigenbaum asked if the USACE's intent is to replace Ogden. Mr. Deleppo stated is could possibly happen, the Ogden contract doesn't go on forever. LTC Knott added that the Ogden contract has already met its maximum dollar amount. All government contracts have a financial ceiling under the federal government. A year ago the contract went out for bid but another contract was not awarded so more money was added to the Ogden contract. LTC Knott stated that based on the importance of the study, waivers were placed and Ogden's contract exceeded maximum dollar amount with federal government permission. Dr. Feigenbaum asked why the Jacobs contract was not mentioned, and assumed it would go on forever. Mr. Gonzer stated that contract has a ceiling also. Dr. Feigenbaum then asked Mr. Gill if Jacobs Engineering is going to be replaced. Mr. Gill stated the intention is to have the contractor on board that can do the best job and so far that has been Jacobs Engineering. He added that they would continue to have the best contractor on board to do the job. Dr. Feigenbaum inquired if any competitive bidding was anticipated in the future. Mr. Gill stated that all of their contracts are competitive under the Federal Acquisition Regulations clause. At some point there has been some competition, but right now there is no competing of that contract. Dr. Feigenbaum stated that it sounds to him that there are plans to terminate Ogden. He added that Ogden is doing a terrific job and he would hate to see another company take that contract. Dr. Feigenbaum then noted it is interesting to see Mr. Banks from Jacobs Engineering is in attendance at the IART tonight, and normally he does not attend meetings that even his engineers report to the community. He has suspicions that this contract will transition when the study advances from the RI phase to the clean-up phase. Dr. Feigenbaum asked LTC Knott if he is thinking of changing contractors. LTC Knott repeated that the contract for Ogden per the law, was awarded to them and they have reached financial maximum. Another contract was put out, there is no specific date yet, but within the next 60 days it should be awarded.
Mr. Dowe from the audience stated he noticed that in the handouts there was no component included to deal with the ecological and hydrological impacts of the mitigation scheme that is going to be used to contain the plumes and treat the soil surface. He stated that obviously from previous experience in Installation Restoration this is an important component that needs to be considered. He then asked if USACE is going to oversee ecological and hydrological impacts or is somebody else going to do it. Mr. Deleppo stated that will be part of what the USACE is going to do. Mr. Dowe added that in regards to what Dr. Feigenbaum said earlier, his personal experience with the USACE is that they do a good job constructing civil works but their environmental record is abysmal. He stated that the New Bedford Harbor clean up was sited as a success story, but the last time Mr. Dowe attended a meeting to discuss phase II on the New Bedford Harbor Clean up his impression was that the civilians were unsatisfied with what was moving forward. He suggested the USACE pick another example to site a success story. Mr. Deleppo stated it is up to him to gain the respect and trust of the group. This is a very important project for Mr. Deleppo to succeed at and he is going to do everything he can with the resources available to him through the USACE to do the best job possible.
Mr. Walsh Rogalski stated he wants to make sure the notification protocol that was recently worked through with the towns is not defected by this change, and this protocol is subsumed under the actions of maintaining continuity. LTC Knott answered yes. Mr. Deleppo added that Mr. Iaiennaro from the USACE helped put that together, reiterating that the USACE will help with these things in the future, that will be part of what the USACE does.
Mr. Hugus stated he would like to add his vote of confidence to the Ogden engineers and that they have done a great job so far and should remain with us. Mr. Hugus then requested the USACE allow the citizens input and discussion regarding the decision-making process for future contractors. He personally would like to see Ogden stay active. Ms. Garcia-Surette asked if there is a mechanism for either regulators and/or interested parties, such as the citizens, with respect to selection process. She further asked that if not, is there an opportunity for the said parties to craft some questions that may be asked of the potential consultants during the bidding and selection process. Mr. Deleppo stated that the latter part of the statement is something that can be included into any procurement selection criteria. He then stated would have to look into weather regulators could ask direct questions & incorporating their comments in the final selection process.
Mr. Cambareri stated his concern with the USACE on board to seem like a step away from straight discussion with the potentially responsible party (PRP). He added that in regards to what Mr. Hugus said earlier about the amount of material that is being reviewed by the citizens and their ability to deal with it; maybe a contractor would help. He feels the TOSC is doing a great job, but maybe a technical citizen representative could sit in on the weekly technical meetings held at the Groundwater Study Office. Mr. Schlesinger asked Mr. Deleppo is the USACE has the resources to support the citizenry in such a manner. Mr. Deleppo stated he does not know of that happening as a role of the USACE but he can certainly check into that issue.
Mr. Murphy then introduced the Rapid Response Action Plan of Scott Veenstra from Ogden environmental and Energy Services, Inc.
Agenda Item #3 Rapid Response Action Plan
Action (RRA) Update
Mr. Veenstra began with RRA Good News. He indicated that Ogden beat their 10/1 deadline for soil removal: one of two enforceable milestones on the project. Based on their delineation efforts, 31 grids about 810 yards (yds) total of soil were removed from various areas of concern, and will be discussed in more detail. Other good news stories based on the soil washing Treatability study which was designed to look at a process in a laboratory setting to predict how it would behave in the field. Help with the final design of that system, Ogden ended up with only about 2 percent of the total soil volume that was dug up which actually had contained contaminants when done with the soil washing process. In other words, 98 percent of what is put on top of the ground will end up being clean, or segregated as clean.
Mr. Veenstra proceeded to give a brief history of how Ogden got to that good news. In backtracking the project, they went through a series of draft work plans and public presentations with open comments, resulting in agreed upon clean up standards with both DEP & EPA requirements. Both agency and public comments were incorporated into a revised work plan. That revised work plan was submitted at the end of July and approved by the agencies by late August. Then they went into the field and began construction. Mr. Veenstra noted that activities that were occurring before they actually got to the field included the issuance of an Order of Conditions for entry into the J-3 Wetland area which came from the Sandwich Conservation commission after a set of public hearings for approval. They did extensive delineation soil sampling trying to figure out the lateral extend and the depth beneath the ground surface they had to excavate. Treatability studies and containment pad construction were particular topics of interest and would be discussed later. UXO clearance included going into the field, inspecting and clearing anomalies based on a magnetic survey. Initial soil removal was completed on September 29, and then additional soil removal included 2 grids on October 12, the day after they received lab data. An additional grid was removed on October 17 after initial data review.
Containment Pad Construction
Mr. Veenstra said this area had previously been used during the processing of the Berm Maintenance Project across the street from Range Control. They took this area which was a dirt landing strip, did some rough grading and put down some asphalt paving. Essentially they built a parking lot of about 60,000 square feet. The idea behind this was to provide positive control of the material they got out of the ground. A blind sump which is like a sewer they were doing a continuous extruded curb. The idea is if rainwater falls on the pad they can control it, test and treat it before they discharge it.
Mr. Hugus asked Mr. Veenstra to clarify where this is. Mr. Veenstra reiterated it is across from Range control. He indicated that they felt it was a good central location, out of the way of most of the Guard's activities and had enough open space. It was within the training area so they weren't moving slow out of the training area.
Mr. Veenstra proceeded with delineation work which included sampling, lab analysis, trying to find out what was and was not contaminated. Based on Delineation of over 100 grids, analysis of those composite soil samples in comparison to those delineation results to the agreed upon clean up standards, they focused the program on 31 grids that had to be removed because they contained contaminants in excess of clean up goals established for the RRA. Those 31 grids equated to 750 cubic yards of material that was removed.
Study area 2 and gun position(GP) 16 sited no action. They did go out and resample and compared those results to the established clean up standards. Study area 2 initial results indicated ethylene dibromide (EDB). The resampling of that area did not confirm EDB presence there. GP 16 in NW portion of MMR initially was a 2,4, dinitrotoluene (DNT) detection. They did not need to remove soil to be in compliance with the agreed upon clean-up standards.
Mr. Walsh-Rogalski asked if there is a possibility that the EDB that they did not find moved through the soil to the groundwater lower than what was sampled. Mr. Veenstra stated they went out to duplicate the initial sampling that was done, and were unable to detect it on the duplicate sampling.
proceeded with describing the steel-lined pit as a yellow box, actually
excavated 8 - 12 months ago. Material was containerized in 6 drums
at the time of excavation. Their response was not to dig that material
up but to report the post excavation samples as part of the final
work plan. That material will be brought to the containment pad
tomorrow October 20, for processing in the week of October 30.
Post Excavation Sampling
Mr. Veentra described Post Excavation Sampling as where they confirm that they met the clean up goals. As stated earlier, initially there were 31 grids. 29 of those 31 grids were reported as less than the clean up goals based on the post excavation sampling. There 2 grids at 6 percent that did not meet the test the first time, 1 grid at the APC and the only grid at GP-7. (VIDEO???) There was 1 grid on the KD Range that still detected dieldrin at 31 parts per billion (PPB) versus the RRA Clean up standard of 246 PPB. But Mr. Gregson said to help out with the MCP program for the MADEP, Ogden should go back in and dig that out. That was done on Tuesday October 17. They are still waiting on analytical results on three additional grids, which are expected to be back in on Monday, and then will respond hopefully with backfilling those as well.
Soil Washing and Treatability Study
Mr. Veenstra stated that the discussion of Soil Washing and Treatability Study issues was delayed from last month and that he would discuss them now. A Treatability Study is done in a laboratory setting using soil from the site they anticipate they will have to process. The goal of the treatability study in this case is to find within the soil matrix where to find contaminants. Soil washing does not destroy contaminants but it helps to isolate a soil grain size where contaminants are present. The study indicated that soil washing could isolate contaminants in the organics. The organics make up only a small percentage of the soil matrix at MMR. Thus 98% of the soil is non-organic, which includes rocks, gravels, coarse sands, and fine sands. The Treatability study broke out each of these different components. They tested each individual component or soil fraction and did not find explosives, pesticides or metals. But explosives, pesticides and metals were found in the organics. Starting Monday they are going to run soil through the soil washing system to get out the 2% organics for subsequent treatment. The other 98% will be tested again, daily process confirmation samples like on the berm maintenance program, analytical data compared to the clean up goal provided those soils continue to be below the clean up goal they will be released for reuse within the training area.
Mr. Veenstra stated photos would be available of the soil washing process for the next IART Meeting. They just finished wet shake down belt alignment so they are set and ready to go. Much of what was discussed was innovative technology on the RRA and what was innovative was linking two technologies that have been proven in different applications and bringing them together as one for the RRA. The second step was Bioslurry, which was degrading the explosives that are present in the organics that were segregated during soil washing. He explained that they feed a carbon source to the naturally occurring bugs in the dirt, getting the bugs excited enough to eat explosives and break them down. In the Treatability study conducted by Envirogen, Ogden got the bugs excited to the point that the end result was non detect for explosives. That was great news.
However, along the way some things were discovered that need some time reviewing so Ogden & Envirogen can tell the Guard and IART that they recommend proceeding with bioslurry as the solution for that 2% of the soil. We had hoped to be there, but have encountered some unanswered questions, we are working to get the answers, but until then we have to exercise an alternative. Initially that alternative is to containerize the organics. Sludge style roll off boxes, sealed back gates, truck tuffs ready to take that material and hold it on site. Once it is containerized, it is controlled. We want to take the time to prove out bioslurry or another innovative technology.
Ogden has a program going on right now with the USACE now looking at five other technologies that have applications for explosives in soil.
Bioslurry is limited by weather. When a bioslurry is finished with treatments it has to be de-watered is not done well when water freezes. Proposal to EPA has been to containerize the fines for the organics, hold them until spring at which point we either have bioslurry proven out or another innovative technology. As the work plan identified, this was always a possibility. We hoped it would not come to having to make a choice, but there is also the option always present of off-site disposal.
Off site disposal is the ARNG's absolute least desirable option even though it might be the most cost-effective. LTC Knott has told Mr. Veenstra that he wants to continue with the innovative technology applications here at MMR and is willing to spend the time to find a technology that should work on this sort of material.
Dr. Feigenbaum asked Mr. Veenstra what the unanswered questions were.
Mr. Veenstra said they have two things to resolve. One is that during the Treatability study a contaminant of concern (COC) called dieldrin was was degraded, but it was not degraded to below the RRA clean up standard. The final detection of dieldrin in the Treatability study was approximately 500 parts per billion(ppb) the RRA cleanup standard established for the Project was 246 ppb. They need to determine weather it was time limited or process limited.
Going back in to look at the study so they can understand it. They provided an executive summary, some recommendations for the guard to review had been discussing those as will be shared in the technical format, and look at what steps are necessary to come to a definitive "YES" to recommend bioslurry, or a definitive "NO" we need to look at something else.
Dr. Feigenbaum asked Mr. Murphy if there could be an open session now before continuing. Mr. Murphy said it is fine, whatever people want. Then announced who would speak in turn.
Dr. Stahl's asked if the data would be available. He indicated that he particularly would like to see the results of the Treatability study and added that this is his particular interest and area of expertise. Mr. Veenstra stated at this point there is an internal document undergoing technical review. Once the internal concerns are discussed, addressed, and released, the Treatability study report for the Brice Soil washing will be available. LTC Knott added that would be next week.
Dr. Stahl then asked what kind of mechanism would there be to comment and whom he should comment to. Mr. Veenstra stated that is a good question and he referred to LTC Knott. LTC Knott asked Dr. Stahl if he thinks that the TOSC comments on the Treatability study should be given to the EPA because it is for the citizens or could he provide comments to the IAGWSP office directly.
Dr. Stahl stated EPA and DEP are also waiting for this Treatability study. Probably the best thing to do would be to have all comments submitted to the ARNG and the Guard produce one document that responds to those purports. ? will have that document to the DEP, EPA and TOSC next week, all comments will come to us and we'll produce a document that has all responses in one area.
Dr. Stahl asked if he could have a timeline.
LTC Knott said there is a standard time to respond to comments on, if you need additional time than we normally give, we can work that out. Dr. Stahl and LTC Knott agreed to three weeks.
Mr. Schlesinger referred back to the previous discussion of area 2 and GP-16. This discussion regarded the non-detect of contamination in non-organic soils. He then asked if there is a chance the locations tested were of the wrong soil type therefore you didn't find the COC and the COC is still there further down in the soil. He expressed concern that these two sites are being "chucked out" without concern for weather the COC is still present. Mr. Veenstra stated that all sampling that was done under the RRA delineation efforts- looking for more contamination. He indicated that they used the same protocol as approved by the EPA for the initial investigation that initially began the RRA. The situation at area 2 regarding EDB was resampled using the same protocol, and was sent to the lab for analysis. He does know that the result coming back is non-detect. They could not confirm the COC's presence. There was no additional sampling done at GP-16 because the RRA clean up standard for the project was a number higher than the detection of 2,4,DNT at that location.
Regarding weather we are looking at the right place for contaminants, the sampling protocol used for the project is approved and is consistent for what has been done to date for all soil sampling grids. They need to maintain consistency so they can compare data.
Mr. Borci answered with two facts to express. One is that the EDB levels in the soil was relatively older data and it was still included in the RRA to have them go out and verify weather or not it is still there. ???You would expect that it would volatilize- it was a big surprise to see it there, so it brings it into question the whole thing from the beginning. But if it is migrating into the groundwater, as part of the long term monitoring plan for the entire Impact Area (IA) wells downgrading of that area are specifically sampled for EDB for that reason.
Mr. Hugus asked Mr. Veenstra to confirm that there was 750 cu yds of soil that would be treated. Mr. Veenstra stated it was the initial 31 grids, they have done 3 additional grids of excavations and are now at about 810 cu yds. Mr. Hugus asked how much of that will have to be containerized. Mr. Veenstra stated that every bit would run through the soil washing process and test the soil to confirm that they are clean. Based on the Treatability study they believe that only 16 cu yds would require further treatment. In other words those 16 yds would be put in containers and held. Mr. Hugus asked if the Treatability of only 16 cu yds. of soil is a problem. Mr. Veenstra said the question is what to do with those 16 yds. The proposal would be to implement bioslurry subject to Treatability study that indicate it would meet the clean up goals. Mr. Hugus then asked if the other 780 cu yds could be treated properly. Mr. Veenstra reiterated that soil washing is not a treatment process, it is a separation process, separating those materials that contain the contaminants from those that do not. It is Ogden's belief that everything but those 16 cu yds will be below the clean up goal. Mr. Hugus stated the team should understand that Mr. Veenstra is talking about a small percentage of soil that will be treated with the bioslurry. Mr. Veenstra said that is correct. Mr. Hugus then stated that he thinks it was a year ago that the Envirogen gave the IART a presentation about the bioslurry. Mr. Veenstra stated that he believes that the first presentation on bioslurry would have been back in March, but it does seem like a year ago. Mr. Hugus said he would have thought that these problems would be ironed out by now. From the progress reports he feels there is intensive meetings about it but there have been no updates from Envirogen since that time. Mr. Veenstra said that is because Envirogen is a subcontractor to Ogden and Ogden is responsible for that report. The Technical team is updated weekly as to the status of the RRA and all its components.
Dr. Feigenbaum asked if there are any daughter products from the explosives and propellants. Mr.Veenstra stated he is not a chemist and has to refer to them and their knowledge of the process. What he can say is that the breakdown is complete. They have written a briefing paper as a result of the last SMB meeting. He suggested that once LTC Knott reviews the briefing, Ogden might also distribute that briefing to the IART as well. Dr. Feigenbaum asked again if the daughter products are going to ammonia, elemental nitrogen, etc. Mr. Veenstra reiterated that he is not a chemist and would have to defer to his subcontractor. His role is to coordinate a lot of people to get the job done.
Mr. Murphy requested
that to be answered now if possible. Dr. Stahl stated he can speak
to what would be expected from this process. From the COC's breakdown
there will be hydrazine, which will oxidize in an aerobic environment.
Nitrogen products, upon oxidization would include nitrite, nitrate.
Carbon dioxide and methanol. Doug expects from dieldrin there will
be chloride and other organics but has not been characterized as
well as explosives. Mr. Veenstra interrupted and requested Mr. Larson
who is the Project Manager from Envirogen and is present in the
audience, to answer Dr. Feigenbaum's question.
Mr. Larson introduced himself. He began by stating that RDX breakdown has been looked at but not in as much detail as TNT where breakdown process has been thoroughly characterized. The first step in RDX breakdown is to go to 3 compounds, MNX, DNX and TNX. Those compounds further break down into other compounds that have not been as well characterized. The breakdown from those proceeds so rapidly that scientists have not been able to decipher them before they break down. The dieldrin is also less well characterized. It appears that they can get it to go through a reductive dechloronation, similar to the way chlorinated solvents break down, which involves tacking on an anaerobic treatment phase to a bioslurry process. Because of the long turn around times they weren't able to do that in the time frame of the Treatability study. Mr. Larson referred back to Mr. Veenstra's question on determining weather the breakdown was time limited or process limited and if it would work through an anaerobic phase.
Dr. Feigenbaum asked if dieldrin is soluble in water. Mr. Larson stated that was correct. Dr. Feigenbaum then asked if it was washing out in the soil washing process. Mr. Larson stated they do not believe so. Dr. Feigenbaum asked if there is any literature on the microbial degradation of dieldrin and Mr. Larson said no. Dr. Feigenbaum assumed that is cannot be done. Mr. Larson stated that there is an indication that it can be done, but there is not a lot of literature on it which is why they want to do a follow on the study. Originally the primary focus of the study was on the explosives, and they thought dieldrin might work in conjunction with the explosives. After examining the results, they learned that the dieldrin needs to breakdown further. They have ideas on how to make it breakdown further, but they need to do additional study on dieldrin.
Mr. Veenstra suggested the best way to follow up on this issue is through LTC Knott. LTC Knott has agreed to distribute this report in a timely fashion between the Treatability study report text, data tables, Ogden's executive summary and statements as to things they need to wrap this up. Mr. Veenstra feels this would answer a lot of Dr. Feigenbaum's questions. Dr. Feigenbaum stated that this has been very helpful and thanked Mr. Veenstra.
Mr. Zanis noted, as one of the citizen members that he wants to give TOSC members, specifically Dr. Stahl, some credit because when Dr. Stahl looked at the data he told Mr. Zanis that there are going to be problems. Mr. Zanis thinks the ARNG should use this information directly, with Biogen and not abandon this project, to continue on and try to resolve it because they might need it in other places in the country. The IART then acknowledged Dr. Stahl's contribution. Mr. Zanis proceeded to ask what the two largest sites were that had to have soil removed. Mr. Veenstra answered that the KD range constituted the vast majority, then the APC would have been second.
Mr. Dow from the audience stated he presumes that in the soil washing process the organics referred to are particular organics that are isolated. Mr. Veenstra said that is correct. Mr. Dow asked if washwater was tested for RDX or HMX associated with the ?????? Organic carbon which presumably gets washed out in the soil washing process. Mr. Veenstra stated they certainly have and thanked Mr. Dow for raising the issue which was not talked about earlier. The rainwater they collect is used in the initial charge in the soil washing process. One thing that Brice does is recirculate that washwater. They also run water through a sand filter and a carbon filter before they put it back in the process. Ogden does observe that there are some transfer of explosives to the washwater. Ultimately part of the project is disposing of the final water in the process.
Mr. Hugus stated for the record, by following up on Mr. Zanis's comment, he thinks it was at Envirogen's first presentation of the bioslurry process that Dr. Feigenbaum pointed out dieldrin would interfere with the biodegradation process because it is made to kill living things. Envirogen heard it from the citizens at the outset and what he was saying earlier about the time that has gone by is that we advised Envirogen about the problem in the beginning about what we thought was going to happen. Mr. Veenstra stated he wanted to address this issue at last months meeting but they ran out of time. Mr. Hugus stated he is not blaming Mr. Veenstra, but feels Envirogen could have grappled with the situation and solved it a long time ago. Mr. Veenstra, in defense of Envirogen, stated that they were subcontracted to perform a service. Envirogen was ready to perform this service, but could not start until the soil washing was completed. The soil washing Treatability study was finished in late August and that was when Envirogen actually started.
Dr. Feigenbaum stated he has a conceptual problem about the dieldrin. Why is there so much dieldrin associated with these sites. Mr. Veenstra answered that there is not so much dieldrin associated with the sites. Earlier he had discussed "spiking" of the Treatability study for Envirogen because the material advanced from the laboratory at Brice that was transported to Envirogen did not have detectable RDX or dieldrin in it. Mr. Veenstra wanted to give Envirogen a chance to demonstrate their process in the laboratory setting. We artificially introduced RDX and dieldrin into the soil matrix. It is not the ideal way to run a Treatability study.
Dr, Feigenbaum stated that he is very confused. Mr. Veenstra explained that in accordance with the work plan they went out and conducted a Treatability study. Part of that was to collect soil from the actual sites of contamination. They took a weighted average of the areas of concern: KD ranges, APC, GP-16 and steel-lined pit. It was blended into a composite sample to represent the soil that we would have to deal with. That soil was run through the Brice Soil Washing Treatability study, on lab scale. The outwork? From that was given to Envirogen represent what they would get in the field to put into your bioreactors.
Mr. Veenstra proceeded to explain again that the material that came out of the Brice Treatability study, was given to Envirogen to do their study. The first thing they had to do was analyze it to get a baseline concentration. When they did that analysis they did not find RDX nor dieldrin. Dealing with trace level contamination in most cases, near the detection limit. Contamination ranges in only in the orders of magnitude greater than the detection limit. In the interest of time, to make sure we could implement the project, we introduced RDX and dieldrin to your sample in your laboratory and run your study on that. The alternative would have been more time consuming, they would have to go back out and collect samples in the field as they had done, re-run it through the Brice process lab study costing more money and time, then give that to Envirogen and have them test that. Re-run the risk that it would come up non-detect again. We felt spiking was in the best interest for the time of the project. Dr. Feigenbaum stated that maybe there is not a dieldrin problem, as a matter of Treatability and maybe there just is not that much out there. Mr. Veenstra stated he would agree.
He further said what they would find in the soil washing process, they will get the organics that they are going to containerize. The process will start running on Monday October 23, and will run for two weeks to complete 810 yds. They will be taking dailey output samples of each of the grain sizes. What we are concerned about what we do next with is the organics. When we have those analytical results, we will know weather dieldrin in a treatability study is even a concern. If we take the organic output from the soil washing in the field and do not detect dieldrin we are less concerned about what happened in the Envirogen study.
Mr. Veenstra moved forward to going into the field with soil washing, the process is set up and they are introducing soil to it on Monday October 23. They will take dailey process confirmation samples, and as they get back the lab data on the three remaining grids, they will finish back filling the excavation sites, and perform site restoration. Site restoration includes re seeding and re establishment of vegetation. Again, they will containerize organics from soil washing until they can make an informed decision as to the next step for that material. Mr. Veenstra stated that completes the RRA update.
Mr. Murphy announced that the meeting is now running 45 minutes behind. He then introduced Leo Montroy from Tetra Tech to give the next presentation.
Agenda Item #4 Munitions Update
Dr. Montroy stated since the last briefing most of the work has been continuing in the J-Ranges and there has been some activity in the High Use Target Area (HUTA). He refreshed the TART the team that the munitions survey project is focused on detecting areas where munitions might have been buried, such as burial pits or debris buried in the ground. They are doing that by taking an area that has been selected for study and clearing out the unexploded ordnance (UXO) from the surface. They then remove vegetation to allow clearance for geophysical equipment. Do a detailed subsurface geophysical evaluation and then analyze and reporting the anomalies that are found. This has been in progress for a number of months now.
Dr. Montroy stated this is not sexy work. It is hard foot-slogging day-in, day-out work. Some days are better than others. To date we have cut approximately 12 acres of trees and cleared approximately 28 acres out of the 30 acres on J-2. The whole idea is to get the area clear so the geophysicists can come in and do their geophysics survey in one continuous push. This keeps continuity and QA issues that would have to be dealt with in doing small areas at a time. Dr. Montroy stated they are using the Brontasaurus technique at J-1. Due to Safety issues in J-2 they had to cut by hand and could not use the Brontasaurus. Again the technique is to clear the area so that they can complete their geophysics.
Dr. Montroy showed a photo of the J-1 range after using the brontosaurus, which is very cleared. Most of the trees that are being removed are 1 to 5 inch diameter pitch pines that are basically have grown into the formerly cleared area since1971. In J-2 they are manually clearing the area, something Dr. Montroy called plain old brute force and it takes a long time.
Mr. Hugus stated that he was impressed by the search for UXO in the J Ranges, but also destroying a lot of trees that are scrub pine. He asked that the ARNG fund Tetra Tech in the re-planting of all the trees that were removed after the UXO Survey is done. He feels this will prevent the IART from getting a reputation as being a team who harm the environment in order to help it.
LTC Knott stated the ARNG would definitely support the restoration requirements under AO#3 Restoration clause. Mr. Borci confirmed LTC Knott's statement. Dr. Montroy added Tetra Tech has a botanist on staff who has worked on the cape for years and is advising TetraTech as to when restoration takes place there might be native plants that that are better suited to restore rather than the typical grqasse3s and/or plants that are used.
Mr. Schlesinger asked if there were munitions found in tree areas as the vegetation is being moved back to the 1971 landscape. Dr. Montroy said yes. Mr. Schlesinger asked what would prevent munitions to having been buried in tree areas in the early 70's. Dr. Montroy stated that outside the boundaries they are cutting there is nothing to prevent it. He said it is a matter of approach; having gone through the Archive Search Report (ASR) and working with what the regulators looked at. If, for example, they find burial sites that are on the edge of a tree line, they will cut more trees and go wherever they need to go. He stated that they have to start somewhere and then stop somewhere to start up from there on.
Mr. Borci stated he thinks it is important to add that at this part that Tetra Tech is using Aerial Magnetometry (Air Mag), and this is where the utility is. J-2 had the air mag completed and Mr. Borci believes it has been contracted in the other J Ranges. Dr. Montroy referred back to a presentation he did at the IART where he superimposed the Air Mag map over the J-2 map and were able to say that the red blotches the helicopter borne arial subsurface magnotometer map showed surface and subsurface anomalies. In the J-2 Ranges they are annotating that drawing to find what anomalies cause the big red blotches. Dr. Montroy said once they get the subsurface geophysics, they are going to compare the two. Theoretically where the Air Mag has something red, the subsurface geophysics should have something red. The idea is that maybe in the future we do not have to cut all these trees down. Maybe with the aerial magnetometer survey is a really good tool for getting big sites cheap, fast and easy without doing all the destruction of trees. Dr. Montroy stated that LTC Knott has authorized Tetra Tech to contract out the same firm, same plane, same pilot to come back out and do another 3,000 acres including the other J-Ranges.
Dr. Montroy discussed the diamond shaped orientation of the HUTA with grids and showed an early photo of surface UXO and fragmented metal. Within the diamond shape of the HUTA, they selected and mapped six 10,000 sf test plots. They constructed access roads around each test plot. Then they removed all UXO. and then began excavation of initial lift of Test Plot 1 (TP1). TP1 was a low-density TP, wanted to start off with something that didn't have as much metal. They are taking extensive samples to send to Ogden's Lab and field screening facility. In the first 2 ft of TP1 found 15 ordnance items that could be taken (safe to move) to the safe handling area and 5 ordnance items that were determined unsafe to move and were Blown in Place (BIP).
Mr. Hugus asked what was found? Dr. Montroy explained this was a 105mm and 155mm artillery site which represented the majority then there were two 81mm and two mortars. He stated that a detailed listing of the exact items on a separate handout produced by Mr. Iainnero, titled "UXO Discoveries/Dispositions Since 9-7 IART". Dr. Montroy showed a clip of TP1 Excavation. He stated it is important not to go down deeper than the lift that they are supposed to do. It is a real difficult activity to scrape and not go deeper. The EOD guys cleared 3 ft down and only maybe 2 ft below that, so if the guy digs deeper and scoops something that was not cleared is a potential hazard. What was dug up goes into a dump truck and the dump truck dumps the soil into the Screening Area on a grate. The big cobbles roll off. Underneath are sets of screens that rotate back and forth. The metal gets separated from the soil. And the soil gets sifted and put off the top. The fragments that are sifted out go into a large lock storage container. The container get weighed to get the mass of metal was picked out of that particular lift.
Mr. Walsh Ragowski asked when do they sample the metal? Dr. Montroy stated the largest portion of sampling is done before they do any excavation. They have a protocol in their work plan within the 10,000 sf there are a number of points that they are sampling. There is a decision protocol to help decide which item to sample. If it is safe to move they will sample under it. They brush soil off the item, collect the soil, wipe the item with cotton ball a solvent for explosive constitute contamination. They take representative samples from the frag that comes out of the lock box.
Mr. Schlesinger asked if he knows at the time the front-end loader picks up the dirt on the ground weather there is something in it? Dr. Montroy stated that in the field at the HUTA TP they are not trying to pick out every piece of metal, which will be here forever. They are looking really for the big chunks, which has been a challenge. Some of the 155 fragments in big chunks like a hunk of metal, but there are also rounds that are the same size. So they do not want a live round going through the sifting process and tumbling into the screening area. That would be bad.
To wrap up Dr. Montroy stated that the J Ranges are undergoing brush and surface clearing. This will take a couple of month before the Geophysics guys can do their thing. Regarding the HUTA, they are taking their time and learning on the way using TP1 so that if they make some mistakes there is much to improve on due to the low density. When they reach TP2, with the experience they've incurred from TP1, they are likely to move faster. Hopefully by the time they get to TP6 they can just speed right through it.
Ms. Garcia-Surette asked that with respect to identifying the extent of clearance that is warranted, its it possible to give a ball park figure of what the extent of potential clearing will be in the future, or is too premature to know? Dr. Montroy stated this study is attempting to look at. There are few studies, none at MMR that state in a particular Impact Area what exactly you are going to find, where, and how far down. MMR is being treated as site specific, and is not being compared to other studies done in other Impact Areas. Ms. Garcia-Surette then asked if Dr. Montroy has any knowledge of other areas within the MMR 15,000 acres besides the HUTA that warrant any kind of evaluation such as the one performed to date. Dr. Montroy stated they are doing that as well. There have been extensive subsurface geophysical work at Gun & Mortar position, Water bodies etc and the answer is the IA is unique because these items came down ballistic trajectory, so they tend to penetrate deeper. They have been focusing in on other parts of the munitions survey project where holes were dug and stuff was put in.
Mr. Borci stated that this is all going to feed into the FS for UXO under AO#3, which essentially takes all this data to help come up with options of density for metal that we see with Air Mags versus what is actually seen on the ground when the trees are cut down. Once all those options are laid out, they can formulate what they need to do.
Mr. Jim Haynes, citizen, stated he was interested in the Air Mag surveys and was wondering if Dr. Montroy could say something about the success of those and specifically, what has Dr. Montroy's experience has been with False Positives resulting from the Air Mag surveys. Dr. Montroy stated that his company has 8-10 years experience running an Innovative Technology Program for the Navy and every 2 - 3 years they invite contractors to go up to Jefferson proving ground. They scatter munitions all over and tell them to find it. They have invited various airborne platforms for years and they really have not done very well. Dr. Montroy stated that his personal opinion was that they do not perform very well. He added that Mr. Borci felt this was a good technology. In the past 2 years they have really fixed up their system. Dr. Montroy feels that the Air Mag at the MMR has been very successful. Regarding the question about false positives, their scientists have controls for everything. What they did was along Jefferson Road they planted real munitions and metal pipes that would look like buried caches of munitions in the ground. They flew the helicopter at various distances - they did not know what or where the anomalies were buried. When they turned in the data, they found everything and they found it even at 25 ft above the ground, which was very good. False positives will always be a problem, but the reverse of that gives them a nice red blotch on the map to go out and look. Gives hot leads. It could take years to cut down trees where the Air Mag has detected a red blotch in the woods. Dr. Montroy stated he is very confident in Air Mag as a technology to use at MMR. He feels it would save years of investigation.
Mr. Schlesinger asked if it was already set in stone what is going to be done as a team to find out weather the pattern is spatially representative that is of the rest of the location. Mr. Borci answered that it is all part of the study. They tried to select an area that appeared to have been used to a great extent through timeframes. Weather or not this is characteristic of the entire central IA, we do not know yet. Mr. Schlesinger clarified that what he wanted to know was is this knowledge going to be applied to areas outside this test plot. Mr. Borci stated all this information will be gathered for the UXO FS. Further issues will be addressed when the FS is completed. Dr. Montroy gave another example, that they flew the Air Mag over the area before they start digging. They will be able to take the subsurface geophysical plots and compare them against the Air Mag to get a correlation. Then they will go to other parts of the IA where the Air Mag shows red Splotches and will do another geophysical survey. If they find the same stuff there will be two points that correlate. That is the scientific approach.
Mr. Dow asked if the Air Mag studies are equally sensitive to UXO and UXORM. Dr. Montroy stated yes, that it looks for thero magnetic objects; it looks for UXO, UXORM, Trucks, truck bodies, steel plates, anything that will give back a magnetic signature. Mr. Dow then asked if the size of the object makes a difference in how sensitive the detection is in the air. Dr. Montroy stated that the bigger the target, the bigger the red blotch. At the other end they were able to find some 155mm along Jefferson road and they can see that from 25ft above the ground. Dr. Feigenbaum asked how deep they were and Dr. Montroy stated they were 6-8 inches deep. He added that part of the job over the winter they will do a surface validation of what is there.
Mr. Murphy, looking at the agenda, asked the IART how they would like to proceed with the agenda. It was agreed to go further with the Investigations Update by Ogden.
Agenda Item #5 Investigations Update
Mr. Clemens began with informing the IART that he is presenting for Mr. Grant tonight. He thanked the IART for the kind words and that Mr. Grant is part of the reason Ogden get such good reaction, he does a great job presenting and is away at a family reunion at the moment. What he is going to do is provide a brief update on the work Ogden is doing as well as address some very specific items that were called out in past IART meetings under the AI.
Mr. Clemens stated he was presenting about three years ago with some of the same maps and they were not any where near as many dots on them as there are now, which means they have progressed. Mr. Clemens stated he remembers Mr. Hugus and Mr. Cambareri had asked questions in the past about the amount of activity in the Northwest Corner of Camp Edwards, and Ogden wants to address what they have been doing and what they will be doing.
Northwest Corner of Camp Edwards
Mr. Clemens stated that utilizing the ASR they have focused in on various areas used for training. There is a Training Area work plan, and Mr. Borci has participated in recons of areas that include the Northwest. They are researching what locations that activities have happened for a more focused investigation. This led to the work at the Anti-Tank gravity Range and other locations that are going to be looked at. But they are trying to focus investigations tied to the activities as that are known or are discovered in the ASR which is a continuing story so Mr. Clemens stated he thinks he understands what Mr. Hugus is saying.
stated there is not a good handle on what is the northern extent
of the plume. He does not believe there is enough knowledge of how
far they extend northeast. Mr. Clemens explained that the purpose
of the transect is to try to get an idea of what is migrating out
of the central IA. There is ongoing work at wells in the northern
area, right now there is a lot effort to focus on what is going
northwest. Mr. Schlesinger explained he has a problem with how far
out the wells are from the central IA. It may take 20 - 30 years
for the water to get to those points. He feels the wells are too
far out. Mr. Clemens said those wells were installed early on in
the program to establish some bounds on where things were. We have
not seen a lot of indication of activity going out in this direction
yet. Mr. Schlesinger added that there are no wells in that area
to make that decision. Mr. Clemens pointed out wells trending north
to capture problems as part of the program.
Dr. Feigenbaum stated he wanted to add his voice of support to what Mr. Hugus. Mr. Schlesinger and Mr. Cambareri said. He feels Jan missed the point. The maps show the plumes are somewhat discontinued. There are pieces of contaminated areas that underlie others and are along side others, so it could be quite possible to get to the end of a well fence and have it non-detect but somewhat down gradient there might be contamination. He feels it would not be a miss to go down gradient from MW-10 and put in some wells to see if there are detached areas of contamination.
Mr. Borci stated he needs to point out that nobody is disagreeing with what they are saying. They are working stepwise, they up at the top and the next wells that go in are going to turn the corner. As they find contamination they will follow it up there. There is another well going in down gradient from MW-10. That will be in the area Dr. Feigenbaum was referring to. Mr. Borci further explained that the Field Sampling plan for the training areas is yet to be implemented. They are waiting for more information from the ASR. He said this area is certainly not off the table and they are going to look at that like every other area. Mr. Borci clarified that what Mr. Clemens was trying to say was that the resources are being focused where the problem is known to exist. As they find more problem areas they will investigate further. Mr. Borci said he is leery to go and place wells without supporting information. There are several wells with no contamination, but when the central IA investigation they began to move outward as they found contamination and plan to follow the same work plan. Ms. Dolan stated she did neglect to say earlier that the danger of going a far field first without going up gradient information is a false sense of security. She agrees it is a spacious area, but they are going to go in there scientifically. She then stated that this issue is done. LTC Knott stated he agrees with Mr. Borci and Ms. Drake. Mr. Cambareri followed up by saying the success is not just putting in a well. The IA Investigation is to understand what lies beyond what they find. Without a program to consistently move forward, he fears that a single well or two installed may make them feel there is no need to go farther.
Mr. Murphy asked if anybody has anything to add. Ms. Drake stated that with the close look that the IART keeps on the project that they are not going to miss a thing. If we reach an end of an investigation and you feel we have not gone far enough then we'll be discussing it right here
Mr. Clemens continued with the status of monitoring well installations. In September completed wells include: three in the IA (MW-123, MW-124, MW-126); five in the J-Ranges (MW-120, MW-122, MW125, MW-127, MW-128); and one well near Demo 1 (MW-129). They are continuing with additional wells in the IA, the J-Ranges and Demo 1.
Mr. Clemens noted that additional wells going into the J-Ranges, regarding the buried munitions that are being found, MW-131 is in the process of being constructed that week. The UXO that came out of that particular area are provided in a handout.
and Sampling Results
Mr. Clemens displayed cross sections as requested by the IART. The intent of the cross-section longitudinally was to show what the contamination looks in the vertical dimension. The cross sections were A-A' and B-B' with the intent to show how the work that AFCEE and IRP has done on CS-19 how that related to the broader area of contamination that Ogden has been working on in their study. Cross Section A-A' shows RDX Concentrations going through the CS-19 Plume as delineated by the IRP program but includes the larger extent associated with their data. Cross Section B-B' shows estimated RDX distribution associated with the IA that are farther up gradient along CS-19. Based on the profile data and well screens, contamination occurs in the surface, finds its way into the water table and migrates out and down. The data so far suggests and area of contamination moving under CS-19 and then a clear CS-19 plume. As was said earlier the IRP program has supplemental activities planned to define better what the extent of the CS-19 plume is. Mr. Clemens explained that the contamination is not like a big blob, but it is a bunch of little distinct sources that generate their own particle tract and their own distinct areas of contamination. As they get more data in, they will be able to figure out the bounds on different sources in different areas of contamination that result from those sources.
Mr. Clemens continued on, stating they have started drilling in the J Ranges. There is profile data that shows trace levels of DNT, extremely low sub ppb detection in the profiles. They continue to study well screens with Agency input, but they need to get real data out of the well screens before they determine what exactly appears to be in the groundwater. The low levels of DNT discovered is not inconsistent with what they have seen elsewhere. There is a lot of interference between materials that are being drilled and until they have the real wells with validated data they do not want to draw conclusions from the trace amounts detected.
Mr. Clemens indicated that there has been more work done in Demo 1 and the source of contamination that has resulted from that. Fences were put up to detect the width of the Demo 1 plume. At the last IART Mr. Grant reported MW-114 installed that indicated an (Royal Dutch Explosive) RDX level of 125 ppb which has led them to look farther south. MW-D1P1 has been installed and the profile data from that boring that shows somewhere between .5 and 1.2ppb in the profiles of RDX. They think this is a good indication of the lateral extent boundary of the Demo-1 Plume. With the agencies concurrence of that data, they are moving ahead with installation of MW's D1P2. D1P2 is down gradient from D1P1 and located where they think is the center line of the plume, drilling has begun. In the future they will gather more data from D1P1 which is now called MW-129, and Ogden will report that data at the next IART meeting. They continue to investigate Demo Area 1 to determine weather they are at the down gradient extension of the Demo 1 plume.
Mr. Clemens stated most of the soil data coming in is associated with the number of open detonation that have occurred of UXO that have been found in the J-Range and K-D Range investigations associated with the RRA presented earlier by Mr. Veenstra. Soil sampling from these areas of open detonation was non-detect. Data is starting to come in from J-Range soil investigations. Presently they are detecting exlosives at fixed firing points and elevated levels of metals such as copper (Cu), lead (Pb) and Berellium (Be) from disposal areas they have been characterizing. As the data comes in the Agencies will be briefed at the weekly Tech Meetings and presented at the IART meetings.
Mr. Walsh-Ragowski asked if they know what military activities Be is associated with. Mr. Clemens stated it is associated with different metals of munitions but does not know exactly which part that is. The munitions report completed a couple of years ago probably flags a number of the metals that have been used in different munitions.
Mr. Clemens moved forward with the final item of his presentation, which was an AI having to do with questions raised on former and current ASP. In August the draft sampling plan was submitted for review of the former ASP located near the Campbell School. The former ASP was identified as part of the ASR as an area for characterization and data points for what might have occurred there. With the agencies, it was agreed upon a number of locations for soil samples associated with concrete pads at the former ASP igloos. A monitoring well put downgradient from those areas to see if there is anything there of concern. Once the approval of the EPA is given, the program will start sometime toward the end of this year. Regarding the current ASP the ARNG and the agencies went out last week, to assess the potential need for soil and/or groundwater work. If there is additional work needed at that location, it will be amended to the Phase IIB program which, with final approvals, is about to kick off in another month or so. Mr. Clemens asked Mr. Borci if he had anything to add as far as his thoughts from the site visit.
Mr. Borci stated at this point the EPA has asked the ARNG to start to put one together for the current ASP. He said there is no hurry, they would like to get the interview information and are starting the process slowly. The Phase IIB field sampling plans have been put together, reviewed, approved and are going to move forward. Mr. Schlesinger asked if a well could be installed Northeast of MW-113. Mr. Borci told him that down gradient of that area there is a well already slated to go in. After the current wells are complete they will propose other locations.
Agenda Item #6 Other Issues
Mr. Murphy moved forward and reminded Mr. Hugus that he had requested 15 minutes added here.
Mr. Hugus stated he wants to get an update on the LF-1 explosives that were recently in the newspaper. He would like to be notified (i.e., by email) of such discoveries so they can be prepared. Mr. Borci said he needs to direct that to Mr. Gill because it was detected as part of the IRP annual monitoring. Mr. Gill stated he brought copies of the press release that went out on that issue. It discusses what they found and what the issues are and the intention is to present at the Senior Management Board (SMB) meeting on October 25 and also at the Joint Process Action Team (JPAT) meeting in November. Mr. Hugus asked if Mr. Gill could just describe what was found and in what concentrations. Mr. Gill stated the information in the press release describes it better than he could. Mr. Hugus asked if Mr. Gill could just name one of the highest hits. Mr. Gill stated there was nitroglycerine, dinitrotoluene and dinitrobenzene and the sampling results were all below the established health advisories. Mr. Borci added that 1,3 dinitrobenzine has a health advisory of just 1ppb, and detected concentrations were below that so it is very low. Mr. Borci asked that these are all photo-diodec array (PDA) confirmed hits. Mr. Gill stated his understanding was that was used for the analytical process. Several of them indicated high interference which is why they are going out to resample for confirmation.
Mr. Hugus brought up another point that has been in the news is all the buried munitions being found in the J-Ranges. As somebody who is supposed to be representing the water public on the Cape the he wants to know who did that. It is not acceptable for no one to take responsibility for that. Another issue concerned the progress reports from the September 4 Tech meeting on page 3 it states that the Guard is concerned that too much time is being spent at the IART meetings on issues not the primary focus of the groundwater study. He wants to know who said that and what the issues were that are being discussed at the IART that are not part of the groundwater study. LTC Knott stated he will look at the minutes and get an answer as an AI.
Ms. Drake stated she wants to respond to Mr. Hugus' statement tracking munitions they have been uncovering. She thinks last month the ARNG presented information about the ASR. They are doing contracts research and have a military historian on board and have also hired a private investigator who is conducting follow up interviews of people who have knowledge of what had gone on out there. The ARNG has been able to track lot numbers of some of the munitions and are in the process of trying to track down where they were manufactured and loaded and who received those items.
Mr. Schlesinger brought up a letter that was sent to the IART this past week on the methodology for the soil background. He does not feel that the letter is adequate. It does not explain very well what it is that the contractor has proposed. His understanding on the intent of that methodology is to rely significantly on the Phase I background locations. He feels those are not located in the right spot regarding herbicides and pesticides. He prefers to include sites upwind of the base to create a background supply of Data points that doesn't only include downwind samples. Mr. Borci stated this will be added as an agenda Item at the next IART. Regarding his first question, there really isn't a lot of explanation in what was sent out and the Guard has drafted some text to go along with the proposal which is about to be sent out to the IART and the TOSC. That will give background for preparation for the next IART.
Agenda Item #7. Wrap Up, Schedule Next Meeting Date, Review Action Items
Mr. Murphy stated the next meeting is tentatively scheduled for Tuesday November 28. They are looking to locate that in Sandwich but there is not a location in as of yet.
Agenda Item #8. Adjourn
Mr. Murphy thanked everyone for attending and adjourned the meeting at 9:55 p.m.