Area Review Team Meeting
April 24, 2001
list does not reflect all the attendees of the open house event
prior to the IART
Handouts Distributed at Meeting:
25, 2001 Draft Meeting Agenda
27, 2001 Draft Meeting Minutes
Status of April
24, 2001 Action Items
Groundwater Study Update
Discoveries/Dispositions Since 01-25 IART
Ranges Update, April 2001
handout: Small Arms
Range Air Sampling at C and SE Ranges
handout: Fact Sheet
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
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
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.
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
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
Mr. Dow asked if the Army study in
the combustion chamber detected any semi-volatile organic carbon
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 21st
century, is a program for the Army to study several different activities
so it can design and maintain ranges in a more environmentally compatible
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
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
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
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
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 requested that the National Guard Bureau (NGB) provide information
on any ongoing Textron litigation.
Mr. Schlesinger requested that the Guard assess ecological receptors of
air and soil from firing events at Camp Edwards.
Schlesinger requested that the Environmental Protection Agency
(EPA) risk assessors review the revised calculations of the Army
Corps of Engineers small arms report.
of Action Items