Impact Area Review Team

River River Drops of rain on a leaf

Impact Area Review Team
Quashnet Valley Country Club
Mashpee, MA
December 4, 2001
6:00 p.m.

Meeting Summary





Ben Gregson



LTC David Cunha

HQ Camp Edwards


Jane Dolan



Todd Borci



Bill Walsh-Rogalski



Ellie Grillo



Len Pinaud



Marty Aker



Tom Cambareri

Cape Cod Commission


Jim Stahl



Janet Pepin

Teaticket resident


Evelyn P. Hayes

Yarmouthport resident


James Kinney



Joel Feigenbaum



Dick Judge

Sandwich resident/SMB


Ray Taylor



Peter Schlesinger

Sandwich resident


Richard Hugus

Falmouth resident







Jim Murphy








Pamela Bonin



Tina Dolen



Bill Gallagher



Ben Rice

Camp Edwards



Dave Williams




Darrell Deleppo




Joe McInerny




Dave Jacobson




Rob Clemens



Kim Harriz



Marc Grant



Lou Seijido

Conti Environmental



Magdelena Krol

GCA GeoEnvironmental

Dave Heislein

Harding ESE


Corinne Shid




George Peterson




Michael Jasinski



Desiree Moyer



Henry Byers



Jan Larkin




Ken Gaynor

Jacobs Engineering


Rick Newill

Foothill Engineering


Richard Skryness


Tom Fogg

IT Corp



Dave Egan

IT Corp


George Gardner

Tetra Tech


David Cobb



Doug Larson



Doug Shattuck

Directional Technologies


David Dow

Sierra Club


Reginald Judson

Pocasset resident



Sue Phelan

W. Barnstable resident

Lori Boghdan



Mary Meli



Deirdre DeBaggis



Handouts Distributed at Meeting:

  1. October 23, 2001 Draft Meeting Summary

  2. December 4, 2001 Draft Meeting Agenda

  3. Responses to Action Items from the October 23, 2001 IART meeting

  4. Impact Area Groundwater Study Program Update – December 2001

  5. In-Situ Treatment of Explosives Study – Pueblo, Colorado

  6. Details of a Conference with Witness #19 – Second Interview 1/10/01 and 9/22/01

  7. Handout for IART Meeting of 12/4/01 re: Action Item #1

  8. Table 7-1 Chemicals of Potential Concern for Human Health CS-19 Study Area

  9. IAGWSP Summary of Nitrocellulose Composition and Environmental Impacts

  10. Anomaly Investigation at the BA-1 (BOMARC) Training Area

  11. Appendix 3 – Emission Factor Tables

  12. Map: Location of Geological Cross-Sections CS-19

  13. Map: Groundwater Wells at MMR

  14. Presentation handout: Demo Area 1 Groundwater FS Update

  15. Presentation handout: IAGWSP Investigation Update

  16. Presentation handout: Munitions Survey Project Update

  17. Screening Values and Standards for Detected Compounds in Soil

Agenda Item #1. Welcome, Approval of October 23, 2001 Meeting Minutes, Review Draft Agenda

Mr. Murphy convened the meeting at 6:01 p.m. and welcomed the attendees. He announced that last month Mr. Judge was approved as a member of the Impact Area Review Team (IART). He then asked the team members to introduce themselves.

Mr. Murphy asked if there were any changes to the October 23, 2001 IART meeting minutes. Mr. Hugus referred to the second paragraph on page 3, and requested that the southern part of MMR be added following "contamination of groundwater caused by plumes emanating from." He then referred to the third paragraph on page 7 and asked that cohesiveness of providing be deleted from the minutes. Mr. Murphy asked if there were any other changes to the minutes. Hearing none, the minutes were approved with the noted changes.

Review Agenda

Mr. Murphy reviewed the proposed agenda, noting the addition of "Late-Breaking News." He also noted that "Other Issues" was inadvertently missing from the agenda. Mr. Hugus requested that "Other Issues" remain a constant on future agendas and noted that he has several items he would like to discuss at that time.

Dr. Feigenbaum requested that Mr. Borci provide some background information regarding his letter on the contained detonation chamber (CDC). Mr. Murphy added this item under "Other Issues."

Ms. Hayes inquired about changes being made at this time to the agenda. Mr. Murphy explained that changes are typically made to the agenda at this time.

Agenda Item #2. Review Action Items

  1. Ms. Pepin requested the identification of the bacterium that would be utilized in several of the alternatives proposed for Demo Area 1.

    Mr. Murphy stated that this information is available in team member packets and on the back table.

  2. The Guard will keep the team updated on the validation status of 2,4-and 2,6-DNT detected in MW-84.

    Mr. Murphy stated that the Guard will provide more information regarding MW-84 tonight.

  3. Mr. Hugus requested that the Guard provide information on the Schooner Pass well results.

    Mr. Murphy stated that the Schooner Pass well was sampled on October 2, 2001 for explosives and perchlorate, and results were nondetect.

  4. The Guard will provide the "Fate and Transport" laboratory study report to the Massachusetts Institute of Technology (MIT) representatives involved with the IART.

Mr. Murphy noted that this action item was carried over from the September meeting. He stated that the "Fate and Transport" report is not yet available, but should be distributed later this month.

Mr. Murphy noted that the action item response document includes a list of items that were sent to team members. He then asked if there were any questions or comments on the action items.

Mr. Hugus referred to item "a," which pertains to interviewee #19 from the archive search report (ASR). He said that he thought interviewee #19 was the person who said that depleted uranium (DU) was fired at the J Ranges, and then recanted the testimony. He noted that the handout regarding this item states that witness 19, as he currently is referred to, is an employee of Textron and has been instructed by Textron’s attorney not to participate in any interviews without attorney presence. He asked how any information is going to become available if everything has to go through a Textron attorney.

Ms. Dolan pointed out that the investigator hired by National Guard Bureau (NGB), not the United States Environmental Protection Agency (EPA). She further clarified that witness #19 was not the individual who made the statements regarding DU. She noted that those statements were made earlier this year and the team received a summary of the interviews.

Mr. Walsh-Rogalski explained that Textron, or any company, has the right to have an attorney present when an employee is interviewed because the theory is that the person speaks for the company in that instance and the lawyer should be able to be present. He stated that information regarding the DU was developed pursuant to grand jury subpoenas, and grand jury material is forever confidential.

Mr. Hugus said that he thinks that legal issues with Textron will become a roadblock and that additional information will not be forthcoming. Mr. Walsh-Rogalski stated that Textron has responded to questions posed by EPA, NGB, and the Air Force through the information request process.

Ms. Dolan added that the Guard is in the process of setting up additional interviews with individuals currently or formerly employed by defense contractors.

Dr. Feigenbaum asked for more information regarding the grand jury investigation. Mr. Walsh-Rogalski explained that there is always a federal grand jury empanelled and that the U.S. attorney brought matters before the grand jury regarding several issues on the base, including the issue of DU. The grand jury then investigates the matter and decides whether to indict, which it has not yet done.

Mr. Kinney referred to the in-situ treatment report and asked what becomes of the polylactate glycol ester, which is the hydrogen release compound. Mr. Gregson replied that he believes that it is a food source for the microbes, but will follow up on the question.

Mr. Hugus asked if he could expect more information on the handout titled "Anomaly Investigation at the BOMARC Training Area" at tonight’s meeting. He noted that the handout states that there may be buried hazardous, toxic, and radioactive materials in the berm at this location. Mr. Gregson stated that a workplan has been approved by the regulators and the interrogation commenced last week. He noted that samples were taken and that he will report to the IART as soon as results become available. Mr. Hugus asked why it is believed that there are hazardous or toxic materials at this location. Mr. Borci replied that glass that may be from electronic tubes, which would indicate possible low-level radioactivity, was detected during the first excavation. He stated that the electronic components that were recovered had the name BOMAC, not BOMARC, and the Guard is following up with that to see if BOMAC can identify the components. Mr. Hugus asked that the IART be updated on this issue at the January meeting.

Agenda Item #3. Late-Breaking News

Investigations Update

Mr. Gregson displayed a map depicting the Central Impact Area and pointed out monitoring well-178 (MW-178). He explained that this well is part of the series of wells being installed to serve as delineation wells. He clarified that MW-178 is located to the north of MW-50, which, in the past, has had Royal Demolition Explosives (RDX) detections of 1.9 parts per billion (ppb) and 0.29 ppb. He explained that MW-178 was installed in an attempt to gather more information on the extent of RDX. He stated that there was a detection of 4.78 ppb of RDX in MW-178, which is above the health advisory (HA) level of 2.0 ppb. Mr. Gregson stated that this detection suggests that the RDX contamination extends north of MW-178.

Mr. Gregson pointed out Demolition Area 1 (Demo Area 1), which is located to the south of the Central Impact Area. He noted that a series of wells are being drilled on Pew Road in an attempt to obtain information on the downgradient extent of RDX and perchlorate from the Demo 1 plume. Two wells that were drilled tested nondetect for RDX. The third well, MW-186, is the southernmost well and had profile detections of 2,4-di-amino-nitrotoluene (DANT) in several intervals. Mr. Gregson noted that these results are suspect because similar profile sample detections occurred in two other wells, but results were not repeated in the actual monitoring well.

Mr. Gregson pointed out the J-3 Range, which is located in the southeast section of the Impact Area, and MW-181, which was installed near the melt/pour building. He reported that a grab sample was collected at the water table that showed a detection of gross alpha radiation at 544 picocuries per liter, which exceeds the maximum containment level (MCL) of 15. He reported that a second analysis was run on the same sample, which indicated gross alpha radiation at 690 picocuries per liter. Mr. Gregson reported that a monitoring well was installed at this location, which tested nondetect for alpha radiation. This sample was also analyzed for uranium and results were either nondetect or low levels; however, these data currently are unvalidated. He reported that the grab samples, or profile samples, are being reevaluated and the sediment is being separated. He reported that he believes the detections may be a result of a laboratory problem or naturally occurring radon.

Mr. Hugus asked how far apart in time the profile samples were tested. Mr. Gregson replied that samples were collected three months apart. Mr. Hugus pointed out that radon has a half-life of days. Mr. Gregson concurred and said that he does not know what the source is. He added that radon is associated with alpha detections. Mr. Hugus asked if DU has been ruled out. Mr. Gregson replied that uranium results were either nondetect or at low levels, which may be associated with background. He added that soil samples collected on the way down to the water table also were nondetect. Mr. Hugus said that he does not understand what are the possible causes of a detection like this could be. Mr. Gregson stated that the IART will be updated on the matter. Mr. Hugus said that it is interesting that so few profile samples base-wide indicate radioactivity interference.

Dr. Feigenbaum asked if both alpha and beta emitters were detected. Mr. Gregson replied that only alpha was identified. Dr. Feigenbaum asked whether radon only emits alpha. Mr. Gregson replied that he does not know, but will find out. Dr. Feigenbaum questioned whether it’s possible to conduct a special analysis on the alpha to determine the energy, which is characteristic of each species of radioactive nuclide.

Ms. Dolan stated that analyses will most likely be conducted to help determine the emitter. She said that the team will be updated in January. Dr. Feigenbaum said that it has been three months and it seems like the process is dragging. Ms. Dolan stated that the profile sample was collected three months ago, but EPA received the results about three weeks ago. Dr. Feigenbaum said that this is not an insignificant finding and he wonders why it took so long. He also inquired about the how the detection relates to background. Mr. Gregson said that he is not sure what background is. Dr. Feigenbaum reiterated that he does not understand why things are taking so long.

Mr. Borci reported that communications have taken place between EPA Region I and the Idaho National Environmental Laboratory, which is an EPA contract lab that has extensive experience in these issues. He said that he is not sure of the exact holding time, but, like all samples, there is a period of time before a sample has to be analyzed. Then the actual analysis and lab verification takes time. He said that he believed about two months passed before EPA received the results. Mr. Borci stated that he is hopeful that the gamma spectroscopy will identify the exact isotope, which would narrow it down to either radon or radon daughter products. This analysis would then be followed by more detailed analyses to determine the exact isotopes that are giving off the elevated radiation levels. He stated that there are two samples: one has not been touched and the other has been analyzed twice. Dr. Feigenbaum asked if the samples should be subject to chemical composition analyses. Mr. Borci said that he assumes that the well was tested for most analytes and explosives. He added that the IART will be provided with more information at the January meeting

Dr. Stahl stated that Mr. Borci is correct and clarified that further analysis will examine the signature of the particles and determine the compounds or the elements.

Mr. Schlesinger asked whether any downgradient samples have been taken, and if so, whether they had similar detections. Mr. Gregson said that he did not know off hand, but would report to the team in January.

Mr. Judge stated that he is concerned with the timeframe and does not want to wait another three months for additional results. Mr. Gregson said that he will let the team know when the spectral analysis will occur. He explained that a screen was installed in the monitoring well at the same location where the profile sample was collected and it was nondetect. He said that he thinks that it would be best to reexamine the original sample and determine if additional samples are necessary. Mr. Judge said that he is still concerned that it takes three months to determine whether radon is the source. He asked how much longer the second sample will take. Mr. Gregson said that the investigation has been expedited and the three-month timeframe will be lessened.

Ms. Pepin asked when the melt/pour building was built. Ms. Dolan replied that it was built in the 1977/78 timeframe. Ms. Pepin asked whether the materials that make up the building have been considered as a source. Ms. Dolan said that this has not yet been considered.

Ms. Hayes asked whether individuals are currently at risk. Mr. Gregson replied that the detection occurred at the water table, which is approximately 70 to 80 feet below ground. He added that there are no current drinking water sources downgradient, so there are no existing exposures to groundwater at this location. Mr. Judge clarified that there are no exposures that the Guard is aware of, because the source is unknown.

Mr. Gregson reported that there were several detections at the J-1 Range. He displayed a map and pointed out the 1000-meter berm and the 150-meter berm. He referred to MW-187 located in the left-hand corner of the map, and noted that it is downgradient of MW-165. He stated that RDX was detected at two intervals in MW-187 at a maximum concentration of 1.30 ppb. He added that other detections at this well include Her Majesty’s Explosive (HMX) at 0.53 ppb and 2,4-DANT at 0.46 ppb. Mr. Gregson then pointed out MW-189, located at the 1000-meter berm, and MW-90 to the south. He reported that MW-189 had a detection of 1,3,5-trinitrobenzene at 0.46 ppb, and MW-190 had a detection of 2,4-DANT in a profile sample.

Mr. Gregson stated that MW-191 was installed in an area where open burns took place. He reported that RDX was detected at a maximum concentration of 2.34 ppb in MW-191. He added that HMX and 1,3,5-trinitrotoluene also were detected in the profile samples.

Mr. Gregson then referred to perchlorate detections. He reported that MW-166 had an unvalidated perchlorate detection of 1.50 ppb, which is at the level EPA established for perchlorate. He stated that MW-81 had a detection of perchlorate of 1.70 ppb in a sample collected from the middle screen. He noted that 1.70 ppb is near the detection limit. A second sample was collected from the well and samples also were collected from the chemical monitoring wells and the water supply wells downgradient; all samples came back nondetect for perchlorate.

Mr. Hugus said that the progress reports indicate that a line was drawn backtracking from MW-7 to MW-80, which prompted testing of the Bourne water supply wells. Mr. Gregson explained that the backtrack was done to obtain more information on a potential source area. Mr. Hugus pointed out that MW-7 is quite a distance away. Mr. Gregson agreed and said that it doesn’t make sense for that detection to be that far out. Mr. Hugus said that this was his question, and he wonders whether the Guard thought that perchlorate traveled faster than everything else. Mr. Gregson replied that perchlorate would travel at about the same rate as RDX. Mr. Hugus asked if there is connection between the perchlorate detections at MW-7 and MW-80. Mr. Gregson said that he does not believe there is a connection. Mr. Hugus asked if there are any perchlorate detections in between the two wells. Mr. Gregson replied that he is not sure about the level of perchlorate at MW-7 and noted that the wells in between MW-1 and MW-80 have been nondetect for explosives and propellant compounds.

Mr. Hugus asked if the detection at MW-80 is in the zone of contribution (ZOC) for the Bourne water supply wells. Mr. Gregson replied that it is probably deeper than the ZOC. He added that these wells are probably two to three years upgradient of the water supply wells. Mr. Hugus asked whether Bourne town officials have been notified of the perchlorate detections. Mr. Gregson replied that they have. Mr. Hugus stated that he thinks the perchlorate detections warrant more attention, especially since they are so close to the water supply wells. Mr. Gregson stated that the wells in question are part of the long-term monitoring plan.

Mr. Gregson then reported that MW-84, which is located south of the water supply wells, had detections of trinitrotoluene (TNT), 2,4-dinitrotoluene (2,4-DNT), and 2,6-DNT in the profile sample. He stated that TNT and 2,4-DNT were not confirmed by photo-diode array (PDA). He also noted that the lab was not able to rule out the 2,6-DNT detection as false-positive, it does not make sense that 2,6-DNT is in this well considering there are no upgradient detections. Mr. Borci stated that the sample in question also was analyzed by selective ion monitoring (SIM), an exact analysis method and the 2,6-DNT was confirmed. He added that this issue is of concern and will be discussed at the next technical meeting.

Mr. Schlesinger asked if there were any old ranges in the area in question. Mr. Borci explained that the particle tracking led to the northern end of the KD Rocket Range. He noted that the next step is to review historical aerial photographs to see if there is anything out of the ordinary in those areas.

Mr. Walsh-Rogalski asked if the 2,6-DNT detection is in the ZOC. Mr. Gregson said that he does not know, but will find out and report to the team.

Mr. Walsh-Rogalski asked about the 2,6-DNT concentration level relative to the health standard. Mr. Borci replied that there is no MCL for 2,6-DNT. He explained that a comparison would most likely be 0.05 ppb, which was developed using the preliminary remediation goal, which is based on a 10-6 cancer risk. He added that the detection in question is not at this level.

Snake Pond Diffusion Samplers Update

Mr. Gregson displayed a map of Snake Pond and stated that the blue dots indicate the preliminary line of diffusion samplers, the red dots represent the final grid of samplers, and the "X’s" indicate samplers that were not recovered from the pond bottom because the sampling bag had deteriorated over time. He reported that there were no detections of RDX in any of the samples that were analyzed; however, there were detections of 2,4-DANT, nitroglycerine, 2-nitrotoluene, and 2,6-DNT. These results are questionable because the diffusion samplers were placed on the pond bottom, which contains a lot of organic material in the sediment that could result in interference. Mr. Gregson added that the monitoring wells north of the pond do not indicate similar detections.

Mr. Gregson reported that he spoke with the United States Geological Survey (USGS) today to discuss the methodology, the results, and next steps. Mr. Schlesinger asked if additional analyses will be conducted on the samples that already have been collected. Mr. Gregson replied that he did not think that the same samples would be used because of the dissolved organic materials, which might have caused interference. He explained that shallow drive-points are being considered as a next step because they would yield a deeper, cleaner sample of the groundwater.

Dr. Feigenbaum suggested that the sediment in the pond is rather homogeneous, in which case false-positives should be occurring everywhere, not just in five locations. Mr. Gregson stated that the pond bottom is not as homogeneous as Dr. Feigenbaum might think. He said that the Guard will be working with the USGS on this matter.

Mr. Kinney asked if the Guard is going to take a more aggressive stance and take more samples and figure out how to address the sediment problem. Mr. Gregson replied that he has been discussing options with the USGS, one of which is shallow drive-points. The idea of using a different membrane on the diffusion samplers also has been discussed. Mr. Kinney stated that he thinks there is a need for aggressive sampling in an area such as Snake Pond in order to determine what is happening out there. He said that he wants to be reassured that the Guard is going to get to the bottom of this matter. Mr. Gregson stated that the Guard is still working on this issue. He added that focusing the investigation has been difficult because there is a lack of a pattern of detections.

Mr. Judge questioned whether some of the nondetects also should be considered invalid given that the detections from the diffusion samplers are being considered invalid due to an interference with the sediment. He asked if the USGS diffusion sampling project is considered to be a failure. Mr. Gregson replied that the USGS faced many challenges. In hindsight, the USGS probably should have given more consideration to the issue of interference from organic materials.

Mr. Judge asked whether there were any problems associated with the first line of diffusion samplers that were installed in August. Mr. Gregson said that he is not aware of any problems, but will double check to make sure. Mr. Judge said that he is concerned about this matter and hopes that it will be addressed quickly.

Mr. Schlesinger referred to the packet of maps distributed to IART members. He inquired about the validated hits that he sees on the maps at every meeting, and noted that nothing seems to be happening with these detections. He referred to the herbicide and pesticide map, for example, and noted that there is a whole line of validated detections along Wood Road. This line of detections remains red on every map and the same is true on the volatile organic compound (VOC) and semi-volatile organic compound (SVOC) maps. Again he asked if anything was being done to address these detections. Mr. Gregson explained that the map to which Mr. Schlesinger is referring depicts all validated detections regardless of whether another detection ever occurred; the maps show information on detection locations at any point in time. Mr. Schlesinger asked if it would be possible to develop a color-coded map indicating number of detections. Mr. Gregson replied that developing that map would be quite complicated.

Mr. Borci explained that EPA is constantly analyzing the data and a consistent pattern would warrant follow-up by the Guard. He explained that some areas have an operable unit addressing the issue. Other areas that are not encompassed by an operable unit are still being monitored and analyzed. Mr. Schlesinger questioned the usefulness of the maps. Mr. Borci stated that the team has been wrestling with this issue for some time. Mr. Schlesinger suggested that the team address this topic at a future IART meeting. Ms. Hayes stated that it would be helpful if the maps that were distributed at meetings were relevant to the presentations.

Agenda Item #4. Demolition Area 1 GW – Feasibility Study Update

Revisions to Feasibility Study

Dr. Feigenbaum inquired about the level of RDX in MW-186. Mr. Gregson replied that RDX was not detected, which is consistent with the other wells along Pew Road. He added that the profile sample indicates a detection of 2,4-DANT. Dr. Feigenbaum asked if 2,4-DANT is consistent with the composition of detects from Demo Area 1. Mr. Gregson replied that it is not consistent with Demo Area 1. He said that he believes there is 2,4-DANT in the Demo Area 1 plume, but it is near the source area and is not detected in any downgradient wells. Dr. Feigenbaum asked Mr. Gregson if he believes that the toe of the Demo Area 1 plume is somewhere between Frank Perkins Road and Pew Road. Mr. Gregson replied that he does. Dr. Feigenbaum said that he thinks that a well should be installed between the two roads. Mr. Gregson noted that he will address this issue in his presentation.

Mr. Gregson displayed a map depicting Demo Area 1. He pointed out the Demo Area 1 depression, noting that the bottom of the depression is approximately 45 feet below the surrounding grade. The depth to groundwater at the bottom of the depression is about 40 or 50 feet. He added that the area was used for open burn/open detonation and training with explosives.

Mr. Gregson reported that the Demo Area 1 Feasibility Study (FS) includes five alternatives: no action alternative; gradient control, which is basically an extraction well at the toe; gradient control with some in-situ chemical treatment; gradient control with in-situ or in place biological treatment; and a plume recovery option, which has five wells along the axis of the plume. He noted that the FS is being refined and some items under evaluation are the number, location, and pumping rates of wells, and the locations of the infiltration galleries. He said that he mentioned at the last IART that one option includes discharging the water back to the Demo Area 1 depression in an attempt to flush the deeper contamination down to the water table. He noted that there are some concerns with this approach in that groundwater flow may be significantly altered at the source area, which may cause problems with the treatment system. Thus, downgradient and lateral reinjection galleries or wells are being considered to address the treated groundwater.

Mr. Gregson noted that some problems have been identified in the draft FS. For example, there is a pumping rate error in Alternative 5. The original draft FS estimated the pumping rate would be 150 gallons per minute (gpm), but revised simulations estimate that the rate would be approximately 500 gpm. The shape of the plume shell was also revised; it is slightly smaller than originally thought.

Mr. Hugus said that he is interested in seeing a revised map of the plume. Mr. Gregson stated that a revised map is not yet available.

Mr. Gregson stated that the revisions to the FS will have an impact on costs. The higher pumping rate for Alternative 5 will result in an increase in the hardware requirements. He noted that the adjusted costs will be incorporated in the revised FS. He also explained that another area of impact may be associated with installing injection wells downgradient or laterally because it is a heavily wooded area and there may be natural resources to consider.

Mr. Gregson reported that his office has received comments from EPA and the Massachusetts Department of Environmental Protection (DEP), and response to the comments is scheduled to be sent to the regulators on Monday. He added that the FS schedule is currently being revised.

Mr. Hugus said that he thought that EPA had not approved the FS for Demo Area 1. Mr. Gregson replied that it hasn’t and explained that EPA did not approve the FS because of concerns with some of the modeling of other contaminants of concern (COC) that should be included. Mr. Hugus asked if the main problem was that the FS ignored perchlorate in the treatment systems that were evaluated. Mr. Gregson stated that perchlorate was not ignored and noted that all of the treatment systems include a step to address perchlorate. He added that there was a problem with incorporating the 1.5-ppb standard for perchlorate required by EPA. Mr. Hugus asked if the NGB accepts that standard. Mr. Gregson stated that the Guard is using the 1.5-ppb standard for perchlorate to evaluate alternatives in the FS.

Mr. Borci explained that the disapproval regarding perchlorate is associated with the modeled timeframe for remedial action to be completed because it was based solely on RDX. EPA suggested that perchlorate might reside in a wider area because it would reach the water table sooner than RDX. He said that EPA recommended that, in order to meet the requirements of the administrative order (AO), a perchlorate plume shell should be identified, including a timeframe for remediation. He added that this is applicable to other COCs as well.

Mr. Gregson referred to Dr. Feigenbaum’s question regarding the toe of the plume. He said that there is concern that there is not adequate definition of the plume in that area. He said that he is pretty confident that the toe exists between Frank Perkins Road and Pew Road. He noted that, for the purpose of the draft FS, the toe is identified halfway between the two roads, but this was a guess. Mr. Gregson stated that there is no well data to support that; however, it does fit the modeling as far as travel time. He stated that the installation of additional wells in that area is under consideration. He also noted that the area in question is very difficult terrain and will require a lot of road building.

Dr. Feigenbaum asked if there is any opposition to installing wells in that location. Mr. Gregson said the only opposition is that natural resources will be impacted. Dr. Feigenbaum asked whether the Massachusetts Department of Fisheries and Wildlife (MDFW) would be alerted. Mr. Gregson stated that an assessment of the natural resources would have to be completed before installation could begin. This is standard procedure that occurs before any well is installed. He explained that the assessment would be reviewed by State Natural Heritage personnel who are looking at endangered species issues. Dr. Feigenbaum inquired about the schedule to install wells. Mr. Gregson said that wells in this area are next in line for Demo Area 1. He noted that MW-186 was installed recently on Pew Road, and the idea was to feel comfortable that the plume did not extend beyond that point. Now that there is some comfort in that regard, the next step is to better define the plume. Mr. Gregson stated that drilling could take place within the next couple of months. The wells have been scoped and funded, and it is now a matter of the natural resources assessment and road building. He added that he will report back to the team regarding more information on the schedule.

Mr. Cambareri asked what effects the increased flow rate for Alternative 5 would have on the design of the treatment system. He noted that the system involves a bio-reactor and probably requires a longer contact time, much more than just carbon filtration. He said that the low pumping rate was encouraging because it would be manageable with the extended contact time. Mr. Gregson said that he would have to report back to the IART regarding engineering and design changes.

Dr. Feigenbaum asked why a bio-reactor is being used. Mr. Gregson explained that the bio-reactor will address the perchlorate, while RDX and other contamination will be addressed by carbon filtration.

Mr. Walsh-Rogalski asked the team members whether they thought that they had enough information to move forward with a decision concerning Demo Area 1, allowing the final definition of the plume to be determined in the design phase. He noted that the other option is to define the plume before moving on with remedy selection.

Mr. Kinney stated that past investigations, not necessarily in the Impact Area, have defined plumes only to find out that the plume has spread. This has caused the waste of time, money, and ultimately, groundwater. He said that he does not want to slow down the process, but cautioned that uncertainty about plume definition may cause problems in the future. He stated that he thinks that more wells are needed. However, he does not agree with a one-well-at-a-time approach and suggested that two wells be installed simultaneously to define the plume more quickly. Mr. Kinney said that he feels comfortable moving forward conceptually, as far as knowing what the constituents are, but he believes the extent of the plume should be defined before the FS is finalized.

Dr. Feigenbaum said that he agrees with Mr. Kinney’s general point, that too little remedial investigation has taken place. However, in the case of Demo Area 1, the source area is well defined and he thinks that the team should at least discuss the broad outlines of a potential treatment system while additional data are collected.

Dr. Feigenbaum asked how it happened that the flow rate was miscalculated for Alternative 5. Mr. Gregson replied that it was a mistake, but that quality assurance/quality control (QA/QC) has been increased to ensure that such mistakes are not repeated. Dr. Feigenbaum stated that he thinks the design aspect should move forward, assuming similar mistakes do not occur again.

Dr. Stahl asked whether the revised pumping rate only applies to Alternative 5. Mr. Gregson answered that the error is confined to Alternative 5. Dr. Stahl asked whether costs have been reevaluated. Mr. Gregson said that he does not yet know what the cost increase will be. Dr. Stahl said that he thought one of the biggest benefits of Alternative 5 was the duration. However, running Alternative 5 for a longer period of time, with a lower rate of flow, would make it comparable to the other alternatives. Mr. Gregson explained that the pumping rate was increased to meet the AO requirement to achieve cleanup within ten years.

Ms. Hayes asked whether it is common for the Guard to receive so many comments from the agencies. Mr. Gregson agreed that the comments were detailed, but noted that it is an important step in the process and has to be done correctly. Ms. Hayes clarified that she is asking whether the Guard usually does a better job. Mr. Gregson explained that this is the first FS to be done under the Safe Drinking Water Act (SDWA).

Mr. Taylor asked whether the reliability of a bio-system has been considered. Mr. Borci replied that currently there are several bio-systems in operation that have proven to be highly reliable.

Agenda Item #5. Review Draft Plume Maps for J Ranges

Mr. Gregson noted that during the break in the meeting he spoke to a representative from Envirogen who told him that there is a fluidized bed reactor in operation in California that is successfully treating 5000 gpm, thus 500 gpm is doable.

Mr. Gregson stated that he has preliminary draft plume maps for the southwest ranges at the Massachusetts Military Reservation (MMR), which the IART has been anticipating. He noted that the preliminary draft plume maps include maps for RDX, HMX, and perchlorate. These figures, coupled with some cross-sections, are going to be part of the J-1, J-3, and L Ranges additional delineation workplan that will be available later this month.

Mr. Hugus asked if copies of the maps are available. Mr. Gregson explained that he did not provide hardcopies tonight, but they will be included in the document.

Mr. Schlesinger asked if the Town of Sandwich has been notified about the plumes. Mr. Gregson replied that the Town of Sandwich has been made aware of the off-post detections.

Mr. Dolan clarified that the document containing the maps will be available on December 21, 2001.

Mr. Taylor referred to the map on display and said that he has never known a plume to get narrower as it traveled away from the source area. Mr. Gregson reminded him that these are preliminary draft maps, and they will be changing.

Mr. Judge asked Mr. Gregson to provide the Sandwich Town Hall with a copy of the document. He said that he is concerned with the timeliness of the IART receiving maps as well as the accuracy and details on the maps. Mr. Gregson reiterated that these maps are preliminary and will be changing over the next few weeks. He explained that the idea is to make sure that the map distributed to the public has the most accurate information.

Mr. Gregson stated that the figure he is displaying depicts four separate RDX plume areas. He explained that the light yellow depicts a detection that is greater than the detection limit, which is 0.25 ppb. The slightly darker color indicates wells that have had detections greater than 2 ppb, which is the HA for RDX. These areas include an area near the burn kettle, south of the L Range, and the Snake Pond spit, which has a detection of 4.0 ppb. Dr. Feigenbaum said that he thinks it is obvious that more data is needed. Mr. Gregson agreed and said that the additional delineation workplan addresses the data needs for better defining these plumes.

Mr. Hugus pointed out that these maps are a result of many citizen requests.

Mr. Borci explained that several high areas of concentrations were identified when the J Range investigation began, which showed that definition was needed. The decision was made to approach this area in a step-wise, logical way. He stated that the Air Force already had installed a lot of wells in this area, which is near the Fuel Source 12 (FS-12) source area. Therefore, the first step was to evaluate the data from these wells. Mr. Borci stated that the next step was to install several wells where there appeared to be some data gaps, which is where the project is to date. Now the plumes have been depicted and the December 21, 2001 workplan will assist the project to move forward and attempt to address the data gaps. He added that he is hopeful that the workplan will help to answer questions that are raised by looking at the plumes in plan view.

Mr. Judge said that he appreciates the work that has gone into this project, but he thinks now is the time to generate a press release to let the public know that a plume has been identified. Mr. Gregson pointed out that press releases have been distributed right along, whenever detections were identified. He added that the next step is to feel comfortable with the depiction and provide that additional information to the public. Mr. Judge asked how soon after the detection at Snake Pond the press release was generated. Mr. Gregson replied that the press release went out within 48 hours. Mr. Judge questioned how long the plume has been depicted in map form, and said that he thinks the Guard is quick to distribute press releases on single detections, but not so quick to release the defined plume data.

Mr. Borci stated that active drilling is occurring in the J-3 Range area; there is already one workplan in progress designed to answer some of the questions that have been raised. The second issue is what characteristics define a plume. He explained that some people believe that three consistent detections in a well are needed before an actual plume can be defined. This would not consider profile samples, and the detections would have to have occurred at approximately similar depths. The image on the screen would not meet that definition of a plume. He stated that he does not believe that anyone at EPA, DEP, or the Guard would feel comfortable declaring that these preliminary draft plume maps definitely define the plumes.

Mr. Borci also said that there is a need to install many wells because many questions will be raised by depicting these plumes on paper. He noted that data is expected over the next month, and it is possible that better definition of the plumes may be obtained before the second workplan is implemented. Mr. Judge asked if perhaps this could occur within a month’s time. Mr. Borci stated that perhaps a map could be presented to the public by spring. He also noted that this procedure is similar to the one implemented in the Central Impact Area. He reiterated that a map will be distributed to the public, although wells will continued to be installed and data will be collected.

Mr. Schlesinger asked why there is hesitancy in releasing this map when other plume maps have been released without the plume being entirely defined. Mr. Borci explained that there is a lot going on in this area; it is at the top of the mound, there are multiple sources, multiple contaminant releases, and there is a series of downgradient wells that appear to be connected.

Mr. Gregson then displayed the HMX plume map. He reported that there are no detections of HMX above the HA, which is 400 ppb. The maximum detection of HMX , 37 ppb, occurred at a well near the melt/pour facility. He pointed out the potential source areas and noted that it mimics the RDX plume in that there is an HMX detection in the central portion of the J-3 Range that is associated with the Demo Area burn kettle. He also noted that there were HMX detections downgradient of the L Range, and north of Snake Pond.

Mr. Gregson displayed the perchlorate plume map and reported that there are scattered detections of perchlorate and three areas have been identified as potential plumes. He stated that perchlorate detections were found in the J-3 Range at 67 ppb and 75 ppb. In addition, there was a perchlorate detection at 10 ppb southwest of the J-3 wetlands.

Mr. Dow noted that the RDX plume and the HMX plume occurred in the same general track, and asked whether the detections were found at similar depths as well. Mr. Gregson replied that they were.

Ms. Dolan inquired about the other isolated perchlorate detections in the area. Mr. Gregson replied that the detections were relatively low, in the 2-ppb to 3-ppb range. He explained that the detections are not connected because they occurred at different depths and there does not appear to be a relationship between them.

Mr. Cambareri said that it appears that the connection of the dots is geared toward a point source approach, whereas the Central Impact Area depicts a broad spread, which indicates a non-point source. He asked whether the various different points are likely to be connected to a single source. Mr. Gregson said that the possibility of a source area is considered when constructing the plume. He added that these isolated detections that do not seem related depth-wise or source area-wise are tougher, at this point in the preliminary draft stage, to connect to anything.

Ms. Dolan said that, with the exception of the L Range, the preliminary plumes do not appear to be connected to firing activities.

Agenda Item #6. Munitions Survey Update

CPT Myer stated that he is going to provide an update on the Munitions Survey Project, starting with the current ammunition supply point (ASP) investigation, followed by the Former A Range investigation. He said that the intent of the Munitions Survey Project is to investigate Camp Edwards training areas for unexploded ordnance (UXO) and UXO burial sites. He added that UXO and UXO burial sites are potential sources for soil contamination, which leads to groundwater contamination. He explained that completing the Munitions Survey will allow the Impact Area Groundwater Study to select and develop alternatives for remediation.

CPT Myer displayed a picture of a towed EM-61 and stated that Mr. John Webster of Tetra Tech has brought in a EM-61 to show the IART.

Mr. Webster presented the EM-61, which is a tool used for ground-base geophysics. He explained that the EM-61 is a cart base system that consists of three separate items: the data logger, which collects the data that we use to generate the dig maps; the brain, which holds all the electronics for the dig maps; and the coil, which logs all the data points as it is charged. Mr. Webster stated that currently the EM-61 is in the global positioning system (GPS) mode.

Current Ammunitions Supply Point

CPT Myer reminded the team members that an archive search interviewee identified a location where he claims small arms were buried at the ASP. Subsequently, five areas were investigated for buried munitions and ammunitions because of potential concerns for contamination. CPT Myer reported that one of sites indicated evidence of burial and disposal activities. In Area E 312 engine starters or igniter starters were discovered. He said that soil samples were taken in the area and tested for explosives, VOCs, SVOCs, metals, nitrates, nitrites, and he believes nitrogen as ammonia. He noted that the results are pending.

CPT Myer reported that a 55-gallon drum that contained some ash, small arms cartridges, and a smoke grenade was also discovered in another section of Area E. Flare canisters and rocket catapults were identified as well.

Mr. Schlesinger asked if the groundwater has been tested in Area E. CPT Myer explained that the soil was tested first and the results are not yet available. The results of the soil testing will determine whether additional testing is required. He noted that approximately 140 anomalies were identified in the five areas, and 84 anomalies have been excavated.

Mr. Judge expressed concern about referring to the 312 engine igniters as one anomaly. He said that it seems misleading. Mr. Schlesinger explained that anomaly refers to a location where some type of metal object was found under the surface, it has no relation to size. Mr. Borci stated that EPA shares Mr. Judge’s concern, and he noted that the report clearly lists what was found.

Former A Range

CPT Myer stated that investigation work also took place at the Former A Range. He reported that an archive search interviewee identified this area as being a range where direct-fire weapons systems for rockets were fired. As part of the Phase IIb investigation, soil and groundwater quality were investigated prior to the geophysical investigation. He stated that surface UXO was discovered when AMEC installed four or five monitoring wells in the area this spring. This find resulted in a recommendation to do a geophysical survey. He also noted that this area was covered as part of the aerial magnetometry survey, which provides additional data.

CPT Myer stated that four areas were investigated in the Former A Range. He reported that excavation occurred at 53 sites. The nine burial sites that were identified contained 3.5-inch rockets. Also, a lot of surface and subsurface UXO was revealed from zero to 24 inches. He noted that 34 open detonations were conducted on the surface UXO because it was considered unsafe to move. He added that 14 of the 34 of the UXO proved to be HE, and the rest were inert.

CPT Myer said that future steps will include additional studies to evaluate the range for UXO and other potential burial sites. The investigation is in the preliminary stage, like all the sites under the Phase IIb project. CPT Myer reported that AMEC is going to produce a tech memo that incorporates data from the geophysical survey and the soil and groundwater investigation. He also stated that the final ASP tech memo is due to EPA and DEP on January 31, 2002, and the Former A Range tech memo is due February 26, 2002.

Mr. Hugus asked why the N Range was not included in the update. CPT Myer replied that the N Range was included in the written update. Mr. Hugus stated that a total of 2164 mortars have been found at the N Range, and this discovery seems to serve as proof that the EPA’s AO is justified. He added that he hopes to see the investigation into buried UXO continue.

Mr. Schlesinger asked whether the soil is tested following a blown-in-place (BIP). CPT Myer replied that it is. If the soil tests positive, additional samples are tested. If those too are positive, the soil is removed.

Agenda Item #7. Open Discussion

Mr. Hugus requested that the team discuss the gun and mortar positions additional delineation workplan at the next meeting. He stated that the soil results from the old gun ranges indicate high detections of DNT, such as 1300 ppb, 2100 ppb, 2700 ppb, and 5000 ppb. He said that he is interested in a detailed discussion and suggested that there may be a connection with the Golf and India Range Study, which also detected DNT in the soil. He noted that he is also unclear about the relationship of the soil sampling locations and the gun positions.

Mr. Borci explained that the plan to which Mr. Hugus is referring is to delineate where the detections where the highest; this is a first step. There is a second workplan that will be available January 9, 2002, which addresses the issue of additional characterization at the same gun positions. He suggested that the second workplan be discussed at the January meeting, at which time team members may provide comments.

Mr. Hugus said that he has two major concerns. The first concern is that past activities are determined and contamination is cleaned up. The second concern is making sure that contamination is not continuing. He requested a discussion on whether current firing is depositing propellant in the soils. He noted that nitrocellulose replaced DNT in the soil, but he would like reassurance that DNT is no longer being used

Mr. Schlesinger asked the regulatory agencies to provide the team with a list of their comments on the maps, prior to the next IART meeting. Mr. Murphy suggested that the Guard review recent IART minutes and compile a list of comments that have been made concerning the maps.

Mr. Judge stated that he is interested in the IART being briefed by a Department of Defense (DoD) representative from the Natural Resource Trustee Council (NRTC). He noted that the NRTC is assessing the damages at the MMR, which will ultimately develop an amount of money assigned for cleanup costs and he wants to be certain that the northern part of the base is included in that assessment. He also indicated that he is uncomfortable with the fact that several of the members of the NRTC are also considered to be potential responsible parties (PRP). Mr. Walsh-Rogalski stated that he and Mr. Borci have been sharing comments with the Installation Restoration Program (IRP) lawyer involved with the NRTC to ensure that the entire base and IART-related contaminants will be addressed. Mr. Jasinski clarified that EPA is a federal advisor to the NRTC, while the state is the lead entity. Mr. Pinaud added that DEP is also an advisor to the NRTC and has also submitted comments regarding the northern 1500 acres.

Mr. Judge explained that the reason he requested a DoD representative to address the IART is because the NRTC is comprised of five voting members; one represents the state and the rest are DoD. He also noted that the SMB was turned down as a voting member of the NRTC. He added that the challenge remains of how to ensure that the NRTC is fully aware of the damages and the continuing findings.

Mr. Hugus asked if Mr. Judge is implying that the PRPs will also be the ones assessing damages. Mr. Judge replied that he is. Mr. Hugus said that he is shocked.

Agenda Item #8. Agenda Planning and Review Action Item

Ms. Meli reviewed the action items and future agenda items as follows:

Action Items:

  1. Mr. Hugus requested that "Other Issues" continue to be a regular agenda item.

  2. The Guard will provide an update on the gross alpha detected at MW-181 at the J-3 Range, which will include whether downgradient wells have been tested for DU.

  3. The Guard will follow up on the question regarding whether the 2,6-DNT detect in MW-84 is in the ZOC for the Bourne water supply wells.

  4. The Guard will provide information regarding the cost and engineering impacts involved with the increased flow rate in Alternative 5 in the Demo Area 1 FS.

  5. The Guard will keep the IART updated on the status of the wells scheduled to be installed between Frank Perkins Road and Pew Road.

  6. The Guard will review a list of comments that have been made on the IART maps.

Future Agenda Items:

  • BA-1 Training Area Update

  • Gun and mortar firing positions delineation workplans

Agenda Item #9. Adjourn

Mr. Murphy thanked everyone for attending and adjourned the meeting at 9:35 p.m.

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