Impact
Area Review Team
Quashnet Valley Country Club
Mashpee, MA
December 4, 2001
6:00 p.m.
Meeting Summary
Handouts
Distributed at Meeting:
-
October 23,
2001 Draft Meeting Summary
-
December
4, 2001 Draft Meeting Agenda
-
Responses
to Action Items from the October 23, 2001 IART meeting
-
Impact Area
Groundwater Study Program Update – December 2001
-
In-Situ Treatment
of Explosives Study – Pueblo, Colorado
-
Details of
a Conference with Witness #19 – Second Interview 1/10/01 and 9/22/01
-
Handout for
IART Meeting of 12/4/01 re: Action Item #1
-
Table 7-1
Chemicals of Potential Concern for Human Health CS-19 Study Area
-
IAGWSP Summary
of Nitrocellulose Composition and Environmental Impacts
-
Anomaly Investigation
at the BA-1 (BOMARC) Training Area
-
Appendix
3 – Emission Factor Tables
-
Map: Location
of Geological Cross-Sections CS-19
-
Map: Groundwater
Wells at MMR
-
Presentation
handout: Demo Area 1 Groundwater FS Update
-
Presentation
handout: IAGWSP Investigation Update
-
Presentation
handout: Munitions Survey Project Update
-
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
-
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.
-
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.
-
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.
-
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:
-
Mr. Hugus
requested that "Other Issues" continue to be a regular
agenda item.
-
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.
-
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.
-
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.
-
The Guard
will keep the IART updated on the status of the wells scheduled
to be installed between Frank Perkins Road and Pew Road.
-
The Guard
will review a list of comments that have been made on the IART
maps.
Future Agenda
Items:
Agenda
Item #9. Adjourn
Mr. Murphy thanked
everyone for attending and adjourned the meeting at 9:35 p.m.
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