Impact Area Review Team Meeting
Holiday Inn
Falmouth, Massachusetts
April 24, 2001
6:00 p.m.

Meeting Summary

  Handouts Distributed at Meeting:

1. April 25, 2001 Draft Meeting Agenda

2. March 27, 2001 Draft Meeting Minutes

3. Status of April 24, 2001 Action Items

4. IAGWSP Groundwater Study Update

5. UXO Discoveries/Dispositions Since 01-25 IART

6. Presentation handout:  Southeast Ranges Update, April 2001

7. Presentation handout:  Small Arms Range Air Sampling at C and SE Ranges

8. Presentation handout:  Fact Sheet Update Process

9. Fact Sheet:  Corrected Findings to US Army Magnetometer of Engineer Report

Agenda Item 1. Welcome, Approval of March 27, 2001 Meeting Minutes, Review Handouts, and Draft Agenda

Mr. Murphy welcomed and thanked everybody for coming to the open house.  He noted that the Public Involvement Plan (PIP) is open to public comment and pointed out the contact names listed in the document.  He also noted that attendees may comment on the PIP during the meeting.

Mr. Murphy asked if there were any changes to be made to the March 27, 2001 Impact Area Review Team meeting minutes. Mr. Hugus asked if the minutes could be paraphrased for easy reading.  He stated that he does not believe it is necessary to have verbatim minutes.  Mr. Gregson stated that the National Guard’s position is to continue doing verbatim minutes; however, a summary of the minutes could be provided to the team members if they want.  Mr. Hugus inquired about the  purpose of verbatim meeting minutes.  Mr. Gregson replied that a verbatim transcript of the minutes would be maintained for the record, so that if there was any question as to what may have been said it could easily be looked up.  Mr. Hugus stated that it takes a long time to read the verbatim minutes and asked if the minutes could be paraphrased.  Mr. Murphy clarified that Mr. Gregson agreed to provide a summary, however, the Guard will still maintain a record of verbatim minutes.

Mr. Murphy asked everyone at the table to introduce themselves, after which he reviewed the handouts.  He noted that the members at the table have maps that were not handed out to the public; however, these maps would be displayed on the projector for everyone to see.

Mr. Gregson that he would like to discuss recent findings at Demo area 1, before presenting the “Southeast Corner of the Ranges” update.  Mr. Murphy added this item to the agenda.

Mr. Hugus stated that less than two months ago he was told that a trench was discovered at the J-Range, where 5-gallon containers containing liquid were found. He said he would like to hear more about that.  Mr. Gregson stated that the containers would be discussed during the “Southeast Corner of the Ranges” presentation.

Mr. Schlesinger asked if magnetometry results could be discussed, and noted that he was unaware of some information displayed during the open house. Mr. Murphy said that this could be discussed under “Other Issues”.  He then began to review the action items.

 Agenda Item 2. Review Action Items

Mr. Gregson clarified that the purpose of X-ing out information on the depleted uranium interview was to keep the identity of the individual and the company confidential. Mr. Hugus stated that he wanted to see the full interview because it was mentioned at last month’s meeting of a person firing depleted uranium was fired and that the complete interview had no qualifications to that statement.  He then asked if two separate interviews were involved. Mr. Borci stated that there was an initial interview and a follow-up interview, and what was provided was both interviews combined.

Mr. Hugus suggested that the person who was interviewed may have been intimidated by the attention given his testimony, and then later retracted what he may have originally said.  Mr. Hugus noted he wants to make sure that the people who step forward are treated with respect and are not “pounced upon.” Mr. Borci stated that he believes there are steps in place to prevent that from happening.

Mr. Schlesinger asked if the steel plates discussed in the interview were found. Ms. Dolan replied that there was no indication that the plates said to be fired on the J-3 Range remained. She noted that the 1000 meter-backstop that has penetrated holes is still there and was sampled.

Mr. Hugus asked if the Guard has any comment to make on the litigation between the Guard and Textron.  Mr. Gregson stated that he cannot comment on that this evening.  He noted that he is not privy to any information regarding the ongoing litigation between the Guard and Textron.  Dr. Feigenbaum asked Mr. Walsh-Rogalski if there is any legal relationship between Textron and the United States Environmental Protection Agency (EPA).  Mr. Walsh-Rogalski stated that there is no outstanding proceeding.  He noted that there are some ongoing negotiations between Textron and the Department of the Army regarding recovery for costs incurred by the investigation of the J-Ranges. 

Ms. Adams referred to the intimidation question that Mr. Hugus mentioned.  She said that she wants to reiterate that EPA is committed to getting information it needs to ensure that the study is completed. Anyone experiencing a sense of intimidation to is asked to inform the EPA that help can be provided.

Agenda Item  3.  Small Arms Ranges

Mr. Gregson introduced Mr. Deleppo, who, he noted, will be focusing on air quality information collected as part of the study, not soil impacts.  Mr. Gregson said that soil impacts are being addressed as part of the groundwater study.

Mr. Deleppo stated that Mr. Kerry LeBlanc, the industrial hygienist from the Army Corps of Engineers, is present to assist with any technical questions regarding his presentation.  He said that the purpose of the presentation is to provide a detailed  and expanded explanation of the preliminary screening of air emissions sampling performed at the C and SE Ranges at Massachusetts Military Reservation (MMR).  He noted that he will discuss the evaluation findings, and the correction that was made, and will finish with conclusions and recommendations made to the Guard based on the available information.

Mr. Deleppo stated that in July of last year EPA and the Guard performed air sampling during a live fire event of small arms using the M-16 rifle and the squad automatic machine gun.  He reported that 23,000 rounds were fired at the SE-Range, and at the C-Range 216 rounds were fired out of the M-16 rifle.  Air samples were taken via high-volume air filters, which were analyzed for contaminants and explosives.  Mr. Deleppo explained that Mr. LeBlanc performed a typical evaluation or screening process of air results from the health perspective.

Mr. Deleppo stated that the first step in the screening process is to evaluate human health inhalation thresholds.  He noted that the thresholds used were EPA risk-based concentrations (RBCs) published by Region III of EPA, the Massachusetts threshold affect levels, and the Massachusetts ambient air levels.  When compared, some of the levels were higher than the published results.  Mr. Deleppo explained that the next step was to perform calculations based on an exposure scenario using an overly protective, conservative assumption.  The results found consisted of two scenarios.  One scenario was an adult exposed to air emissions on-site for eight hours a day, 100 days per year for ten years. The second scenario was for a child exposed to air emissions off-site, eight hours a day, 200 times per year for 30 years.

Mr. Deleppo reiterated that the numbers used were overly conservative numbers, using the most protective air dispersion assumptions, to provide a worst-case scenario.  He added that although arsenic and chromium were not detected, the scenarios assumed that they were detected.  Then these values were put into the calculations.

Mr. Deleppo explained that the results of the calculations included a cancer risk and a non-cancer hazard index.  He noted that if these values are greater than one, they are examined further. Mr. Deleppo reported that the non-cancer hazard index originally was calculated to be 1.94 for the on-site and 4 for the off-site.  He noted that because the values were greater than 1, further research was required.

Dr. Feigenbaum stated that Mr. Deleppo reported 1.94 for an adult; but the table in the handout says 0.194.  Mr. Deleppo explained that during the review process of the memo, the Corps coordinated with Army agencies, the state, and EPA, and discovered that there was a math error.  The error pertained to the amount of days, the average period that was used, that is, the non-carcinogenic exposure dose formula.  Mr. Deleppo explained that the original calculation was 365 days for one year instead of ten years.  It changed from 365 X 1 to 365 X 10.  Mr. Deleppo noted the direct correlation is that the 1.94 went to .194, and added that Mr. LeBlanc would be able to explain better.

Mr. LeBlanc stated that the calculation formulas used for estimating the dose and the risks are pretty well documented by EPA and the Massachusetts Department of Environmental Protection (MADEP).  He explained that body weight goes in the denominator of the formula, which is calculated by an average period over which the exposure occurs.  He explained that the exposure is 365 X the number of years. In the original calculation, the number of years was left out. He said the Corps had done some calculations before, where it was looking for one year; however, the length between the number of years was disconnected in this particular block in the spreadsheet. The result calculated out to be only 365 days instead of 3650 days.

Dr. Feigenbaum stated that the number of years was left out of the calculation, meaning that 365 was not multiplied by 10.  Dr. Stahl remarked that whatever concentration is in the air sample is being calculated to reflect a concentration being exposed to a person every day for ten years.  Mr. LeBlanc confirmed this, however, he noted that there is another entry for the number of firing events.  Dr. Stahl asked where that value goes in the calculation.  Mr. LeBlanc replied that the number of firing events goes in the numerator, and he referred to Table 4 in the handout, which was taken from EPA regulations.

Mr. Pinaud stated that he also was confused, so he consulted his risk assessor.  The risk assessor explained that what was done wrong mathematically in the original documentation was that ten years of exposure was crammed into one year, essentially concentrating exposure over one year. Mr. Pinaud added that when he talked to the risk assessor about the corrected findings, the risk assessor thought that the corrections made a lot more sense.

Mr. Deleppo stated that with the corrected values, the calculations are less than 0.2, which is below the value of 1.  He reiterated that the data that were used for the evaluation were limited, and that is why overly protective assumptions were used.  He added that the original memo was dated March 14, 2001, and the corrected memo was distributed on April 19, 2001.  Mr. Deleppo stated that the Corps recommended that the Guard send the corrected findings to the Joint Program Office (JPO), EPA, Massachusetts Department of Public Health (MMDPH) and the Agency for Toxic Substances and Disease Registry (ATSDR) for evaluation.

Mr. Schlesinger stated that he had asked about ecological receptors at the last meeting, and he wants to add an action item to ask the Guard to address the issue of ecological receptors to both air and soil contaminants from firing events.

Dr. Feigenbaum stated that he still doesn’t understand the calculation.  Mr. LeBlanc reviewed the calculation with him again.

Mr. Dow stated that the Community Working Group (CWG) discussed the air sampling results and noted that heavy metals were one of the only things detected.  Mr. Dow then asked how 2,4-DNT gets into the soil if there is no 2,4-DNT in the rounds that were fired.  Mr. LeBlanc stated that his understanding is that there may be 1/100 of 1% of DNT in the propellant; however, there is no information to verify that.  He added that there may have been other activities conducted that involved 2,4-DNT.

Mr. Dow asked if the Army study in the combustion chamber detected any semi-volatile organic carbon  (SVOC) contaminants.  Mr. LeBlanc replied that the preliminary information indicates that there are a lot of hydrocarbons and a lot of different semi-volatiles in the bang-box results.

Mr. Borci stated that as far as he knows, the propellants/rounds that are used currently are tungsten tin ammunition, which is commonly called green ammo; however, the propellant is still the same propellant.  Green propellant is not currently used in these rounds.  LTC Bailey stated that Mr. Borci is correct.  Mr. Borci noted that this is where the 2,4-DNT source exists.  He also explained that when the bullet is fired, the heat turns the metal into gas, which is carried downwind; the excess propellant is kicked out in front of the barrel and deposited as particulate matter.  He said that the soil data match the conceptual model.

Mr. Hugus stated that the Guard’s claim that it’s using green munitions is a falsehood because the munitions are not green.  He said that the change from lead to tungsten in the bullets was an improvement; however, the propellant that drives the bullet is still dinitrotoluene, which is not good for the environment.  He added that this activity is harmful to the environment and the citizens are not in agreement with it continuing.

Mr. Hugus then stated that he accepts that Mr. LeBlanc is present tonight to correct an error he made in his report; however, he believes that the Corps and Mr. LeBlanc are going past their responsibility when they say that there is no apparent public health justification for limiting or changing the current range use policy.  Mr. Hugus stated that aside from the business of risk assessment, there is solid data from last year’s air monitoring that shows that substances like antimony, barium, copper, lead, and zinc were higher upwind than downwind.  He added that he believes that more work needs to be done by the Guard on the air emission question in order to actually protect public health. He said that he hopes the ranges on Greenway Road remain suspended for use, regardless of the corrections made to the report.

Mr. Zanis noted that he has the formulation for the propellant which he can provide to EPA. 

Ms. Crocker said that she thinks it’s wonderful to see so many citizens in the audience this evening. She urged the citizens to consider adding their expertise and interest to the team. Ms. Crocker also urged EPA to get a neutral professional to facilitate the team in order to avoid the appearance of a conflict of interest in the process.  She also thanked Mr. LeBlanc for finding the math error and correcting it.  Mr. Murphy noted that the PIP contains information on how to go about becoming part of the IART team.  Ms. Crocker said that copies of the PIP are not available at this meeting.  Mr. Murphy anyone who wants a copy of the PIP should speak to a staff member from the Impact Area Groundwater Study Office.

Mr. Dow stated that at the CWG meeting a JPO representative that said that the propellant could not give rise to the 2,4-DNT that was found in the soil.  Mr. Cambareri noted that he believes that JPO representative was Mr. Hap Gonser.  Dr. Feigenbaum remarked that it is irresponsible for a public employee to be making statements at public meetings that misinform the public.  He added that he hopes disciplinary action is taken.

Mr. Schlesinger asked if EPA has a risk assessor who could review the revised formula.  Mr. Borci stated that EPA risk assessors will review the revised calculations to make sure they are correct.  Mr. Schlesinger inquired if it is possible to revise the formula to reflect the distance of the ranges of Greenway Road to human receptors.  Mr. Borci stated that he would like to wait until more sound, scientific data are back from the Range 21 study, which is being conducted to help the Army better place ranges within installations all around the country.  Mr. Mierz stated that MDPH supports the no-use policy of the ranges adjacent to Greenway Road.

Mr. Hugus said that he is not familiar with the Range 21 study.  Mr. Borci replied that the Range 21 study, named for the 21^st century, is a program for the Army to study several different activities so it can design and maintain ranges in a more environmentally compatible manner. 

Mr. Walsh-Rogalski inquired about additional soil sampling to be done at the small arms firing ranges.  Mr. Gregson stated that the Phase IIb study has been expanded to include additional samples at some of the older ranges’ unused grids, at firing points.  He added that the sampling is ongoing.

Mr. Cody clarified that the Guard never said that what was found in the soil wasn’t or was from firing.  He added that what was found in the soil isn’t from one firing event; rather, it is from over ten years of usage at the range.  Mr. Hugus suggested that the whole history of the ranges should be examined, as well as the time it takes for dinitrotoluene to be washed through the soil into the groundwater.  Mr. Cody replied that this is why the study is not going to end tomorrow; the National Guard is going to keep doing studies.

Mr. Schlesinger inquired about a degradation study, to determine how rapidly 2,4-DNT degrades and moves into the soil column.  Mr. Borci stated that EPA has some conservative leaching calculations that give a general idea of degradation time.  Also, the Guard has done some groundwater modeling and is awaiting the results.  He added that the regulatory agencies all agreed on a cleanup level of 700 parts per billion (ppb).

Ms. Katani said that while she is very interested in contamination of groundwater, this meeting is too technical for her to understand.  She then stated she thought she heard someone refer to a nuclear material.   Mr. Walsh-Rogalski explained that what they were discussing was depleted uranium, as opposed to enriched uranium, which is used in nuclear bombs.

Ms. Garcia-Surette clarified that, as she understands it, concentrations in the soil have exceeded reportable concentrations and are already a part of the Massachusetts Contingency Plan (MCP).  She added that both MADEP and EPA are working cooperatively on this matter.

Mr. Seaver commented that he thinks that possible intimidation of a witness by EPA should be pursued vigorously if it occurs here.

Agenda Item  4. Southeast Corner of the Ranges 

Mr. Gregson reported that after installing two additional wells (D1P3 and D1P4) to better define the extent of the Demo Area 1 plume, Royal Demolition Explosive (RDX) was detected in one well positioned downgradient and consistent with depths back in the main body of the plume.  He stated that three well screens are in the process of being set - one above the main body of contamination, one at it, and one below.  The Guard is working with EPA and MADEP to come up with a response plan for additional well locations.  At present, additional well locations are being considered along Frank Perkins Road, the next step will be to look at locations along Pugh Road, which is about a quarter of a mile downgradient, to find out about the toe of the plume.

Mr. Zanis stated that he hopes the new wells aren’t installed too far downgradient from the plume.  Mr. Hugus inquired about the concentrations that were found.   Mr. Gregson replied that the unvalidated profile detections showed the highest detection to be 70 ppb.

Mr. Gregson then noted that in February the plan was to define the downgradient extent of contamination at Demo Area 1; at that time, it was thought that the two wells would be sufficient to define the extent.  However, wells are drilled to get an idea of what’s going on, and it appears that additional investigation needs to be done. 

Mr. Hugus said that he appreciates the Guard bringing this to the IART, and he hopes everybody is taking note of this.  He also said that Demo Area 1 has been investigated closely for over two years and he doesn’t understand why this is just being discovered.  Mr. Hugus stated that he believes the answer is that the Demo Area 1 area needs a more aggressive study.  Mr. Schlesinger stated that he agrees with Mr. Hugus.  He also inquired about the priority level of the site. Mr. Gregson replied that it is a high priority site, which clearly has the highest levels of RDX in groundwater.  He said that it will take more than one well to determine what is happening there, and the Guard, along with the citizens, is concerned about defining the downgradient extent of the plume. 

Mr. Cambareri stated that he believes that the lateral extent of the plume has been defined. He suggested that rather than putting wells in the lateral extent of the plume, those resources should be used to install more wells downgradient.  Mr. Gregson stated that he understands what Mr. Cambareri is saying; however, the Guard is trying to define the heart of the plume before stepping out in other directions.  Mr. Cambareri asked Mr. Gregson to identify the concentration at the inner contour of the plume.  Mr. Gregson replied that the concentration there is 100 ppb. 

Mr. Borci stated that the current approach is working well; once the southern extent is bounded, the investigation will work its way out.  He added that this is the most precise way to ensure that the best information is available.  Mr. Cambareri said that he believes the distance to Pugh Road is a good distance relative to the scale of plume identified.  Mr. Borci noted that the RDX plume is a tight, narrow plume.  He also said that RDX is a polar compound, so it doesn’t seem to disperse into the water; however, he is interested in seeing the Guard’s proposal.

Mr. Zanis asked if the plume is threatening any long-range water supplies.  Mr. Borci stated that the plume is within a zone of contribution (ZOC) for one of the Bourne water supply wells, which is why it is top priority.  He also pointed out that, the entire aquifer is a water supply; however, if a plume is within an active pumping ZOC, it gets bumped up on the priority list.  Dr. Feigenbaum asked why it is taking so long to identify the toe of this plume.  Mr. Borci replied that the well being discussed was supposed to have been the toe well.  He said that he hopes that the new toe well be installed within a month or two.

Mr. Gregson stated that the Demo Area 1 plume is a classic plume when looking at cross-sections as well.  He then reviewed the different wells that were installed over the past few years and explained where the particle tracking is going and why it has taken so long.  Mr. Gregson noted that it was discovered that the plume was probably going more south of some of the wells that were drilled.

Dr. Feigenbaum pointed out that the problem of the source area is independent of the problem of remediation downstream.  If the source area is active, and there is only a downstream remediation system, that system would run forever, unless the source area is cleaned up. 

Mr. Borci explained that from the citizens’ viewpoint the process is taking a long time, but this is because the citizens don’t see what’s happening behind the scenes.  He stated that right now the groundwater study is ahead by six months, which is probably accurate if the toe can be defined.  That is why they are going to install the new wells now.  The Guard plans to submit a draft soil report, which essentially is a remedial investigation, within a couple of months.  The process is moving forward, and there is an effort to condense it to as short a timeframe as possible is order to get the contributing source controlled, while simultaneously installing remedial measures to address the groundwater downgradient.

Mr. Gregson stated that the presentation for the southeast corner of the ranges summarizes results of investigations completed so far at the J-1, J-2, J-3 and L Ranges, as well as for the Fuel Spill 12 (FS-12) plume and Snake Pond.  He referred to the map and explained that the four flow lines indicate particle tracks for different pumping treatment scenarios.  He also noted the presentation handout includes a vertical cross-section that runs along Greenway Road and shows detections of explosives in the profile.   

Mr. Gregson stated that the major investigation work, as detailed in the July work plan, has been completed, except for the third round of groundwater sampling.  He noted that 150 soil samples were collected, analyzed, and reported, and 16 wells have been installed and sampled, 11 of which sampled twice.  Inspection of target control pits is presently being completed, and available results were summarized for the January 2001 work plan and interim data was reported in March 2001.  Work to finalize the work plan for the next phase of the investigation is continuing.   

Mr. Gregson stated that 154 soil samples and eight wipe samples were collected at the J-1, J-3 and L Ranges; also, nine wells were installed.  At the J-1 Range, 36 soil samples were analyzed, and 13 wells were installed; all but three of those wells have been sampled at least once. At the J-3 Range, 206 soil samples and thirteen wipe samples were collected, 29 wells were installed, 20 of which were sampled at least once. The data were summarized in a March 20, 2001 sampling report. 

Mr. Gregson reported that on the J-1 Range a trench was discovered that contained five buried 5-gallon metal pails.  Clean Harbors excavated this material, the cans were containerized, and samples were collected from the trench. Clean Harbors characterized the materials for hazardous constituents prior to disposal. One of the drums came back as being hazardous for toxic compound leaching process (TCLP) or leachable barium. The other two drums were non-hazardous and the soil stockpile came back as non-hazardous. The suspected contents in these drums were paint or paint residue, which is what Clean Harbors believes was originally in the cans. Mr. Gregson stated that it appears the trench was used for disposal of varnishes, paints and the like.

Mr. Hugus asked if barium would be a paint product.  Mr. Gregson replied that it would.  He also noted that AMEC collected soil samples from the trench to test for explosive compounds.  Mr. Hugus asked if Clean Harbors’ report is available.  Mr. Gregson stated that at this point just the data analysis sheets, which indicate detections of barium and cadmium are available.  Mr. Hugus asked how the material in the buckets was identified as paint.  Mr. Gregson replied that the material looked like old paint. 

Mr. Gregson then reported that the field work is scheduled to be completed in May/June, with an additional delineation work plan due in May; however, timing is being discussed with the regulators.  The results of the first phase of work will be presented in a report scheduled for September 2001 submittal. 

Mr. Gregson stated that another component of the investigation is the J Range FS-12 Response Plan, which involves additional sampling between Snake Pond and the J-Ranges.  He reported that RDX was detected in two wells near the north cove of Snake Pond.  He said that the response plan includes groundwater sampling, installation of two new monitoring wells in the north end of Snake Pond; that work is scheduled to begin in early May 2001.  

Mr. Schlesinger inquired if any particle tracks could be related back to magnetometry data collected for that area.  Mr. Gregson stated that that connection was not made.  Ms. Dolan noted that the magnetometry data are being reviewed to see if anomalies can be tied back to contamination in groundwater.  Mr. Borci added that several well locations were changed, based on magnetometry data.

Mr. Gregson stated that explosives were detected in only one well sample, from monitoring well 130 (MW-130), and perchlorate was detected at Disposal Area 2 on the J-2 Range.  He noted that the Guard is working with EPA and MADEP to finalize plans for additional sampling at other areas of potential concern.  Mr. Schlesinger inquired if the perchlorate detection was upgradient from JPO supply wells.  Ms. Dolan replied that it was upgradient of JPO’s Zone 2 area of contribution.

Mr. Gregson stated that review of soil data revealed that High Melting Explosive (HMX) was detected in soil up to 370,000 ppb or 370 parts per million (ppm), with four other propellant explosive pyrotechnic (PEP) compounds in the soil from the J-3 melt-pour building, which is located on the southeast end of the J-3 Range.  Mr. Gregson explained the key to the detections on the map handouts by noting that a yellow color represents a detection of either RDX or HMX, and green represents non-detect for the compounds. He noted that, RDX and HMX have been observed in well and profile samples at the northwest end of the J-1 Range. Locations include: the wastewater disposal area at MW-136, the steel-lined pit, MW-58, and a new well at the Impact Area boundary, MW-164. He noted that the profile sample at well MW-164 showed a level of around 70 ppb, which is significantly higher than the other RDX detections seen at the J-Ranges, which generally are less than 10 ppb.

Mr. Gregson stated that two more wells are planned for the area in the J-1 Range where the buried 5-gallon cans were discovered, and one additional well is planned at the melt-pour building location.  He also noted that there were two new recent detections of perchlorate at MW-13 at 109 ppb. Perchlorate data continue to be collected.

Mr. Schlesinger inquired about progress to address the perchlorate problem.  Mr. Gregson noted that during a recent discussion about Demo Area 1, remedial system designs were presented that handle perchlorate; those designs would include the J-Ranges as well.  Mr. Borci explained that the first step is to get a handle on the source of contamination, the next step is remedial systems, and then source removal.  He also noted that the FS-12 system was designed for fuel removal.

Mr. Gregson described what he called three fairly distinct areas of groundwater contamination that were tentatively identified south of the J-3 and L-Ranges. He noted that there is a western, an eastern, and a central area of contamination. The primary contaminant in the western and eastern areas is RDX, and the contaminant in the central area is HMX. Also, there appears to be some overlap between the HMX in the central area and the RDX in the western area, further downgradient from Greenway Road. The western area of RDX has been detected in groundwater samples from MW-132, in the center of the J-3 Range.

Mr. Hugus stated that Mr. Gregson’s plan view showed two different scenarios - one with the extraction system on for FS-12 and one with it off. He asked if everything would be captured by the FS-12 extraction system. Mr. Gregson replied that with the system on it appears that it would; however, at the flow line for MW-54 does not appear to go into the extraction system.

Mr. Gregson stated that the highest HMX concentration in a well sample detected to date was at 18 ppb at well 90WT0004, which is on Greenway Road, just downgradient of the melt/pour building. He noted that the health advisory for HMX is 400 ppb. At locations downgradient of the L-Range, along Greenway Road, the contamination is close to the base boundary. Migration off-post has not been detected; however, additional investigation is required to confirm that.  The highest RDX concentration in well samples was 9.24 ppb at MW-153, 105 feet below the water table. 

In conclusion, Mr. Gregson stated that at the J-Ranges there are multiple source areas, multiple contaminants, and a group of compounds. Explosives detected in the groundwater appear to be migrating in a southerly direction.  Detections to the north along the J-1 Range are moving in a different direction, toward the Central Impact Area.  

Mr. Schlesinger inquired about the plan to install a well in the little island in the middle of Snake Pond.  Mr. Gregson replied that negotiations with the land owner to gain access to that location are ongoing.  Mr. Hugus said that he thought at the Joint Process Action Team (JPAT) meeting that the Air Force Center for Environmental Excellence (AFCEE) reported that access to that island had been denied.  Mr. Minior stated that Mr. Robert Gill did report that information.  However, subsequent conversations with the land owner have provided resolution to the issue, and AFCEE hopes to be able to have access to that land in a day or two.

Mr. Hugus asked, given its location at the top of the aquifer, whether the contamination be going in all directions.  Mr. Gregson replied that he believes this is possible.  Mr. Borci noted that this is why it is difficult to draw plumes on a map for this location.  Ms. Dolan urged Mr. Hugus to re-read the work plan for the J-Range investigations because it details all the activities that occurred there and explains why wells are being located in certain spots.  

Mr. Hugus asked if there is any historical evidence that these compounds didn’t upwell into Snake Pond.  Mr. Gregson replied that he can’t comment on that; however, the Guard has collected surface water samples in the pond for explosives, and has not detected anything.  

Mr. Cambareri asked whether Mr. Gregson is confident that the wells in the FS-12 area were screened in the right areas to evaluate contamination from the J-Ranges.  Mr. Gregson replied that the wells were chosen specifically because they were believed to be screened at appropriate depths.   Mr. Cambareri inquired about sampling of any existing wells farther downgradient, which might account for older contamination from FS-12 areas.  Mr. Gregson stated that AFCEE is installing in a couple of wells on the southwest and southeast side of Snake Pond as part of its investigation, and will be splitting samples from those wells with the Guard.  

Dr. Feigenbaum said that he thinks the presentation needs improvement because it took him quite a while to figure out the cross-section, which is strictly determined by the way Greenway Road runs. Mr. Gregson stated that the cross-section is not perfectly perpendicular to groundwater flow; however, it does provide a representation of what conditions would be like perpendicular to groundwater flow.  Dr. Feigenbaum disagreed.  Mr. Gregson maintained that while it is not perfect, he believes that it does illustrate accurately the three areas of contamination being discussed – the westernmost RDX, the central HMX, and the easternmost RDX.  Mr. Borci stated that the cross-section that Dr. Feigenbaum is looking for exists, nut there’s not a big difference, and to illustrate the data this map serves the purpose.

Mr. Schlesinger stated that as a parent of children attending Camp Good News, he wants to make sure that there are no materials going into Snake Pond.  He then asked if the bottom of Snake Pond can be tested where the upwelling would occur.  Mr. Borci stated that the two wells, MW-101 and MW-102, which are immediately north of Snake Pond had detections about 80 feet below water table, only surface samples have been collected to date.  It is expected that data from the new well on the island in Snake Pond will show whether the contamination remains 80 feet below the water table. If it indicates that upwelling brings contamination closer to the bottom of the pond, the concern would increase.  Mr. Schlesinger inquired if testing water at the bottom of the pond can be done.  Mr. Gregson replied that it can.  He also noted that the results from the well Mr. Borci mentioned will help determine where upwelling might be occurring, if anywhere in Snake Pond.  Mr. Schlesinger questioned the source of the pond water come from if it isn’t coming from upwelling.  Mr. Gregson clarified that the pond is fed by groundwater; however, the depth of contamination being seen in the wells just to the north might be deep enough that that particular groundwater does not enter the pond.

Mr. Mierz noted that his understanding is that in response to an MDPH health consultation at Snake Pond last summer, AFCEE will be collecting drive-point samples at the pond in the vicinity of the Camp Good News beach. He suggested splitting those samples to analyze for not only ethylene dibromide (EDB) but possibly explosives as well. 

Agenda Item  5.  Updated Fact Sheet

Ms. Dolen of the Impact Area Groundwater Study Program (IAGWSP) office stated that her office works with EPA and MADEP in developing public information pieces.  She reminded everyone that they have a chance to comment on the PIP until May 25, 2001. Mr. Schlesinger stated that he doesn’t have a copy of the PIP. Ms. Dolen noted that the PIP was distributed to the team during last month’s IART meeting.  She also said that she will provide copies to those who request them.

Ms. Dolen stated that the resources being used to create the fact sheet include the June 1999 fact sheet and information from EPA Administrative Order #4. An outline of the types of things that were in the June 1999 fact sheet will be incorporated into the new 2001 fact sheet.  She noted that the map included in the document is not the map that will be in the final fact sheet; the document being provided tonight is only a prototype for discussion, to get feedback on the layout. She added that this may be one of 30 sections in the final document. If the team likes this prototype, she will fill in the information and bring it back for more discussion. 

Mr. Walsh-Rogalski said that he thinks it is important is to have a fairly concise overview section that ties all the pieces together. He stated that when Ms. Dolen talks about 30 sections, it’s somewhat scary because it is important to get the big picture before moving into the details. He suggested producing something of a smaller size that is supported by more detailed sections. Then those who don’t have the stamina to read 30 pages, or 30 sections, can still get an overview.     

Mr. Hugus stated that 30 sections would become a 60-page document and people would not want to read it.  He then suggested including all the findings of fact in Administrative Order #4.  He also said that he thinks that the PIP slights the citizens of their involvement.  He noted that was the Alliance for Base Cleanup (ABC) which originally pushed for the study of the Impact Area in 1990, when he first joined. All the parties that are named in the PIP finally listened to the citizens, which is why the study was undertaken. Mr. Hugus suggested that mentioning the citizens more in the document would be helpful, and may inspire more public involvement.  

Ms. Adams commented that the fact sheet contains too much detail, and should be no more than five pages long.  She said that she thinks it is a good idea to have the backup information, and she thinks that the short version of the fact sheet, should have a plume map, which, in her opinion, is more important than a photograph.  Ms. Adams also noted that she is in favor of a “further reading” section.  

Dr. Feigenbaum said that a person who never heard of RDX before would come away from reading the chemical fact sheet thinking that there is “much to-do about nothing.”  He explained that the document seems to mouth a commonly-held belief that EPA goes overboard in establishing health advisories for human beings on the basis of animal studies. He noted that human beings aren’t mentioned until the last paragraph, after a good deal of information about mice, where it stated, “RDX can cause seizures, problems with the central nervous systems in humans and animals.” Dr. Feigenbaum stated that the human result ought to be up front, not the mouse result. He added that Ms. Dolen shouldn’t  include “what we don’t have evidence for,” but  “what we do have evidence for.”  

Mr. Borci explained that the current document resulted from an effort to take a standard chemical-specific sheet and make it slightly site-specific. He also agreed, however, that all of Dr. Feigenbaum’s comments are well taken and on the point right now.  

Mr. Dow asked when the new 2001 fact sheet will be available in a draft form.  Ms. Dolen replied that if it is a five-page fact sheet, it may be ready by the next IART meeting.

Mr. Walsh-Rogalski commented that he believes the fact sheet misses the point of the study, which is to protect a resource - the drinking water supply - for the future of Cape Cod. He noted that you can’t drink the water if it’s not available, so the focus shouldn’t be just on risk, He said that the bigger context needs to be reflected in the fact sheet as well. Because the resource itself is at stake, in addition to public health, on a very individual level.  

Mr. Schlesinger stated that he would like to hear about the invitations that were issued to four agencies to participate on the team.  Mr. Murphy said that he heard back from two of the organizations, the Metropolitan District Commission (MDC) watershed division, who had a representative present tonight, and the Division of Fisheries and Wildlife.  He noted that he believes their intention was just to come to a meeting and observe, as they are not that familiar with the team. Mr. Murphy also mentioned that a representative of the Wampanoag tribe is present as well. He stated that he has not heard from the Department of Environmental Management (DEM) - and will contact that agency before the next IART meeting.  

Ms. Dolen stated that she needs to revise the timing for the fact sheet; she said that she will have it ready for the June IART meeting, not the May meeting.  

Agenda Item 6. Adjourn  

Mr. Murphy thanked everyone for attending and adjourned the meeting at 9:45 p.m.

Action Items:

1. Mr. Hugus requested that the National Guard Bureau (NGB) provide information on any ongoing Textron litigation.

2. Mr. Schlesinger requested that the Guard assess ecological receptors of air and soil from firing events at Camp Edwards.

3. Mr. Schlesinger requested that the Environmental Protection Agency (EPA) risk assessors review the revised calculations of the Army Corps of Engineers small arms report.

Status of Action Items