Area Review Team
Agenda Item #1. Welcome, Review Action Items and Draft Agenda, Approval of July 27, 2000 Meeting Minutes
Ms. Frawley convened the meeting at 6:10 p.m. and welcomed the attendees. She briefly reviewed the handouts, and the team members introduced themselves.
Ms. Frawley announced that Mr. Murphy will serve as IART facilitator starting in October so that she will be able to devote more time to some water projects. She thanked the IART members for the opportunity to work with them, and said that the experience has been inspirational, educational, and rewarding, both personally and professionally.
Ms. Frawley briefly reviewed the agenda and asked if there were any changes. She noted that a request was made to have a question and answer section regarding the Upper Cape Water Supply ENF, which will be addressed under "Other Items". LTC Knott asked if Ms. Frawley is referring to the JPO Water Update. Ms. Frawley replied yes, and said that is her understanding that is the same discussion. She added that Dr. Feigenbaum and Mr. Zanis requested further clarification on the issue and had questions about well locations. LTC Knott stated that the presentation made by Mr. Grant will identify the JPO well locations, but any specific questions should be addressed to Mr. Kent Gonser, who is unable to attend tonight’s meeting. Dr. Feigenbaum asked if there was a JPO representative available. Ms. Larkin addressed the team and noted that she will answer any questions that she can, but pointed out that she is not the technical lead on the project. Dr. Feigenbaum said that the IART is not interested in a technical presentation at this point, but is more interested in policy issues.
Review Action Items
Ms. Frawley noted that this item was mailed to the IART.
Ms. Frawley noted that this item was mailed to the IART.
Ms. Frawley said that this item is on the agenda.
Ms. Frawley said that this item in on the agenda.
Ms. Frawley noted that this item will be covered tonight.
Mr. Hugus said that he would like to comment on a few action items. He first referred to Action Item #2 regarding the request he made for a written inventory of the vehicles currently stored at the UTES/Boeing Michigan Aeronautical Research Center (BOMARC) site. He said that the inventory identified at least 100 personnel carriers tucked away behind the BOMARC site. He stated that he does not think that those vehicles should be there, and noted that they have narrow tracks, which tear up the ground. He added that the vehicles continuously drive over the regional water supply. Mr. Hugus then requested that the NGB get rid of the vehicles.
LTC Bailey stated that the plan is to send approximately half of the personnel carriers to other locations, but 46 will remain on site. Mr. Hugus asked LTC Bailey if the vehicles in question are all tracked vehicles. LTC Bailey replied that the inventory list contains a combination of tracked and wheeled vehicles. Mr. Hugus asked LTC Bailey if he thinks it is appropriate to drive these vehicles over the regional watershed. LTC Bailey pointed out that the vehicles are driven on roads. Mr. Hugus stated that the roads are above the watershed. He said that the 15,000 acres occupied by Camp Edwards has been designated as the site for future water supply for the Upper Cape and he thinks that steps should be taken to protect the entire piece of land. He stated that the armored personnel carriers are damaging and leak oil.
Dr. Feigenbaum stated that he and Mr. Hugus examined the site and identified thirteen 155-mm artillery weapon vehicles. He asked LTC Bailey whether those vehicles are needed. LTC Bailey replied that he believes that eight of those vehicles will be moved, but the rest will remain. Dr. Feigenbaum asked what use the vehicles serve. LTC Bailey replied that the vehicles are used for training. Dr. Feigenbaum asked what the personnel carriers are used for. LTC Bailey replied that the personnel carriers also are used for training. Dr. Feigenbaum said that he does not understand how the personnel carriers could be used for training. He added that he looked at the areas where personnel carriers had been driven and found that they crush everything in their paths; they disturb the soil, and make a mess. He asked LTC Bailey what kind of training is taking place with the personnel carriers. LTC Bailey explained that the personnel carriers are used for crew and operating training. He added that some of the vehicles belong to the engineer battalion, and are used for their training. He stated that the vehicles only operate on approved roads, and do not enter the wetland areas. Dr. Feigenbaum asked who is monitoring the training activities. LTC Bailey replied that the Integrated Training Management Program oversees the training to ensure that the environment is not damaged. He added that the site will be closed to training or remediated if damage occurs.
Dr. Feigenbaum asked LTC Bailey if he is familiar with the little white pots that are under the personnel carriers. LTC Bailey explained that the pots are preventative in nature to ensure that oil or other things are not leaked onto the ground. Dr. Feigenbaum stated that the pots are overflowing. LTC Bailey reported that DEP conducted an inspection of the UTES and found no major deficiencies. Dr. Feigenbaum said that he does not consider equipment that is dripping oil on an unpaved surface to be of minor concern. Ms. Drake explained that Mr. Henry Cui conducted a site inspection about a month ago. She also noted that a monthly inspection program in place. She said that an improved set of oil pans has been ordered. She stated that Mr. Cui found no large environmental problems and concluded that the UTES is not a particularly severe situation. She said that she believes that there is a plan to repave some areas, and added that it seems to be a fairly well-cared-for situation.
Dr. Feigenbaum thanked Ms. Drake for the second-hand report, and suggested that she and Mr. Pinaud visit the site because he (Dr. Feigenbaum) thinks it is a mess. He said that there is pavement that is actually melting away because so much oil has dripped on it. Ms. Drake said that she will discuss the matter with Mr. Cui and report to the IART. Dr. Feigenbaum stated that he thinks somebody has to take responsibility for cleaning up the site.
Ms. Garcia-Surette asked whether the UTES situation will be addressed through the Master Plan. Mr. Cody replied that one of the issues in the Master Plan is the relocation and construction of a new UTES, that includes a secondary containment pad, which will have oil/water separators designed to catch any runoff. He added that funding also is available for demolition of the BOMARC site, which was abandoned by the Air Force in 1971.
Dr. Feigenbaum stated that he believes that the situation at the UTES is not so much a planning issue as it is a regulatory issue. He said that pollution is happening right now, and it should be addressed and not held hostage to the funding of some hypothetical Master Plan.
Ms. Crocker stated that she has spoken to personnel who work at the UTES. She suggested that concerned IART members ask for a briefing on the activities that occur at the site. She said that she believes that there is not another automobile site on Cape Cod that is treated as carefully as the UTES.
Mr. Hugus noted that Action Item #3 refers to the request for a current ASP inventory. He noted that the Guard is self-proclaimed to be the best steward of the environment at Camp Edwards. However, Adjutant General (AG) Keefe has denied Ms. Mindy Lubber’s request for an inventory of the ASP because it is a security issue. Mr. Hugus stated that he disagrees with GEN Keefe and thinks that the citizens have a right to know what is in the ASP. He pointed out that the IART will later discuss contamination from the old ASP, due to its drainage system, which is the same type of drainage system on the current ASP. He said that if the Guard wants to live up to its claim of being the best steward of the environment, it should provide a current inventory to the citizens who are concerned about their future water supply.
Mr. Walsh-Rogalski stated that EPA received a response from the Guard, which included an inventory of items that were shipped out of the ASP, but did not provide adequate information to determine what was left in the ASP. He said that the inventory is very difficult to interpret, and EPA requested a more straightforward inventory. He reported that the Guard has made some efforts to provide a current inventory to EPA, but has requested that EPA not share the information with the public. He stated that EPA is not willing to withhold the information from the public. Mr. Walsh-Rogalski said that EPA has requested that the Guard at least state categorically that there are not certain types of items in the ASP. He said that the issue is being worked.
Mr. Schlesinger said that he thought that certain people had clearance to the ASP, and asked why they could not address the situation. Mr. Walsh-Rogalski explained that it is not really an issue of clearance. He explained that the Guard is willing to pass the information onto EPA, but with the condition that it is not shared with the public, which EPA is not willing to do. Mr. Schlesinger asked if there is a response to the request he made at the last IART for a list of the constituents of concern. LTC Bailey replied that the situation is in legal hands right now. He noted that he did request that a list of constituents be considered.
Dr. Feigenbaum asked Mr. Walsh-Rogalski if the ASP inventory issue has been discussed in Washington, D.C., or whether the decision was made by the Adjutant General. Mr. Walsh-Rogalski replied that GEN Keefe made the decision. Dr. Feigenbaum clarified that this is not a Pentagon policy issue. Mr. Walsh-Rogalski replied that that is his understanding. LTC Bailey said that he believes it was a decision made by GEN Keefe, but that he does not know to what level the situation has been elevated.
Dr. Feigenbaum asked Mr. Pinaud and Ms. Garcia-Surette to address this issue through Secretary Durand’s office and the governor’s cabinet because the AG works for the Secretary of Public Safety and therefore could be countermanded.
Mr. Hugus asked if a decision has been made about who will present CS-19 data. Ms. Frawley noted that this question will be addressed during the next agenda item.
Mr. Zanis referred to Action Item #7 and stated that the area in question was located.
Approval of Minutes
Ms. Frawley asked if there were any changes to be made to the July 27, 2000 meeting minutes. Ms. Dolan referred to the third paragraph on page 15 and noted that the extent of the geophysical survey on the J-2 range is approximately 35 acres, the J-1 range is about 70 acres. Mr. Grant referred to the third paragraph on page 13 and stated that Mod-flow should be written MODFLOW and suggested inserting "groundwater model" after that word. The minutes were approved with the suggested changes.
Agenda Item #2. CS-19 Briefing
Mr. Aker informed the IART that the position stated by AFCEE at the last meeting has not changed. He said that the CS-19 presentation will be made at the Joint Process Action Team (JPAT) meeting, and Mr. Gill will take any comments made at that time to Col Coke.
Mr. Walsh-Rogalski stated that although Mr. Grant makes great presentations, EPA thinks that presenting IRP data is not the most efficient use of his time. He said that EPA is dismayed that the IRP and AFCEE, which prides itself on community involvement, will not address concerned citizens at the IART.
LTC Knott stated that he agrees that Mr. Grant does a great job at presenting.
Mr. Hugus noted that he is a JPAT member, and he saw the CS-19 presentation made by AFCEE at its last meeting. He said that he thinks it is too bad that all IART members were not able to hear the presentation, and it is unfortunate that AFCEE has chosen not to cooperate directly with the IART. He also stated that he believes that the JPO is also at fault as it was established to coordinate all activities and ensure that there are no arbitrary separations of sites. Mr. Hugus added that the public does not differentiate between whose bureaucratic responsibility a site is, but is interested in coherent information about the damage to groundwater. He stated that this "turf war" between AFCEE and the Impact Area Study upsets the years of work that have occurred trying to establish a good relationship between cleanup managers and the public, which, for many years, has been disappointed at the lack of information and honest presentations.
Mr. Hugus stated that there are many absurdities involved with there being an important site within the Impact Area, about which the IART can not make meaningful comments. He noted that a recent map released by the IRP depicts all the delineated plumes, including CS-19. However, it appears to the public that the only problem in the Impact Area is CS-19 since Demolition Area 1, the J-Ranges, and the Central Impact Area data are not included on the map. He stated that the public thinks it is ridiculous that there is any separation between AFCEE and Army sites. Mr. Hugus further remarked he thinks it is absurd that IART members have to attend another set of meetings to learn about CS-19. He said that he thinks the decision made by AFCEE is ridiculous and should be changed.
Dr. Feigenbaum said that it is also his misfortune to be a member of both the IART and the JPAT. He stated that there is a lack of consistency in the method of drawing plumes. He pointed out that AFCEE is holding to its time-worn policy of drawing plumes at the maximum containment level (MCL) of the boundary and not at the non-detect level, which was an excellent innovation introduced by Ogden Engineering. He said that he has requested that future AFCEE maps reflect non-detect contours as well.
Dr. Feigenbaum then said that he wants to inform the team about some discussion that took place at the JPAT meeting regarding how the decision for AFCEE not to present to the IART was made. He reported that Mr. Minior stated that the project managers advised Mr. Gill. Dr. Feigenbaum noted that Mr. Gill had the courtesy to contact him the day after the last IART meeting, at which time Mr. Gill confirmed that the project managers advised him. However, Mr. Pinaud and Mr. Marchessault disavowed that they had advised on or agreed with the decision, which creates a problem of credibility. Dr. Feigenbaum said that he asked Mr. Gill at the JPAT meeting if he was willing to change his mind and allow AFCEE to present to the IART; however, Mr. Gill replied that the issue is being handled in San Antonio. Dr. Feigenbaum stated that he thinks it is time for Mr. Gill to get off on the right foot and start getting in step with the community.
Dr. Stahl stated that TOSC members need CS-19 data because that site is one of the more significant areas of contamination. Mr. Aker pointed out that all CS-19 data are immediately supplied to Ogden Environmental as soon as they become available.
Mr. Zanis asked why AFCEE is represented at the IART table if its representative is unable to speak and give a presentation. He also asked the NGB, as the steward of the environment, to pressure AFCEE to make the presentation because there could be some crucial information that Mr. Grant could miss. He stated that he thinks it is only right that the citizens receive CS-19 reports and presentations properly, and without game playing. He then asked Mr. Aker why he attends IART meetings. Mr. Aker replied that AFCEE is at the table to supply information about which Mr. Grant might not be aware, to clarify technical issues, and to bring IART comments back to the IRP.
LTC Knott pointed out that CS-19 will be included in the Investigations Update and is a key part of the briefing.
Mr. Hugus stated that he is interested in a separate CS-19 presentation. Mr. Grant explained that the CS-19 investigation results are incorporated in with the rest of the groundwater and soil results. Mr. Hugus stated that AFCEE spent 25 minutes discussing CS-19 at the JPAT meeting, and displayed an interesting plume map. Mr. Grant said that he is not sure if that map is included with tonight’s handouts. He did note, however, that there is a map that depicts the extent of RDX for the Impact Area, which includes CS-19. He said that he will address how the Impact Area contamination envelops the CS-19 contamination, which makes it difficult to draw distinctions between. Mr. Hugus commented that the Central Impact Area plume is involved with the CS-19 plume, which is another point of absurdity for separation. He said that another problem is that AFCEE wants to do its own munitions survey, and efforts will be duplicated. He reiterated that he would like to see the same presentation that was made at the JPAT meeting.
Agenda Item #3. Munitions Update (see attachment #2.)
Mr. Montroy stated that he is going to give a brief presentation on some of the major activities that have occurred since the last IART meeting.
Data Validation Task in Demolition Area 1 and Gun Positions 10 and 11
Mr. Montroy displayed a photograph of Demolition Area 1 and stated that approximately 12 acres have been cleared. He pointed out the Uplands Area and the central depression. He noted that a sub-surface geophysical survey was conducted and the map, which was peppered with many anomalies, was shown at the last IART. He said that first the sub-surface anomalies are ranked from the highest to the lowest signal. He noted that five or six anomalies were chosen for excavation, which began about three weeks ago. However, 25 anomalies were excavated, rather than the five or six, in both the Uplands and Basin areas. Mr. Montroy reported that hand digging tools and a small track excavator were used. He explained that the majority of the anomalies contained many items, including targets, rolls of razor wire, railroad rails, and even a General Electric refrigerator. He said that two 750 pound general purpose practice bombs were detected, as well as eight 3-½ inch practice rockets, one 155-mm practice projectile, and one 175-mm (seven inch projectile) that will be blown in place tomorrow. He stated that a technical memorandum will be distributed to the regulators next week, which will include an analysis of the 25 anomalies. Mr. Zanis asked how many acres were covered. Mr. Montroy replied that the 25 anomalies were found in approximately 12 to 13 acres.
Mr. Montroy then referred to gun positions (GPs) 10 and 11 and reported that the threshold was raised to detect the bigger anomalies. He reported that 94 anomalies were detected at each GP. He noted that GP-10 was examined first and that UXO personnel first dug down one foot using hand tools in an attempt to locate the anomaly. He said that excavation would stop if an anomaly was found and if hand-held detectors indicated that there was nothing else there. However, if the anomaly proved to be lower than one foot, a small excavator was brought in. He stated that the excavator was used at approximately two-thirds of the sites at GP-10, whereas one-third of the sites yielded the anomaly within the first foot. Mr. Montroy stated that mostly metal debris, such as nose rings and bands from boxes, have been found. However, a supplemental booster charge also was discovered, which was used to provide more boost to a projectile from a 155-mm machine gun. He noted that work has recently begun at GP-11.
Mr. Montroy stated that there are a few locations in the Uplands Area that are under investigation and appear to have been a demolition area. However, excavation is not taking place at this point because Ogden plans to conduct soil sampling in the area.
J Ranges Task Progress
Mr. Montroy reported that work is ongoing at all three J-Ranges. He noted that J-1 and J-3 are the newer sites of investigation and have a much larger surface area. He explained that the concept of the munitions survey project is to locate buried caches of munitions or burial pits. The first step is to clear the UXO from the surface and then conduct a sub-surface geophysical survey, which includes the removal of vegetation. He commented that removing vegetation is a time-consuming and difficult effort. He stated that an innovative approach is now being used at J-1 for clearing vegetation. He then displayed a picture of the tracked excavator that is being used, which has a rotating head that is like a drum with teeth. He explained that the drum is swung back and forth and literally chews the trees down. Mr. Montroy said that the method used for clearance prior to the introduction of this excavator included four or five teams using chainsaws and weed-whackers. He added that the new instrument being used is safer and is 16 times faster than the original method. He showed a 20-second movie clip of the excavator in action. He noted that the excavator does not penetrate the ground and functionally does the same job as the chainsaws and chippers. He added that so far, J-1 appears to have a relatively clean surface.
Mr. Montroy reminded the attendees that last month he displayed a map depicting the results of the airborne magnetometer (airmag). He reported that since the last meeting the items that were detected are being geo-located. He said that the data are helping to locate areas where there will most likely be a lot of geophysical noise.
LTC Knott asked Mr. Montroy to identify what has been found. Mr. Montroy referred to the map and pointed out the various locations of some metal plates, a refrigerator, a concrete berm with reinforcement rods, and a concrete wall. He pointed out the disposal area and reported that there is nothing large on the surface.
High-Use Target Area Update
Mr. Montroy explained that the purpose of this project is to determine how UXO and UXO related materials (UXORM) are distributed and what the physical characteristics are both on the surface and sub-surface in a high-use target area (HUTA).
Mr. Montroy stated that the HUTA consists of a 4-acre site and noted that items on the surface have been removed and catalogued. He explained that six 10,000-square-foot test plots will be selected and will be excavated like an archeological dig in three-foot lifts.
Mr. Montroy reiterated that the surface clearance of the HUTA is complete, and noted that 740 items have been catalogued. He said that 150 items, including 50 UXO, 50 UXORM, and 50 pieces of debris, have been selected for further sampling. He stated that the sub-surface geophysical survey was conducted and two of the six test plots have been chosen. He explained that two feet below the surface will have to be cleared in order for the heavy tracked equipment to move back and forth safely. He noted that construction for the first test plot will begin within the next ten days.
Mr. Montroy explained that the four acres of the HUTA consist of 16 sub-grids, and every item has been located, photographed, and catalogued using the United States Army Corps of Engineers (USACE) criteria. He displayed a map of the HUTA and pointed out that anomalies are scattered throughout the area. He explained that personnel take field notes and create drawings of everything that is found. The data is then fed into the Geographic Information System (GIS) for future use. He referred to the map and stated that there are three pieces of data for each dot: a photograph, its location on the grid, and a drawing. He noted that more information will be added to each item as it becomes available. Mr. Montroy reported that currently the 150 items are being wiped down and analyzed for explosive residue. He added that all the data are being incorporated in the GIS, which means that they are retrievable, and instantly related back to a place and space.
Dr. Stahl asked Mr. Montroy if he knows whether the item that will be blown in place in Demolition Area 1 contains high explosives (HE). Mr. Montroy replied that all he knows is that uniformed military made the decision that the item should be blown in place. LTC Knott explained that the explosive ordnance disposal (EOD) team determined that it was not safe to move the item. Dr. Stahl said that the reason he asked about HE is because he is curious about the source of HE is Demolition Area 1, and wondered whether the item in question could be the source. Mr. Montroy replied that the same kind of data collecting will take place in Demolition Area 1 as in the HUTA.
Mr. Walsh-Rogalski asked Mr. Montroy to provide a general characterization of what he is seeing in the HUTA in terms of UXO and UXORM. Mr. Montroy replied that he is finding exactly what one would expect to find in an impact area. He said that 10% (approximately 70 to 75) of the 750 items are considered to be UXO, according to the USACE definition. He added that 10 of those items were considered suspect enough to contain HE that they were blown in place. The remaining items have been moved to a safe handling area. Mr. Walsh-Rogalski asked whether the UXO items that have been found are pitted, corroded, or cracked. Mr. Montroy replied that it is too soon to tell.
Mr. Schlesinger asked Mr. Montroy whether he knows if the soil at the sites that were surveyed has been disturbed. Mr. Montroy explained that historically GPs have disturbed soils because they were used up until a few years ago. He also said that while it is hard to tell in Demolition Area 1, he does not believe that any areas appear to have been excavated recently. He added that recent disturbances have not been detected in the HUTA.
Mr. Hugus inquired about the percentage of rounds that were sent to the detonation chamber, versus the rounds that have to be blown in place. Mr. Montroy reiterated that 750 items were identified in the HUTA. He said that 59% (approximately 400) of those items have been defined as UXORM, based on USACE criteria, which means that the piece of fragment is recognizable as having been part of a projectile. He reported that 29% of the 750 items were classified as debris or fragments that could not be associated with a particular projectile type. He said that 12% (approximately 76) have been classed as UXO, ten of which had to be blown in place. The remaining will be or have been sent to a safe handling area. Mr. Montroy explained that the decision to blow in place is made by uniformed military on site; then an incident report is filed and the item is red flagged. Mr. Hugus stated that he is interested in minimizing the amount of blow in place activity because it presents new problems to the environment.
Mr. Hugus pointed out that the UXO Survey will discover a lot of munitions, and asked whether the detonation chamber has the capacity to handle them. Mr. Borci explained that the Groundwater Study Office is rated for a certain net amount of explosives that can be held at one time, which is currently at full capacity. However, the Guard is going to ask the Department of Defense Explosive Safety Board (DDESB) to approve a larger net explosive weight storage capacity. He said that he believes that 13% of the identified UXO, prior to the 81-mm cache, were blown in place, which is a pretty low percentage. Mr. Hugus asked whether the full net capacity could lead to work stopping on the UXO survey. Mr. Borci replied that he believes the munitions would be left in place until there is room in the handling area. Mr. Hugus pointed out that work would stop if munitions were left in place on a future drill pad site. Mr. Borci said that that is correct, but pointed out that the Guard is trying to manipulate the schedule to match where work can and cannot take place.
Mr. Hugus asked if EPA is proposing that the Guard acquire a second chamber as a solution. Mr. Borci stated that the chamber was down for a period of time, but should be caught up within a week or two, and should be able to keep up with the rounds that are found throughout the base. Mr. Hugus asked whether a second chamber is being considered to handle the volume. Mr. Borci replied that the concern is not for a second chamber to handle the volume, but to handle larger rounds, which cannot be detonated in the current chamber. He noted that there are approximately twelve items that are 155-mm and larger, and cannot be sent to the chamber, and he expects that more will be found in the HUTA. Mr. Borci noted that the Guard said that it would find a larger chamber if deemed necessary, and he believes the need has been demonstrated.
Mr. Hugus stated that the Guard originally was asked to provide a detonation chamber that would handle 155-mm rounds. He said that he is concerned that 155-mm rounds that are considered safe to move will be blown in place because there is not a chamber available. Mr. Borci stated that to date there are 12 items that match that description. He reported that EPA just received a proposal from the Guard to take those items to some of the grids at the armored personnel carrier, which already are contaminated and scheduled for excavation by the end of the month, and blow them in place. Currently EPA is discussing whether to approve that procedure. He stated that acquiring a second chamber will take some time, and it might be the best option safety-wise to detonate the rounds now in an area that will be excavated and treated in the near future. Mr. Hugus stated that he hopes that it does not take another three years to obtain a second chamber.
Mr. Hugus asked Mr. Montroy if Tetra Tech was involved in the discovery of the two bombs at Demo Area 1. Mr. Montroy replied that the bombs in question were identified as geophysical anomalies, and an incident report was filed. He said that the Guard was notified, at which point the Air Force took over ownership of the two items.
Mr. Hugus asked Mr. Montroy if he thinks that Demo Area 1 has been back-filled. Mr. Montroy replied that it is possible, but also said that he will defer to the technical memorandum that is scheduled for release. He referred to the depressed area and said that it is probably more likely that bulldozers were used over a period of years to create new flat surfaces to do effective open burn open detonation (OBOD). Mr. Hugus said that the area would have to be excavated further if it has been back-filled. Mr. Montroy stated that that is occurring and reported that all the anomalies have been removed in their entirety to the point where a signal was not detected. However, pieces of wire were left behind because the UXO Health and Safety Officer decided that the razor wire presented a health hazard.
Mr. Borci stated that he believes it is clear that the current surface elevation of Demo Area 1 is not the historical surface, and it has been deeper in the past. He said that the full extent of some of the activities that have occurred there are unknown. However, the validation effort at Demo Area 1 will help to solve this issue. Mr. Hugus stated that Mr. Zanis deserves credit for informing the team that this area had been back-filled, back when COL Murphy and CAPT Boggess were at the Massachusetts Military Reservation (MMR).
Dr. Feigenbaum asked Mr. Montroy if the twelve 155-mm rounds were located on the surface. Mr. Montroy replied that all of the 76 UXO items that were discovered were on the surface or immediately underneath the surface. Dr. Feigenbaum asked if the items that were immediately beneath the surface were protruding above the ground. Mr. Montroy replied that the items in question could be seen physically. Dr. Feigenbaum clarified that so far almost everything has been on the surface. Mr. Montroy stated that so far everything has been on the surface.
Dr. Feigenbaum said that he is not clear about the overlap regarding the use of the following three technologies; the magnetometer, electromagnetic conductance, and the airmag. Mr. Montroy explained that the airmag is comprised of three separate sesuim vapor magnetometers affixed to a helicopter. Dr. Feigenbaum asked if all three technologies are used. Mr. Montroy stated that only the electromagnetometer 61 (EM-61) was utilized in the HUTA, due to the surface area. He explained that the EM-61 is located on a cart, which allows for it to maintain its distance from the surface in the heavily pock-marked HUTA. Dr. Feigenbaum asked if the helicopter is used to identify buried objects. Mr. Montroy replied that the helicopter will detect buried anomalies down to a certain size. Dr. Feigenbaum asked Mr. Montroy to what depth the helicopter can detect objects. Mr. Montroy replied that the depth of detection varies on how high above the ground the sensors on the helicopter are. He explained that there are areas within the Impact Area comprised of scrub oak vegetation and the helicopter could fly four to five meters above ground. However, there are other areas within the Impact Area where there are more mature trees and the helicopter had to fly higher above the ground. He explained that the sensitivity of the helicopter was tested by flying it over Jefferson Road at varying heights where specific items were placed. He added that the data from the test will be used to determine what is the smallest object that can be detected at different heights.
Dr. Feigenbaum stated that he read an item on the Internet regarding an airborne magnetometer survey that was conducted in the Badlands, which claimed that it is the only technology that is required. Mr. Montroy replied that it is probably true that an airmag survey is the only technology needed in the Badlands because of the wide-open spaces. He stated that the exact same helicopter, sensor device, and pilot were used in both the Badlands and the Impact Area. Dr. Feigenbaum stated that the information he read generalized that this technology can be used throughout the country. Mr. Borci reported that he attended a conference where a draft presentation on the Badlands data was given. He said that he then asked the Guard to consider utilizing this technology. He added that the desired goal of airmag is that it will limit the number of places where vegetation has to be cleared. He noted that it already has proven to be an effective tool at MMR.
Mr. Schlesinger asked if there is a facility in the mid-west that can handle 155-mm rounds. Mr. Walsh-Rogalski replied that there are a few facilities in the country that are capable of detonating 155-mm rounds; however, the rounds on base cannot be moved. Mr. Schlesinger asked why the rounds cannot be moved again. Mr. Walsh-Rogalski said that he believes that a round cannot be moved off base once it has been fired. Mr. Schlesinger asked LTC Knott why previously-fired rounds cannot be moved off base. LTC Knott said that he does not know, but he will find out and report to the IART.
Agenda Item #4. Investigations Update (see attachment #3)
Mr. Grant stated that he is going to provide an update on groundwater study results that have been made available since the July 27, 2000 IART meeting. He briefly reviewed the team members handouts and apologized for the fact that the explosive map does not contain the extent of RDX in the Central Impact Area. He noted that future maps will depict the extent of RDX.
Field Work and Sampling Results
Mr. Grant referred to Figure 1 and pointed out the Impact Area and a series of wells throughout the Impact Area. He noted that nine wells were installed in August 2000. He stated that Monitoring Wells 112, 113, and 115 (MW) were installed in the Impact Area. He pointed out that MW-115 is located on the south end of a transect, and MW-112 and MW–113 are located at the north end of the same transect. He reported that wells were also installed in the J Ranges, which he pointed out on Figure 2. He clarified that MW-121, -116, -117, and –119 are located in the J-2 Range and MW-118 is in the J-1 Range. He pointed out that profiling has not been completed on these wells, which are located at the water table and are stage 1 wells. He explained that subsequent drilling of the wells will include deeper profiling to characterize the rest of the aquifer and get a sense of groundwater flow direction and chemical concentrations, at which point they will be considered stage 2 wells. Mr. Grant reported that the last well installed was MW-114, which is near Demo Area 1.
Mr. Grant reported that upcoming well installations in September will be focused primarily on the J-Ranges.
Mr. Grant referred to a figure depicting the status of the groundwater sampling. He noted that he discussed the August long-term monitoring round, which was a relatively large sampling event, at the July IART meeting. He reported that the round essentially has been completed. He added that the wells that were installed between 1997 and 1999 have now been sampled five times. He stated that a fourth sampling round has been completed for the Demo Area 1 far field group 2 wells, as well as for the gun and mortar position wells. Mr. Grant said that a third round of sampling was completed on the Demo Area 1 response wells, which was not part of the long-term monitoring plan. He added that the Impact Area response wells will be sampled on a three-month interval.
Mr. Grant stated that a significant amount of time was spent on the groundwater sampling results. He said that the latest monitoring data suggests a slight change in the extent of RDX. He referred to Figure 3, and said that the map will be updated to include the RDX detections. He then pointed out the particle tracks and said that they indicate the path of groundwater at various locations in this part of the Impact Area. Mr. Grant stated that a number of wells will be installed to the west, a few in the center of the RDX contamination, and a few along the western/southern boundary, in order to piece together the extent of contamination.
Mr. Grant noted that Figure 3 also depicts a couple of transects; he pointed out A' A from north to south, and B'-B which runs through a row of wells and provides a snapshot of the location of contamination as the groundwater moves through. He noted that Figures 4 and 5 depict a depth perspective.
Mr. Hugus inquired about the two small fingers located in the northern part of the mass of plumes. Mr. Grant displayed the next transect view, and said that he has refined the depiction of the extent of contamination since last month, with the addition of two wells on the north side. He reiterated that he is referring to profiling results, and that the wells have not actually been sampled yet. He explained that the profiling results from MW-111 modified the way he is depicting the contamination emanating from CS-19. He referred to the two fingers Mr. Hugus mentioned, and said that the section view shows RDX contamination at MW-112, which seems to connect with the contamination detected at MW-98 and MW-92. However, the extent of RDX is deeper at both MW-112 and MW-113, which may be due to a separate source area. He added that RDX concentrations at MW-113 are approximately 10 parts per billion (ppb), as opposed to health advisory concentrations of 2 ppb at other locations. He explained that the plan view map depicts two separate little areas of higher contamination, one at MW-112, at about 20 to 30 feet down, and one at MW-113 at about 50 or 60 feet down.
Mr. Gregson inquired about the zones of contribution (ZOCs) for the water supply (WS) wells. Mr. Grant explained that the ZOCs on this map are estimated and are not based on the pump tests, which will be available within the next couple of weeks. He pointed out the ZOCs for WS-4, WS-5, WS-3, and WS–2.
Mr. Grant referred to the outer transect in Figure 5 and pointed out CS-19. He explained that the view to the south has changed since last month because of detections at MW-18, which is a new well installed by AFCEE. He added that there were also detections at MW-7, and a profile detection at MW-111. He said that the detection levels at the MWs are about 3 ppb, while the profile sample is about 4 ppb. He explained that the depths are a little bit different, but only about ten feet apart and the screen in between shows a lower concentration. He noted that a number of wells will be installed in the area farther south.
Mr. Borci asked Mr. Grant why explosives are not being detected in MW-7. Mr. Grant replied that he believes MW-7 was installed in 1996, at which time profiling was not done. He explained that well screens were installed, and essentially there are data gaps. He noted that samples are taken every ten feet at the two new CS-19 wells, as opposed to the well screens that are set at certain depths in MW-7. Therefore, it is possible, for instance, that there is a slightly higher RDX level just above the screen, which would connect the "blobs". Mr. Grant stated that it is difficult to say that the lines are anything close to real because the numbers vary from a ¼ ppb, which is the detection limit, to 2 ppb.
Mr. Hugus asked Mr. Grant whether Ogden has installed any wells at CS-19. Mr. Grant said that he was referring to MW-111, which is downgradient form CS-19, but was installed along the particle track for MW-37, which passes along the southern edge of CS-19. Mr. Hugus asked how this well location may enter into the ongoing jurisdiction problem with AFCEE regarding CS-19. Mr. Grant said he has no knowledge of the political issues regarding CS-19 jurisdiction. He did explain, however, that the intent of MW-111 is to determine the extent of contamination from MW-37. He said that the contamination in CS-19 does not appear to be associated with MW-37. Mr. Grant then referred to a map contained in the CS-19 RI, which he said might help to clarify the issue. He said that the map to which he is referring is labeled Figure 3.2 in the handouts. He pointed out MW-18 and MW-7, and noted that MW-111 is not included because it was installed after the draft RI was released. He then referred to Figure 5.20, which is another map from the draft RI. He noted that this map depicts the contamination originating at CS-19, which follows the typical pattern of slowing down with migration due to the vertical gradient. Mr. Grant explained that the contamination coming from the Impact Area is not shown in this figure because it is unclear how it should be depicted, given that there are not a lot of data points available. He stated that contamination from MW-37 has not reached MW-111, and in fact, it may not even have reached CS-19.
Mr. Grant stated that the draft RI indicates in its "Response to Comments" that an additional MW will be installed to the west to check on the downgradient extent. Ms. Adams noted that Figure 5.20 does not depict the RDX that is coming from the Central Impact Area and traveling adjacent to or underneath the CS-19 plume. Mr. Grant said that that is correct, and pointed out that it is difficult to depict that contamination in this view because there are not a lot of data points. He explained that there is a data point at MW-37, which shows contamination, and there are several CS-19 wells that show the shell of contamination, but none of them are deep enough – except for perhaps 58MW10 A and B – to intercept the contamination coming from MW-37. He reiterated that it is difficult to draw the extent, but said that he believes it is coming from farther back than MW-37 because it is not at the water table. He stated that the draft RI primarily depicts contours of 2 and 10 ppb of RDX. He pointed out that less than 2 ppb does not show up clearly on the map.
Mr. Zanis stated that the NGB classifies its detections differently than the IRP, and therefore the plumes are drawn differently. Mr. Grant agreed that the plumes are drawn differently, but said that he does not know if classified is the appropriate word. He added that the map he displayed is how CS-19 is presented in the draft RI report, and he does not know if there are specific reasons why it was drawn this way. He pointed out that 2 ppb was used to draw the plume because it is the health advisory. Mr. Zanis stated that AFCEE does not include Impact Area plumes on its maps; however, CS-19 is included on IART maps. Mr. Grant said the NGB does not have quite the same focus as the IRP. He referred to Figure 3, which is from the draft RI, and pointed to an area depicting levels above 2 ppb, which AFCEE depicts as coming from CS-19. He said that these detections may be coming from the same general area as MW-111. However, that assumption is preliminary because MW-111 has not been sampled yet and the data are based on profile samples. Mr. Grant stated that the draft RI was released before these profile samples were available and suggested that AFCEE may draw the plume differently now.
Mr. Schlesinger referred to Figure 5.20 and asked if the area on the left edge of the plume, which depicts 10 ppb, is indicative of a large concentration that has moved by that point, or whether it is from a nearby source area. Mr. Grant said that the area in question still is connected to the water table at 58MW02, and it does not appear to have moved away from the source area. He added that the RI states that, based on modeling, it is expected that the CS-19 plume will not persist for more than six or seven years. The fact that the plume is persisting and the concentrations are not dropping significantly suggests that there is a continuing source. He said that there is probably a source of RDX at CS-19 in the vicinity of 58MW02. Mr. Schlesinger referred to Figure 3, which shows a light yellow area upgradient. Mr. Grant explained that Figure 3 is not really a plume map, but rather a map depicting the extent of contamination. He said that it is not indicating that there is one big "blob" of RDX coming from some point farther back, but rather that there are detections above 2 ppb at these wells. He said that AFCEE has a pretty good definition of the CS-19 plume. He also said that the map in question is a long way from the plume maps AFCEE has drawn for CS-19 and from what the IART has drawn for Demo Area 1. Mr. Schlesinger asked Mr. Grant if more information is needed so that the Groundwater Study and IRP can learn from each other. Mr. Grant noted that he does not see much difference between what has been prepared by the IRP and what has been prepared by Ogden. He added that there is an effort under way to gain information about the downgradient extent. He also noted that he believes that AFCEE is planning to install a well west of 58WM18.
Mr. Borci suggested that this topic be addressed at the next technical meeting. He also suggested that Ogden create a longitudinal cross section of CS-19 that shows CS-19 in contrast to all the upgradient contamination believed to be coming down from the Impact Area. Mr. Walsh-Rogalski suggested that it would also be helpful if the NGB could draw a map of CS-19 using the same guidelines it does to draw other plumes.
Mr. Zanis stated that he thinks that the IART is trying to do the best job that it can. He noted that AFCEE is not cooperating, and two different maps are confusing to the team. He suggested that the best way to address this issue is for the Groundwater Study to assume control of the CS-19 plume. Ms. Adams stated that, after consideration, it has been decided to continue to work with AFCEE as long as the study maintains the standards that are held for the NGB. She explained that there are a lot of rules and bureaucracy within the Department of Defense (DoD) regarding a site such as the MMR because IRP uses funding from the Defense Environmental Restoration Program (DERP) and the NGB would spend its Operation & Maintenance (O & M) money. She stated that it is a bureaucratic thicket, and EPA thinks that DoD should figure it out. She said that it should not be up to EPA to figure it out how to make DoD funding and programs work. Therefore, at this point, EPA is not pushing the issue of taking over CS-19 until it is absolutely necessary.
Mr. Zanis stated that it seems that AFCEE is making a misstatement by reporting that CS-19 is going to naturally attenuate after six years. He said that this area has not been used in over 30 years and the plume is still present and it is not going to go away.
Mr. Schlesinger asked whether it would be appropriate to ask state representatives for assistance regarding this situation. Mr. Walsh-Rogalski replied that EPA is going to try to resolve this issue, but there are legal options available if the situation continues.
Mr. Minior said that if Mr. Grant presented all the CS-19 data, regardless of who collected it, all the information is there. He said that Mr. Grant’s map depicts the 2-ppb contour and in plan view the detection lines are for the analysis. He then referred to the cross-sectional view and said that if the fact that some of the data are from the IRP and some are from the Groundwater Study Program is omitted, the depiction of the detect line versus the 2-ppb line is still present. He reiterated that all the data have been shown, regardless of the fact that they were collected by two different programs. He noted that the IART is asking to see both plan and cross sectional views. However, the Groundwater Study Program has not gotten to the axial projections on the particle tracks yet, and AFCEE has done some of the particle track work.
Mr. Grant stated that he thinks the Guard is taking all the information available from AFCEE and presenting it in a slightly different format. Mr. Walsh-Rogalski told Mr. Minior that he thinks his comments are valuable, and would be even more valuable if he (Mr. Minior) was willing to make a full presentation at the next IART meeting. Mr. Minior stated that Mr. Grant already has presented all the information and there is no need for AFCEE to present it too. He explained that Mr. Grant can present the overall picture as it relates to the entire Central Impact Area and can do a better job at consolidating all the data in the format to which this group is accustomed. Mr. Walsh-Rogalski asked Mr. Minior if he would ask AFCEE to change its mind about presenting to the IART. Mr. Minior pointed out that Mr. Walsh-Rogalski has gone to higher levels than he has about reversing the decision, and it has not changed.
Mr. Zanis noted that the CS-19 study is publicly funded, and he believes that the IART deserves a presentation from the people who conducted the study. He also said that he would like a presentation from the person who claimed that the plume is going to naturally attenuate in six to seven years.
Mr. Aker stated that the draft RI indicates that the plume would naturally attenuate in six to seven years if the source were removed. It is also stated in the report that there is a continuing source. He said that the plan is to eventually eliminate the source. Mr. Zanis thanked Mr. Aker for the information, and noted that it would be nice if the IART received information like that in a formal presentation.
Mr. Hugus said that, despite what Mr. Minior said, he thinks CS-19 is going to be a continuing issue. He said that when it comes time to discuss cleanup options, there are going to be two entirely different cleanup standards to consider. He added that the IART is willing to show the entire picture on the maps it produces, but AFCEE only depicts CS-19, which is misleading to the public.
Mr. Gill stated that he thinks that it would be a duplication of effort if AFCEE presented the CS-19 data because the Groundwater Study Office is doing an excellent job at portraying the total extent of contamination. He explained that the CS-19 plume has been identified under the Federal Facility Agreement (FFA) and AFCEE will continue to provide information to Ogden. Mr. Hugus said that the public does not understand the difference between the two programs. He said that he thinks is would be a matter of honesty for AFCEE to print a map that depicts the entire picture because the public should know that CS-19 is not the only plume in that area.
Dr. Stahl, speaking as an expert in fate and transport, said that it his personal and professional opinion that the RDX would not attenuate in six or seven years, even if the source disappeared overnight. LTC Knott asked Dr. Stahl how long he thinks the RDX would persist. Dr. Stahl replied that he is not sure because he has not had a chance to study all the data. He then noted that he has studied the data from Demo Area 1, however, and there has not been a significant degradation of RDX across that plume. LTC Knott asked Dr. Stahl if there is a bare minimum of RDX concentration that indicates that it would take more than six or seven years to degrade. Dr. Stahl replied that a number of variances have to be considered, such as how fast the RDX is tracking, the age and size of the plume, and the concentrations. LTC Knott asked Dr. Stahl how he knows that six or seven years is wrong. Dr. Stahl replied that he is basing his conclusion on the data he has seen from Demo Area 1. LTC Knott noted that he and Mr. Borci spoke earlier about including TOSC members in technical meetings, and he thinks that this discussion is a good example of how issues could be ironed out before an IART meeting. Dr. Stahl agreed that it makes sense to have TOSC members attend the technical meetings.
Mr. Aker stated that the six or seven years it would take for natural attenuation applies only to CS-19, which has maximum concentrations of 16 ppb. He explained that Dr. Stahl is comparing CS-19 to Demo Area 1, which has concentrations in the hundreds of ppbs. Dr. Stahl noted that degradation follows an assentive line; the closer it gets to zero, the slower it goes. Mr. Zanis asked Mr. Grant if Demo Area 1 is being redrawn. Mr. Grant replied that it is.
Ms. Larkin stated that the JPO will work with the IRP and NGB on a map that depicts all the contamination.
Mr. Schlesinger asked if the IART has been presented with the concentrations for CS-19. Mr. Grant said that the actual concentrations are presented in the draft RI and have been mapped.
Mr. Cambareri stated that he is frustrated by all this discussion about CS-19 in terms of fate and transport. He said that it is difficult to capitalize on the knowledge of two different sets of consultants and two different agencies. He told to Mr. Gill that there should not be turf battles over public participation. He said that the team needs to deal with the science and the facts, as Mr. Minior said. He stated that the IART is here to discuss the Impact Area, which should be discussed thoroughly at one meeting.
Mr. Cambareri asked Mr. Grant about MW-113 and the northern border of the Central Impact Area. Mr. Grant questioned whether Mr. Cambareri is asking if the northern border should be in a different location. Mr. Cambareri said that it seems likely there is something more north. Mr. Grant explained that there are clean profile samples at MW-3, although they are older samples that were collected in 1998. He said that it is possible that the contamination could have moved through there, but the profile samples did not indicate that. Mr. Cambareri referred to the curlicues of non-detect within major detections, and said that that could be an explanation for MW-3 also. Mr. Grant agreed that that is a possibility. Mr. Cambareri stated that the IART has been expressing to the Guard that the northern/northwest area still is unresolved. He pointed out that the areas in question are in the ZOC for site 95-6 and approaching the ZOC for 95-15. He suggested the installation of far field wells in the 95-15 area.
Mr. Hugus concurred with the statement Mr. Cambareri made about the lack of information in the northwest area of Camp Edwards. He said that he would like to know why so little investigation has been done in the northwest section of Camp Edwards.
Mr. Borci explained that at the time, it was believed that MW-113 was located at the northern extent of the contamination. He said that it is obvious that that is not the case, and another well will be installed toward the northeast, near Groundstar 8, and further investigation will occur. Mr. Borci stated that the northwest corner has not been thoroughly studied so far because the history of activities in the area is not extensive. He said that the northwest section causes a big gap in the data, but it has not been a priority. However, the investigation is moving north as the contamination moves north. Mr. Hugus requested a presentation on the current data from the northwest section. He noted that this area could be used for future water supplies if it is clean.
Mr. Grant referred to slide 4 and pointed out that the northern extent has been refined slightly. He reported that there have not been any significant results from the J-Range wells since last month. He added that the Demo Area 1 plume will be refined a bit more because of the higher RDX concentrations that were detected in MW-114 in the southwest.
Mr. Grant displayed a slide depicting the location of MW-114 and reported that two additional wells, D1P1 and D2P2, have been proposed to help delineate the Demo Area 1 plume. He noted that the particle track does not appear to be accurate unless the source area is bigger than expected. However, the source area seems like it should be pretty well confined by the depression in Demo Area 1. Mr. Hugus inquired about the concentration level at the southern well. Mr. Grant replied that the profile level at MW-114 is 125 ppb. Mr. Zanis asked about similar levels upgradient of MW-114. Mr. Grant pointed out the area in question and noted that the particle track appears to be more accurate. Mr. Zanis asked Mr. Grant how far he thinks the contamination extends. Mr. Grant replied that well D1P2 will be installed where the toe of the plume is believed to be located. Mr. Zanis pointed out that the contamination may be drifting more toward the south. Mr. Grant said that well D1P1 will detect contamination to the south.
Mr. Zanis asked about pesticides at CS-19. Mr. Grant said that he will address that when he reports on the soil data.
Latest Soil Data
Mr. Grant displayed Figure 3.1 from the draft RI, which shows the central area of interest for CS-19 and a number of grids. He explained that each grid has five separate points, and there is a total of 25 grids are arranged across the area. He reported that the 25 grid points represent surface soil samples, and there are six borings that went a little deeper. Mr. Grant reported that the detections for explosives were limited to seven locations, which is indicated in Figure 4.2 from the draft RI. He explained that there are detections at five different grids and, one had detections at two different depth intervals. He concluded that there are trinitrotoluene (TNT) detections scattered around at fairly low levels, and RDX detections at surface and sub-surface at 58BH0003, whose boring was continued down to about eight feet or more. He added that deeper soil samples at that location did not encounter RDX; so it appears that the extent there is somewhat limited in depth. Mr. Grant noted that the boring in question went through former burn pit 6, which might account for the detection.
Mr. Grant stated that AFCEE is concluding that the extent of explosive contamination in soil is somewhat limited, and there does not appear to be a strong source for the RDX contamination. However, the modeling does suggest that a continuing source may exist. He said that he believes AFCEE is going address the source issue with supplemental characterization – perhaps in the RI process – of both UXO and the magnetic anomalies.
Mr. Hugus asked what AFCEE is doing to research the magnetic anomalies. Mr. Aker explained that Jacobs Engineering is reviewing Tetra Tech data, and the eventual plan is to excavate the anomalies. Mr. Hugus pointed out that the use of Tetra Tech data implies that AFCEE is cooperating with the effort. He noted that Tetra Tech surveyed CS-19 for AFCEE. Mr. Aker stated that AFCEE is using all the available data and the NGB also is using all the available data. He said that it is a combined effort and neither AFCEE nor the NGB is operating in a vacuum. Rather, they are operating in conjunction with one another, which is really the way it should be. Mr. Hugus agreed that AFCEE and NGB should be working together.
Mr. Hugus said that Mr. Grant mentioned that the soil detections are characterized as being limited. He asked whether he means that they are limited in concentration or in number of locations. Mr. Grant said that he meant that the frequency of detection was somewhat lower than what was expected with this apparent source of groundwater contamination. He said that a total of 91 samples were taken and only seven detections were identified. Mr. Hugus pointed out that the detections that were identified were very high. He said that the soil samples showed RDX levels as high as 520 ppb and TNT levels as high as 740 ppb. He stated that he thinks there should be more soil samples taken at CS-19.
Mr. Hugus asked if certain operations occurred at CS-19 that could have caused the high levels of explosives. Mr. Grant replied that a variety of activities may have contributed to the contamination. He noted that it is obvious that some sort of disposal took place at the burn pit. He also said that it is possible that UXO may be a contributing factor. He stated that the cause is not clear, and he believes that AFCEE is going to discuss the issue with the agencies and perhaps conduct additional sampling.
Mr. Zanis noted that Mr. Grant said that detections are dropping slightly in the groundwater. Mr. Grant concurred that detections have dropped slightly since the last round of sampling. Mr. Zanis stated that the contour of the land has changed tremendously. He suggested that the perimeter road, which is not really a perimeter road, probably prevents water from penetrating the ground. Also, the craters have been removed completely, which means there is no ponding of water to dissolve the RDX and allow it to penetrate the groundwater. He stated that he believes that the claim that the detections are dropping is not legitimate. Mr. Grant said that he does not believe that AFCEE is claiming that concentrations are dropping significantly, but that there is a continuing source, which will be examined. Mr. Grant also said that he recalls reviewing data from a four-year period, and there was not a huge number of data points. Therefore, it is difficult to identify a trend. Mr. Zanis stated that the TNT is definitely not biodegrading quickly, considering the detect of 740 ppb. He said that he thought TNT degraded much quicker than what that 740 ppb suggests. Mr. Grant noted that he believes TNT breakdown products were included in the 740 ppb detect.
Dr. Stahl asked if the RDX detections at 0003 and 0015 and asked if they were only surface soil detections, and whether the soil below the detections was sampled. Mr. Grant replied that deeper sampling was conducted for explosives and the soil was clean. Dr. Stahl asked Mr. Grant to clarify that there are many surface samples, but a limited number of bore hole samples. Mr. Grant concurred, and said that boreholes were advanced at six locations.
Mr. Walsh-Rogalski asked Mr. Grant if 2,4-DNT was detected. Mr. Grant replied that he does not know without looking at the report. Mr. Aker said that he believes that 2,4-DNT was found in a couple of samples, but it was not very widespread.
Mr. Grant reported that seven detonations were conducted in the J-2 Range on July 13, 2000, but no detections were identified in the craters. He added that approximately 129 detonations took place at the end of July in the J-2 Range, and 6 of the 24 craters had detections for explosives.
Mr. Zanis asked about the pesticides at CS-19. Mr. Grant explained that the CS-19 RI includes a risk assessment, which normally is done under the IRP to assess the potential risks to human and ecological receptors by the contamination that was detected. He said that the soil concentrations did include pesticides, but they did not pose an unacceptable risk from a human health standpoint. However, there is a marginally unacceptable risk to a particular bird species from an ecological standpoint. Mr. Grant reported that the main unacceptable human health risk was posed due to the assumed exposure through groundwater. He explained that it is based on the assumption that someone is drinking the groundwater that is contaminated with these levels over a long period of time. He pointed out that the risk is associated with explosives, and not with pesticides or herbicides in the groundwater.
Mr. Hugus requested that IART members be provided with a copy of the draft RI report for CS-19, given that he was not aware of the risk assessment. He then asked Mr. Grant if pesticides were detected in the groundwater. Mr. Grant replied that he believes pesticides were detected in groundwater. Mr. Hugus asked why pesticides would be detected in groundwater. Mr. Grant replied that it depends; however, the pesticides probably are the result of disposal or use of pesticides in the area. Mr. Hugus asked at what depth the pesticides were detected. Mr. Grant replied that they were detected at the water table, which is about 100 feet. Mr. Hugus asked Mr. Grant if he is suggesting that the pesticides traveled straight down into the groundwater beneath CS-19. Mr. Grant replied that that is possible, if the concentration is high enough. He added that it is also possible that the detections were not really there, because pesticides are one of those problem compounds, with which the laboratory sometimes has difficulties. Mr. Aker agreed that many variables could have contributed to the pesticide detections. He noted that it has been reported that there were, at one time, standpipes in the area, which went approximately 75 feet into the ground. He explained that chemical contaminants and, possibly, pesticides were disposed of in the standpipes.
Mr. Hugus again inquired about the IART receiving a copy of the draft RI report for CS-19. Mr. Gill stated that the RI report will be distributed to the information repositories when it becomes final. Mr. Hugus pointed out that the IART is accustomed to receiving similar documents in the mail. LTC Knott agreed to include the final RI report in a mailing to the IART.
Mr. Zanis asked Mr. Aker if the dichlorodiphenyltrichloroethane (DDT) detections were at high concentrations. Mr. Aker replied that they were, and noted that the IART has received information concerning this issue before. He added that more analytical data will be available at the next JPAT meeting. Mr. Zanis asked Mr. Aker if he knows the concentration levels. Mr. Aker said that he does not know then offhand, but recalls that they seemed to be fairly high for the depth. Mr. Zanis asked Mr. Aker to confirm the contamination could not have gotten there from the surface. Mr. Aker replied that most pesticides are immobile once they reach soil, and it would be difficult for them to move that deep.
Latest UXO Findings
Mr. Grant referred to Demo Area 1 and reported that two 750-pound bombs were uncovered at Demo Area 1. He explained that one of the bombs was empty and had an inert fuse and the other was filled with concrete and did not have a fuse. He stated that both rounds will be cut up and disposed of as scrap metal. He noted that other smaller finding were detonated at various locations.
Summary of Phase II(b) Field Sampling Plans
Mr. Grant referred team members to the last map in the handout, which is from the Feasibility Study (FS) workplan and shows the locations of most of the areas of interest. He explained that 12 areas were identified in the Phase II (b) workplan as needing further investigation. He reported that these sites include a couple of inactive demo sites that were formally used along Frank Perkins Road; the former anti-tank gravity range; training area BA1; the former grenade courts; Demo Area 2 on the north side; mock village, which is near the Coast Guard antenna station; the former K Range; former ASPs; former small arms ranges Bravo, Charlie and Delta; and the former E Range, which is a moving target range. Mr. Grant added that also included in the twelve areas are the former GA and GB small arms ranges, which are located near UTES and BOMARC. He explained that each area will be investigated and draft field sampling plans have been submitted to the agencies and the IART. He encouraged the IART to provide any input on the plans as soon as possible.
Mr. Zanis stated that all of the sampling points at the C Range are located on the top of the hill. He noted that the bottom of the hill as been historically void of trees, and suggested that sample points be added at the bottom near the kettle hole. He also requested sampling points where the hill drops off at the firing position, and half way from there, to the bottom of the kettle hole. He explained that at one time sheets hung at the edge of the parking lot, and personnel would shoot M-60 machine guns through the sheets. He said that bullets "went sailing everywhere", not necessarily just at the hillside targets. He added that the targets were located at the 1000-inch range, which means that the bullets were "sailing all over the area". Mr. Zanis also said that he has never found actual targets in the area, which leads him to believe that it was more like an open shooting range.
Mr. Zanis then noted that the same is true for the anti-tank gravity range. He said that bullets would impact on the hillside and as the target moved down, the bullets would impact the berm; many bullets would land short. Mr. Grant asked Mr. Zanis if he is referring to the berm in front of the track. Mr. Zanis replied that he is and noted that he believes that a lot of ordnance will be found in front of the railroad tracks and at the base of the hill.
Mr. Zanis asked if some of the sampling points can be moved. LTC Knott replied that this is being considered. He then suggested installing sampling points at the base of all the ranges. He also referred to firing positions in the former E Range and asked if there was a detection there that was not associated with Demo Area 1. Mr. Grant replied that it depends on what is meant by firing position, and then pointed out the well that had the shallow hit of TNT. Mr. Zanis commented that it is not really close to the firing position. Mr. Grant agreed and said the closest well is along Frank Perkins Road.
Mr. Borci stated that while there is not a lot of history available on the E Range, but he hopes that the supplemental archive search information will offer addition data.
Dr. Stahl stated that although he has not reviewed all the plans yet, he does have some comments that he would like to present. He referred to training area BA, and noted that there is a radioactive quarantined area that has electronic tubes. He asked what is known about the electronic tubes and whether they are likely to leak radiation. Mr. Zanis noted that he has a copy of the landfill study report for Landfill-7. He noted that the report may indicate where the tubes, which were used for radar systems, are located. He reported that one of the tubes was found in the Impact Area a long time ago. Dr. Stahl said that he is concerned about the possibility of anything radioactive migrating into the groundwater. Mr. Zanis stated that he would like to see the landfill removed.
Dr. Stahl stated that he thought the plans for the ASP and the mock village were adequate. He also said that he would like to a see a good sub-surface characterization of the anti-tank gravity site. He noted that he also has some concerns about Demo Area 2. Mr. Zanis pointed out that Demo Area 2 has not been delineated at all and there is C4 lying on the ground there. Mr. Grant stated that eight wells are proposed for Demo Area 2.
Mr. Grant asked about a deadline for the IART to submit comments about the Phase II (b) Field Sampling plans. Mr. Borci said that he has started to put together EPA comments, and would like the team members to submit any comments to him by next week.
Small Arms Sampling Plan – Phases I and II
Mr. Grant reported that the Guard revised the sampling plan to include comments made by the TOSC and IART members. He said that the current plan is to implement the soil sampling and air sampling. He noted that the air samples from the first sample, which was a small event, should be available any day. The current plan is to conduct air sampling during a heavy live-firing event of approximately 4000 rounds, and right now it appears that Charlie Range is scheduled for a live firing event on September 23, 2000. Mr. Grant said that soil sampling also will take place at the "Charlie" Range because it seems to be the only range that is getting a lot of use.
Mr. Hugus asked whether a heavy firing event took place this past summer when air sampling could have been conducted. LTC Knott replied that the Guard’s training program peaks in October, which will be the first opportunity to conduct air sampling at a firing event of at least 4000 rounds.
Mr. Hugus stated that he does not agree with the decision that IART members cannot attend the sampling because of safety issues. LTC Knott replied that the safety issue will be addressed by providing a safety briefing to interested team members, who will then be welcomed to witness the sampling event.
Dr. Stahl noted that several detonations occurred over the last month and asked about the levels of concentrations that were detected in the soil following the detonations. Mr. Grant replied that the validation process is lengthy and the data cannot be provided formally until they are validated. Dr. Stahl asked Mr. Grant when he expects the data will be validated. Mr. Grant replied that he is not sure, and noted that there is a backlog of samples due to the groundwater sampling event and the HUTA investigation.
Mr. Zanis asked Mr. Grant if the soil is sampled immediately following a detonation, when the blackened soil is still visible. Mr. Grant replied that the current procedure is to sample the soil within a three-day period, but it usually is done within a day unless there are unusual weather conditions or extenuating circumstances. He added that the location then would be covered to prevent infiltration if detection occurs. Mr. Zanis asked if the top of the soil is skimmed, or if someone "blindly scoops down six inches". Mr. Grant explained that the soils are taken based on a modified grid format. He said that there is a five-point grid, which is not scattered over 22 feet, but is contained within the crater. He added that the soils are taken from zero to three inches.
Mr. Zanis explained that he is wondering if the samples are being diluted by including too much of the "good" ground underneath. LTC Knott stated that the protocol for sampling BIP sites has been approved by DEP and EPA. Mr. Zanis asked if the protocol can be modified so that just the topsoil is skimmed. Mr. Borci stated that the Guard has to go back and complete a second modified grid of samples when detections occur, which covers a wider area. He noted that the Cold Regions Research and Engineering Laboratory (CRREL) has been conducting tests that include detonating rounds on clean snow cover and then sampling. He said that it appears that the Guard is on the right track as far as sampling protocol, but it is continually being refined. Mr. Zanis asked if it would be a problem to skim just the soil surface. Mr. Borci commented that going down three inches essentially is skimming the surface. Mr. Zanis said that he is suggesting sampling down to a half inch. Mr. Borci said that detonation releases a tremendous force and sampling only a half an inch down might miss something. Mr. Zanis said that he understands, but asks that his recommendation be considered.
Mr. Schlesinger inquired about the three-day waiting period before a crater is covered. Mr. Grant clarified that craters are covered as soon as there is an indication of contamination. Mr. Schlesinger pointed out that it takes time to validate a detection. Mr. Grant explained that the decision to cover a crater is based on non-validated data. Mr. Schlesinger asked about the timeframe for receiving an unvalidated detect and explained that he is concerned about rain pushing contaminants into the groundwater. Mr. Grant said that he is not sure if the turnaround time on those samples is four weeks or five days. Mr. Borci said that he believes it is five days. Mr. Schlesinger said that he thinks the craters should be covered immediately following a BIP. Mr. Borci said that he will discuss that suggestion at the next technical meeting and noted that he thinks that practice may already be taking place.
Mr. Hugus said that the BIP reports indicate that almost every detection is dismissable because it falls below the reportable concentration under the MCP for S1 soils. He asked DEP what S1 are and whether it feels the MCP standards are high enough. Mr. Pinaud stated that Ms. Garcia-Surette is involved in a work group that currently is reviewing reporting concentrations and cleanup standards for explosives. He explained that reporting concentrations for S1 soils is a category, which includes any area that is in a groundwater protection zone, and S1 soils have the lowest reporting standards that the MCP currently has. Mr. Pinaud also stated that a concentration above the reportable concentration requires compliance with the MCP. However, detections below the standard do not fall under the state regulatory system for cleanup laws.
Mr. Hugus pointed out that the Guard could take advantage of the low standards set by the MCP and conducts BIPs all over Camp Edwards. Mr. Pinaud said that he does not think that the MCP is a problem, and again noted that the standards currently are under review. He also restated that the Guard is under no legal obligation to clean up sites that fall below the reportable concentration. Mr. Hugus said that the Guard could detonate in open soil because it is not a legal matter according to the MCP. He stated that this is where he thinks the two programs have to work together to prevent such activities from happening. He noted that the SDWA requires cleanup to background, and he is glad that EPA has higher standards. Mr. Borci noted that all detection areas will be cleaned up under the SDWA. Mr. Hugus suggested that Ogden clarify that point in the BIP reports.
Mr. Zanis asked whether it is known what concentration level of RDX in the soil will cause 2 ppb in the soil underneath. Mr. Borci replied that information like that is part of the fate and transport modeling. He reported that EPA is working with the Idaho National Environmental Engineering Laboratory regarding the same question.
Ms. Frawley noted the time and suggested that the team postpone any remaining agenda items until the next IART meeting. Mr. Hugus asked that next month’s meeting agenda include a discussion about the comparison of the old ASP inventory to the new one.
Agenda Item #5. Other Issues
Mr. Cambareri explained that the ENF was submitted by the JPO for the MMR Water Supply Project. He said that the JPO requested a Phase I waiver in order to begin construction on the project, and Secretary Durand granted the waiver. He reported that there are still a number of permitting hurdles that the project will face such as the DEP New Source Approval Process, the Water Management Act, and permits required for water withdrawal. Mr. Cambareri stated that one piece of legislation concerning the water supply project did not pass, which will make it difficult to obtain funding to transfer water to the communities. He added that the Cape Cod Commission (CCC) submitted comments on the ENF related to the regional management of the water supply on the Upper Cape and the portion of the Sagamore lens as it relates to the communities.
Mr. Schlesinger asked Mr. Cambareri if the ENF deadline has been extended. Mr. Cambareri replied that it has not. However, the ENF included a request for a waiver of an Environmental Impact Report (EIR) to begin construction. He explained that a default extension was granted of another ten days because of the waiver, but the he was not an agreement made for an extension on the comment period.
Agenda Item #7. Wrap Up, Schedule Next Meeting Date, Review Action Items
Frawley noted that the "Rapid Response Action Plan Update"
item will be moved to October agenda. She suggested that the team
meet on Thursday, October 19, 2000. Mr. Hugus requested that Action
Item #1 be carried over to the next meeting as well. He also asked
LTC Knott when the small arms range sampling will take place. LTC
Knott replied that the event is scheduled for September 23, 2000.
Ms. Frawley thanked everyone for attending and adjourned the meeting at 9:50 p.m.