Area Review Team Meeting
Bourne Best Western
January 25, 2001
Distributed at Meeting:
28, 2000 draft Meeting Minutes
November 28, 2000 Action items
Ordnance (UXO) Discoveries/Dispositions Since 11-28 IART
Commonwealth of Massachusetts Executive Office of Health and Human
Services Department of Public Health, January 25, 2001
States Environmental Protection Agency, Region 1, January 4, 2001
Environmental Protection Agency, Region I, EPA Docket No.: RCRA
1-2001-0014; Administrative Order for Use of Controlled Detonation
Chamber for Regulated Munitions Wastes
from the National Guard Bureau at the January 25, 2001 Public
Hearing on Draft Unilateral Administrative Order, EPA Docket#
Survey Project, IART Briefing – Tetra Tech, Inc.
Handout: Demo Area 1, Draft Groundwater Report
Handout: IAGWSP Investigations Update, AMEC
Handout: Small Arms Range Air and Soil Sampling, AMEC
Handout: Army National Guard, Impact Area Groundwater Study Program,
CPT Bill Myer, MMR Environmental Restoration Chief
Item #1. Welcome, Approval of September 7, 2000 Meeting Minutes,
Review Action Items
and Draft Agenda
At 6:00 p.m., Mr.
Murphy said, "OK People, I’d like to get started. So if team
members could take their seats please? And start off with the introductions
of the people sitting at the table for the benefit of everyone who
is not sitting at the table, and if we could start down this end
with you, Richard…"
Hugus said, "I’m Richard Hugus, a citizen of Falmouth and a
founding member of the Impact Area Review Team."
Zanis said, "Paul Zanis, Resident of Sandwich."
Schlesinger said, "Peter Schlesinger, Sandwich"
Dolan said, "Jane Dolan, EPA"
Borci said, "Todd Borci, EPA"
Mr. Walsh-Rogalski said, "Bill Walsh-Rogalski, EPA"
Adams said, "Margery Adams, EPA"
Murphy said, "Jim Murphy. I’m from EPA, I’m the facilitator"
DeBaggis said, "Deirdre DeBaggis, CH2M HILL"
Deleppo said, "Darrell Deleppo with the Army Corps of Engineers"
Gregson said, "Ben Gregson, Groundwater Study Office"
Knott said, "Joe Knott, National Guard Bureau"
Stahl said, "Jim Stahl, TOSC"
Culligan said, "Trish Culligan, Technical Advisor for the citizens"
Taylor said, "Ray Taylor, Sandwich resident"
Cody said, "Sean Cody, Massachusetts National Guard"
Bailey said, "LTC Don Bailey, Massachusetts National Guard"
Myer said, "Bill Myer, Impact Groundwater Study Office"
Ms. Grillo said, "Ellie Grillo, DEP"
Aker said, "Marty Aker, AFCEE/MMR"
Murphy said, "Thanks. The people standing up, there’s also
seats over here; I know there’s still seats back there, and some
people like to stand. That’s fine also."
Murphy said, "Looking at the November 28 minutes, I just wanted
to see if anyone had any comments or changes on the minutes. Richard."
Hugus said, "Perchlorate, I’m not sure where it is later on
in the minutes. It’s not two words, it is one. Page 5, five paragraphs
up from the bottom, ‘Ms. Adams stated she can not speak to the
rational of B.G. Keefe’ that should be ‘rationale.’ On
page 8, ‘Upper Cape’ should be capitalized, third paragraph
down. Let other people get in if I’m - Page 25 under ‘Background
Soil Concentrations Methodology’ the third line down it should
be, instead of ‘cleanup the background’ to the extent feasible,
it should be ‘cleanup to background." And then page
27 on the first line, it starts with the misspelling of perchlorate.
And on page 33, I’m sure DEP would point this out, but the presenter
was - fifth paragraph down - it’s not ‘Mr. Dahn’, it is ‘Mr.
Dayian’. And in the same paragraph, mentioned ‘sensory wells’
and that should be ‘sentry wells’, and again ‘sentry wells’
on page 34. So just light, small problems."
Murphy said, "Thanks Richard. I note DEP has asked we hold
approval of the minutes, not approve them at this meeting because
the two staff members who made the presentation last month did not
get a chance to review the minutes. So I would like to hold them
before we approve them. We can approve them next meeting. Any additional
Grant said, "Page 20…"
Murphy said, "Could you just introduce yourself, Marc."
Grant said, "Marc Grant, AMEC Environmental. Page 23, second
paragraph, second sentence displayed a map of the ‘J-1-3-L’,
that’s kind of a nomenclature that we use for that work plan that
covers three different ranges. There is a global change: I think
any word that says ‘tract’ should be ‘track’, talks
about particle tracks rather than particle tracts. Page 25, first
paragraph, the word ‘tic’ should be ‘capital T capital
I capital C’, that’s an abbreviation for ‘tentatively identified
compounds’. Page 29, third paragraph, last sentence, ‘the
three SVOC’s were’ and this chemical name is bis-2 ethylhexylphthalate,
next paragraph down the word ‘invalidated’ would be better
said, ‘not’: two words, ‘not validated’. Page 26,
first paragraph under ‘Update on Demo 1’ second to last sentence,
‘profile results are 0.3 and 1.5 ppb RDX which are not (‘not’
is the missing word) not above health advisory."
Murphy said, "Thanks a lot. Any additional comments on the
Drake said, "Richard got ‘Larry Dayian’, and ‘sentry
wells’, but discreet global change ‘d-i-s-c-r-e-t-e’
in this setting."
Murphy said, "Thank you, so we’re all set. We’re going to hold
the approval of the minutes until next month at the request of DEP.
Looking at the agenda, there was - we made an adjustment in the
agenda from the draft agenda that people received in the mail. And
that was to - previously under 8:30 we were going to have a discussion
of EPA Administrative Order number 4. Now we have moved it up to
8:00, and we will suspend the Impact Area Review Team meeting and
have a public hearing on the Administrative Order for use of the
controlled detonation chamber – contained – excuse me, CDC, you
get stuck on the acronyms and forget what the real words mean. Anybody
have any other changes to the agenda before we go ahead? Richard."
Hugus said, "May I have 5 minutes to discuss two topics? One:
the production of a map for the base-wide plumes - and two: a fact
sheet, a new fact sheet."
Murphy said, "OK. So, we can put those under ‘other issues’.
Jan, did you have - OK moving on to the…"
Cambareri said, "I was curious and would like an update on
how the issue with the profiling upgradient of the water supply
wells went on. There was a great deal of conversation, and a number
of forums across Cape Cod. It seemed as if the JPO was on a road
to listen to what was said in those forums."
Murphy said, "OK, if we can put that under ‘Other Issues’ I’m
not sure who will address it at the time, but we’ll - I’m sure Todd
will have something to say.
looking at the action items. There was one change in the action
items that are on people’s tables tonight. Under number six there
was just a slight change in the language of the status and that
was just to make it a little bit more clear. We can cover that when
we get down to it."
Item #2. Review of Action Items
Protection Agency (EPA) agreed to communicate directly with BG
Keefe regarding the issue of making the ammunition supply point
(ASP) inventory available to the public.
Status: EPA has
contacted CPT Sciaraffa of GEN Keefe’s office and is coordinating
Walsh-Rogalski said, "I spoke with CPT Sciaraffa, Legal
counsel for MA Guard, and we agreed on an approach that would
allow EPA - first of all it would require the MA Guard to develop
a comprehensive and comprehensible inventory of the ASP. Todd
Borci, on behalf of EPA, would then inspect the ASP with this
inventory to see whether or not it was accurate. We wouldn’t
then take the inventory because it would then be subject to
FOIA. So their concern is that the document would become public,
our concern is we can’t hold a document such as that, from the
public. This is an interim step, we still haven’t figured out
how to make this information available to the public, but we
both agreed that as at least one way to move forward, we could
create this inventory and inspect the ASP and find out what
was in there and the EPA would not leave with any kind of written
Murphy said, "Richard, you have a comment?"
Hugus said, "Yeah, about the ASP. I approve of EPA sending
Todd Borci to look at the contents of the ASP, but still maintain
that the public has a Right-to-know what the contents of that
supply point are, and don’t want that to be lost sight of. I
know that MADEP is looking into Right-to-know provisions on
this issue and I’d like to hear what they’ve come up with on
Pinaud said, "I’m sorry, was the question that DEP was
looking into Right-to-know issues?"
Hugus said, "Yes, according to minutes of the technical
meeting, I believe."
Pinaud said, "I do not recall that. I don’t believe we
Hugus said, "Well, maybe I can ask that you and EPA do
so, look into community Right-to-know policies and see if we
do have standing there. As I said before, it was only because
the community did become involved in what was going on at Camp
Edwards that we have found and uncovered all the damage and
contamination that has been uncovered. And I don’t think a door
should be shut on us on this issue because of the Guard’s claim
of national security or just plain security at this point, because
this issue has been debated for so long anybody who cared to
know would have found out by now that the ASP is not even guarded.
So this just made matters worse for the National Guard in terms
of what they say they are worried about."
Walsh-Rogalski said, "One point, Richard. We did at one
point, research the Federal EPCRA; the Community Right-to-know
law, and at that point phosphorus was the only thing that would
have triggered Right-to-know in a minimum threshold and wasn’t
reached at that point. That’s my memory of the research that
we did, so maybe after this inventory is done and Todd takes
a look at it, we can take a look at the thresholds again. But
at least the last time no thresholds were triggered, and assuming
that the inventory has decreased as has been represented I don’t
think EPCRA, the federal law, is triggered."
Hugus said, "Sorry, I must have confused EPA with DEP on
this issue. But do I understand that when it comes to explosives
the community doesn’t have any right-to-know grounds. Is that
Walsh Rogalski said, "I’m hesitant to answer that without
taking a look at it specifically. All that I remember is last
time I looked, and the only thing that was on the ultra-hazardous
list that we thought would have been stored there was white
phosphorus. And that would have been the thing that triggered
it, but I’ll go back and look at it again."
Murphy said, "Len."
Pinaud said, "I’d like to know if the Guard has a position
on this Right-to-know issue? Either the Guard Bureau or the
Cody said, "This is Sean Cody with the Massachusetts National
Guard. I believe that CPT Sciaraffa and Mr. Walsh-Rogalski were
discussing that. So the Massachusetts National Guard’s position
is that it doesn’t want to give out the inventory due to security
Murphy said, "Peter."
said, "I think we’ve gone this route before, but why won’t
they give out constituents if they won’t give out the actual
rounds. Why can’t you just tell us what’s in them? I mean really,
we’re trying to work together, we’re not being confrontational
about it, we are trying to get a job done. Why can’t you just
tell us what the constituents are? We can calculate the quantities
we know from the previous inventory what was there, but if you
could tell us the constituents of those materials at least we
could make some calculations."
Bailey said, "I think we have been talking about this for
a long time, and the discussion has elevated well above my level.
If it was an easy answer it would have been resolved long before
now, that’s why it is between the legal people, whatever they
work out is what they work out. There is not much more that
I can add to that."
Murphy said, "OK. Are we ready to move on?"
requested the Army Corps of Engineers (USACE) to look into whether
potential contractors can present their qualifications at an IART
Status: The IART can review the draft evaluation
criteria that will be used in the RFP; however, after checking
with Corps Contracting and Legal Counsel personnel, Federal Procurement
Regulations do not allow for potential contractors to present
their qualifications to the IART during the procurement process.
Deleppo said, "I can answer…"
Murphy said, "OK. There is a written answer, if people
want to go through each one of those that’s what we’ll do or
if - I guess that’s what we’ll do unless somebody wants to skip
Zanis said, "There is a question from the audience."
Murphy said, "I just saw that. After Darrell speaks, if
anybody from the audience has a question - if you could just
come up to the microphone, that would help me see and recognize
you, after Darrell…"
Deleppo said, "On action item number two, this question
from Joel. The history on this is that the Corps is going to
hire a contractor to do work at MMR. And the question was -
I think revolves around the input that the IART can have on
the selection of that contractor. And I’ve been asked to check
into during the presentation - or of there is going to be presentations
of the contractor qualifications - if they could be done at
an IART meeting. And after checking with the folks that work
on this in the Contracting and Legal Counsel at our office in
Concord, the regulations don’t allow for that - for any kind
of presentation during the selection process of the contractor
to be open to the public. So we are not allowed to do that.
I also have stated in the past about finding a way to get your
input on the selection criteria that we’re going to use, and
what I want to say tonight is that I think in the next mailing
I can send out what that criteria would look like. I can send
you a copy of a previous solicitation that we’ve done that is
probably going to be used as a model for the new one. The new
one hasn’t been approved yet through the Corps Higher Headquarters
and that’s probably not likely to happen until the end of March
timeframe and that’s when the actual proposal will go out to
the public. And then again, then it will be open to the public
and anybody can see it. But to get your input ahead of time,
we’re trying to get you some information, I guess next week
will be the next mailing; and then get your feedback by the
next IART meeting, which is, I think the twenty-eighth of February?"
Murphy said, "Tuesday, February 27, is what we’re going
to discuss at the end of the meeting."
Deleppo said, "So that’s our plan for that, to get your
input on that criteria before we send it out."
Murphy said, "Thanks, Darrell. Dick."
Judge said, "Thank you for taking me out of order. I’ve
got a selectman’s meeting to jump over to. Just a quick comment
and it does have to do with the Administrative Order number
four. As an SMB member I was surprised to wake up this morning
to the paper and read what I read, considering there were plenty
of opportunities for late breaking news at the SMB meeting last
night. I just would like to make sure that we continue to get
information as soon as possible and that perhaps Joe, you can
answer to this, maybe why it wasn’t brought up last night under
late breaking news?"
Knott said, "Hi Dick. AO4? I had two slides and we went
Judge said, "No, that you were not going to - was I sleeping
through it - that you were going to contest the AO4."
Murphy said, "You were busy facilitating the meeting."
Knott said, "Actually, on the second slide, the last bullet,
it said in general that we were going to send a letter and that
we were going to request and meet with the Administrator from
EPA headquarters under the RCRA, the Order."
Judge said, "Thanks Joe. My mistake, thank you."
Murphy said, "David…"
Dow said, "This is David Dow with the Sierra Club. When
we had our Community Working Group meeting on Friday over in
Sandwich, I raised the issue of finding out what kind of hazardous
substances were in the munitions storage area. Because, when
we develop our plan - which is supposed to be submitted to us
by March thirty-first by the Massachusetts Army National Guard
- we actually have to know what kind of hazardous substances
are there. I’m not concerned about what kinds of rounds and
stuff, but to coordinate the environmental performance standards
and the compatible training, you actually need to know this,
and this issue wasn’t addressed in our drafts. But I presume
the Massachusetts Army National Guard is going to address it
in the final environmental impact report and master plan. So
I would second Peter’s suggestion."
Murphy said, "Thanks, David. OK, the next action item –
Oh - I didn’t see your card, if you - I do have new glasses
tonight Joel, I still didn’t see the card."
Feigenbaum said, "Well, are they just for reading or."
Murphy said, "No, well I can see about as far as you."
Feigenbaum said, "I’m not going to add to the lengthy discussion
we’ve already had about the Guard stonewalling on the supply
point. I mean, I’m opposed to this holding up of information
but it is up to the EPA attorneys, I guess. There are lawyers
to take care of this so there is not much we can do except invade
the supply point I suppose, but that’s probably not advisable."
Walsh-Rogalski said, "If you do that, get an inventory
on the way out."
Feigenbaum said, "OK, I’ll probably get an inventory of
lead in our bellies. So the answer here is no, we can’t be a
part of the selection process of the contractors, is that right?"
Deleppo said, "Yes."
Feigenbaum said, "And who is going to do that? Is that
going to be the Corps? Or is that going to be the Guard?"
Deleppo said, "That will be the Corps of Engineers"
Feigenbaum said, "So the Guard is giving over that authority
to the Corps? I’d be curious what allows the Guard to just transfer
its authority. This is one of the major concerns of the cleanup,
a good contractor do a good job. A lousy contractor is going
to do a lousy job, and considering the Corps just came into
town, it seems kind of strange that they would then have this
whole authority. Can anyone explain that?"
Murphy said, "Len do you want to comment?"
Feigenbaum said, "I’m looking for an explanation of where
the Corps all of a sudden gets this authority."
Deleppo said, "Well, the Guard has designated the Army
Corps of Engineers as the supervising contractor. And we were
in the business of doing this type of environmental work. And
they have basically designated us to do that and given us the
authority to use our contracting mechanisms - which are the
same as the Guard and the same federal acquisitions regulations
they would use to hire a contractor. We’ll follow the same rules
that they would have followed, and hire this contractor for
Feigenbaum said, "So they can’t, the Guard can’t hire their
own contractors? Is that what you are saying? They don’t have
the ability? I mean, what’s going on here?"
Knott said, "I think your confused, Joel, with what’s going
Feigenbaum said, "I am."
Knott Said, "Let me help you out. The contract that is
referenced here, that you’re talking to Darrell about being
part of the selection process, is a Corps of Engineers contract.
A term - not to bring in any acronyms to confuse people - but
is a ‘Corps contract’.
contract that AMEC, formerly Ogden is under, is a National Guard
Bureau contract. And the follow on the National Guard Bureau
contract, again is a National Guard Bureau contract that has
been going on. The solicitation is out, AMEC has put in and
various other companies.
confusion is that we have got that Guard contract that is replacing
the Ogden contract, that’s going on, that is a Guard contract.
The Corps is a 100 million dollar contract that is centered
on MMR. Not all the work will be done here, but it is centered
on MMR to help. Another tool in the toolbox for the Corps, to
meet the requirements here, so it is a Corps of Engineers contract.
It’s not the AMEC contract that is not making sense. It is a
couple of contracts out there - and this is a Corps of Engineers
contract, and that’s why their doing their contract."
Feigenbaum said, "But it could have been done, just the
other out and through the Guard contract, right?"
Knott said, "The Guard contract is still going on, we’re
still pursuing. It’s been going on for I’m guessing, about a
year or so for that procurement. These are multiple contracts
too. Again, more tools in the toolbox to do the best job that
Feigenbaum said, "Is this for the cleanup of the contaminated
water, the explosives, is the soil…what are we talking about
Deleppo said, "The contract will be able to be used to
do any kind of environmental work on the base, so studies, design
and cleanup. All those different things."
Feigenbaum said, "So all that could have been done under
a Guard contract though."
Deleppo said, "That’s right."
Feigenbaum said, "But the Guard has somehow chosen to hand
over its authority to the Corps."
Deleppo said, "Not the authority. Just the contracting
effort will be done by the Corps for the Guard."
Feigenbaum said, "But that’s the authority to choose a
contractor. This is pretty straight forward, right? The Guard
is saying to the Corps, you choose the contractor that we would
have chosen if you weren’t here."
Knott said, "No, Joel, we’ve got 2 separate contract actions.
Both the National Guard Bureau contract - which is out now going
on covers all things also - through cleanup and remediation.
The Corps of Engineers has a separate contract that covers all
things: cleanup, study information. Both those contracts will
be available for use in the Groundwater Study."
Feigenbaum said, "Well how are you going to determine which
contract - it sounds like duplication."
Deleppo said, "Let me offer this as an example of how it
works. The - we’re going to talk about the CDC later. The CDC
being here, it was brought here under a Corps of Engineers contract.
The Guard asked the Corps to get it and bring it here and a
Corps of Engineers contract was used to do it. So again, the
Guard is going to ask the corps to work on the cleanup. And
they have a choice of using their own contracts or asking us
to do it. It is the way the Army does business all across the
nation. That is just the way the Army does business. The Corps
of Engineers is an engineering organization that’s available
to any part of the Army; in fact, the EPA uses the same contracts.
They have hired the Corps to cleanup superfund sites using these
same type of contracts."
Feigenbaum said, "Well, be that as it may; why is it not
possible for us to interview potential contractors? Apart from
- obviously nobody would be asking to see the bids if there
are competitive bids, but why can’t we talk to these people?
What is the legal bar against that?"
Deleppo said, "Maybe it would be helpful if - tonight our
counsel, legal counsel from the Concord office is here. Her
name is Mary Byers and maybe she can help explain that a little
better than I could."
Murphy said, "If you could just use the microphone back
Byers said, "I’m Mary Byers. I am the district counsel
for the New England District Corps of Engineers. I think your
question is; why can’t you be part of the selection process,
is that correct?"
Feigenbaum said, "That’s what I said."
Byers said, "OK, I just want to verify that that is the
question you have. Under the Federal Acquisition Regulation,
which is the way we do federal procurements in the government,
and under the Procurement Integrity Act - only government employees
or contractors of the government can be part of the evaluation
reason is we have to keep proprietary information confidential
and we cannot release it to the public because we cannot guarantee
that those people who see it would not release it. Those members
of the boards are required to sign statements that have potential
criminal sanctions for releasing any information. In fact, if
they leave the government they have to ensure that they can’t
release that information for 5 years. So they are required to
keep the information proprietary. That includes all the competitive
process, the bids, the proposals, any of the technical information,
all that information that is presented in proposals by contractors
and reviewed. And the competitive determinations are made and
a selection is made. That is all confidential and proprietary
until there is an award. And even parts of those contracts,
those proposals; for example, would not be released to the public
after an award is made because they are confidential and proprietary.
So we’re trying to ensure that the competitive bidding process
is secure. And that is under the Federal Acquisition Regulation,
and Federal Procurement Integrity Act."
said, "Well, that really doesn’t answer my question."
said, "OK Joel, I was going to let COL Murphy respond and
then I think Len had a comment and then maybe we can try to move
on, maybe you can talk to them more after the meeting."
Feigenbaum said, "Well, this is a subject for long discussion.
Last time around we were kind of shocked that Ogden, a.k.a whatever
they are now - AMEC, wasn’t just going to continue sort of automatically.
And, you know, we had a long discussion about how we can be
involved in the process to make sure it was all above board
and we have enough doubts about the Corps, let alone their favorite
contractors; and so now you’re saying let’s move this out and
I’ll talk to somebody later."
Murphy said, "Let’s see what COL Murphy has to say, and
then Lenny, and then we’ll see."
Murphy said, "Basically what I was asking Jim - I’m Richard
Murphy from the National Guard Bureau - basically just that,
that we do move on. I think what we are doing is within the
order. I think that Joel has been noted that he doesn’t like
the process. But this is not, it’s not a scheme to do anything.
We are simply widening the availability of the process that
we knead into this. And I would ask that you try to keep the
meeting on track and not have it diverted quite so long. There
are other more relevant issues that really need to be discussed.
We’re not attempting to do anything wrong. And I think Joel’s
concerns should appropriately be noted, and let the meeting
go on to some more relevant issues."
Murphy said, "Len."
Pinaud said, "You can correct me if I am wrong but I thought
that AO1 and AO3 said something about EPA concurrence with contractors
selected. And I know that doesn’t speak directly as to what
the action item is, but it might give the team some comfort
if they know that EPA has to concur with the contractor issue."
Murphy said, "Both orders provide that EPA approves supervisor
contractors and all subs. OK, and Richard you have a comment
also, and then I’d like to move it along if we could."
Feigenbaum said, "I’d like to come back."
Murphy said, "You get one more shot."
Hugus said, "Yeah, I think we can spend time on this, it
is after all our…the whole future work here. As one of the people
who asked for citizen involvement in selecting a contractor,
I made it clear that we didn’t want proprietary information
about contractors. We just wanted to know what their record
was. And from my point of view this is sort of like the ammo
supply point issue. The military’s coming in and saying essentially
the citizens, the public don’t have the right to democratic
involvement. It is the same thing and in one case it is because
of national security, or security; and in this case it has to
do with so-called proprietary information. And to me this is
just a subverting of democratic procedure."
Murphy said, "Joel?"
Feigenbaum said, "Yeah, see, I don’t - the lawyer didn’t
answer my question, maybe you could."
Byers said, "It’s prohibited by law. That is the answer."
Feigenbaum said, "What is? Now, what is prohibited by law
is revealing to us proprietary information. But is it prohibited
by law for a prospective contractor to come here and tell us
what kind of work they’ve done in the past?"
Byers said, "It is prohibited for us to release any information
about any contractor during the evaluation process. Our evaluators
are not even supposed to know the names of the contractors,
OK. They are supposed to look at them as if they don’t know
who they are, look at them technically, and make determinations…"
Feigenbaum said, "So then it’s not just a question of proprietary
Byers said, "That’s what we’re trying to protect, under
Feigenbaum said, "But if a contractor came in here and
said, well I worked at Pease air force base and did such and
such a cleanup, what is proprietary about that?"
Byers said, "The problem is that I wouldn’t be able to
tell you who those contractors were until after we have made
a selection. We are not allowed to release any information about
the proposers for a contract until after a contract has been
Feigenbaum said, "So the issue of proprietary acknowledges…that’s
a red herring."
Byers said, "No, its not."
Feigenbaum said, "You’re just not allowed to release any
Ms. Byers said, "But we’re trying to protect proprietary
information, that’s the reason why the federal procurement law…"
Feigenbaum said, "So you think if we found out that they
worked at Pease air force base that somehow we’d be able to
sneak under the table and find out proprietary information?
It doesn’t make sense."
Murphy said, "Joel, I don’t think we’re going to get anywhere
with this one tonight, if you want to…"
Feigenbaum interrupted, "But these people are preparing
to spend something, like a quarter of a billion dollars on this
project and I think the public has some interest in making sure
that this is not just a sweetheart deal between the Corps and
one of their favorite contractors. I don’t know what protection
there is in this thing."
Byers said, "There is no such thing as a favorite contractor
in procurement law. It is fairly competed, that’s why we have
the procurement laws."
said, "OK Thank you. Moving along to number three."
requested that the Massachusetts Department of Environmental Protection
(MADEP) add nitroglycerine to their MCP reporting list.
Nitroglycerine is currently on the Massachusetts Contingency Plan
Oil and Hazardous Material List with a Reporting Quantity of 5
lbs and a Reporting Concentration of 0.5 mg/l (ppm) in groundwater
(RCGW1) and a Reporting Concentration of 50 mg/kg (ppm) in soil
(RCS1). If the intent of the request was to add nitroglycerine
to the MCP Method 1 Cleanup standards, please be advised that
nitroglycerine is not currently on the list of compounds under
consideration for a change or establishment of a Method 1 standard
for promulgation in spring, 2001. However, a Method 1 cleanup
standard for nitroglycerine is being considered for future MCP
revisions and MADEP may establish an interim standard for nitroglycerine
in the near term.
Murphy said, "There is a long written response, does anybody
have any, want to comment on that? OK, Joe…"
Knott said, "I just think it was well written."
Murphy said, "Well written reply. Jim."
Hugus said, "I also asked that MADEP raise their standards
across the board in the MCP for levels of explosives in soil.
That is not reflected in the action item. But I say it for the
Pinaud said, "I think you’ve made that clear to Millie
Garcia-Surette and I think she’s responded to you saying she
has brought it to the attention to senior management within
DEP and they are actively trying to do that."
Murphy said, "OK, number four…"
agreed to measure the distance from the firing ranges to Greenway
Status: On December 20, 2000, MADEP measured
the distance from the firing positions at Ranges O and P to Greenway
Road. Ranges O and P are the ranges closest to Greenway
Road and the direction of fire is to the west or into the Impact
Area (away from Greenway Road). At the O Range, the distance
from the firing positions to the western edge of Greenway Road
is 210 feet. At the P Range, the distance from the firing
positions to the western edge of Greenway Road is 410 feet.
Murphy said, "There’s a status update on that. Any comment
on that? OK, number five…"
requested that future IART agendas be revised to allow more time
to discuss Action items as a separate agenda item.
the IART agenda format has been revised so that the action items
are discussed as a separate agenda item.
Murphy said, "That’s what we are currently doing. Number
Area Groundwater Study Program (IAGWSP) office will inquire whether
or not the USACE has funding to support IART citizen members at
Status: The Guard has asked the Corps
to investigate a technical assistance contract, to enhance the
assistance IART citizen members currently receive from TOSC.
Murphy said, "Do you want to say anything to that Darrell?
Knott said, "The bottom line is that we have asked the
Corps to do that and we would like to take the opportunity tonight
to ask for a citizen volunteer on the IART to help them in that
process. Not to get into too much terminology again, but the
scope of work, ask the Corps, see what we can do to investigate
some kind of technical assistance to help the TOSC. Obviously,
the TOSC is doing a great job, but we have some limitations
with the TOSC so the citizens would like more than just the
TOSC. So we ask that as we pursue this avenue to try to get
the citizens some assistance, and we make sure that as we go
out we know that package, that scope of work, that the citizens
want to make sure this contractor has. So we’re hoping we can
ask for a volunteer tonight to work with Darrell and the Corps:
on here’s what the citizens would like, the qualifications etc…"
Schlesinger said, "I took it on before. I’ll be happy to
jump to the task providing I get some cooperation from the rest
of you guys. Joel, Tom, everyone else here."
said, "Sounds like you are it. Number seven…"
Tech agreed to provide a map that illustrates all current and
future investigation areas for the Munitions Survey.
Tetra Tech will provide this map at the meeting as part of their
Munitions Update handout.
Murphy said, "Some maps are going to be provided tonight.
Dr. Feigenbaum requests number eight…"
will provide the IART a listing of their relevant UXO experience
including, but not limited to, quantity and types of UXO, locations,
and disposal mechanisms.
Status: In response to his request,
a comprehensive report is provided in the IART mailing.
Murphy said, "That was provided in the mailing. Number
will report an ASR Update at the February IART.
The USACE will present the ASR update at the February IART meeting.
Murphy said, "That is still going to happen. And the following
are on the agenda."
item will be included on the January 2001 IART agenda:
Murphy said, "OK, that is the action items. Moving on to the
Demo 1 Groundwater Report."
Knott said, "Draft…"
Murphy said, "Draft Groundwater Report, Thank you. And
Darrell is going to introduce it, and then Marc will…"
Deleppo said, "Yeah, I just wanted to say before Marc got started
is that the draft Groundwater Report, and the topic of Marc’s discussion
about identifying contaminants of concern is something that we want
your feedback on. We’ve asked that the regulators respond back by
the eighth of February, and if we’d like to take your verbal comments
tonight on it and also try to keep that eighth of February time
frame to keep the project moving along. And Tina Dolen at the Groundwater
Office is going to be the collector of these comments. But again,
tonight verbal comments are absolutely acceptable."
Murphy said, "Does Tina want them by email, or how does she
want to receive them?"
Dolen said, "I’ll receive them voice mail or email which is
so thank you, I’ll look forward to hearing from you."
Murphy said, "You want to comment on it before it gets going,
Schlesinger said, "Oh, well, are you asking for the comments
now or after the presentation?"
Murphy said, "After the presentation."
Schlesinger said, "OK, that’s fine."
Murphy said, "You are very anxious down there."
Schlesinger said, "I just don’t want to have to email to respond
Item #3. Demo 1 draft Groundwater Report - AMEC
Grant said, "OK, our presentation is on the Demo 1 Groundwater
Report. There is a handout that you have that has the word slides;
it also has at the end of the handout the map that will be showing
during presentation. Just to put this report in context, this is
one of several documents that are coming out on Demo 1 in the next
couple of months.
1 was divided into soil and groundwater operable units. The purpose
being to allow them to perceive separately into sight characterization
and feasibility studies so that everything can go a little bit more
quickly. So, this groundwater report is the first report out, it’s
a site characterization report. Basically, it is describing what
we found and where we found it, what seems to be the problems and
any additional data needs. That’s going to be followed up with a
Groundwater FS screening report, abbreviated here ‘FSSR’ actually
coming out next week which is very quickly and we are overlapping
site characterization and feasibility study quite a bit in order
to compress schedule here. And basically what we did is back in
early December; we issued a contaminants of concern identification
document, which set the stage for completing both the Groundwater
Report and the Groundwater FSSR. And we got agency comment and input
on that COC report, and once we got that we started finalizing both
the site characterization and feasibility study parts of those reports.
soil reports both for site characterization and FS are a little
bit behind the groundwater, that’s owing to a later characterization
effort, there’s additional information coming in later, on soil.
So, those will be coming out in March for the site characterization
report and April for the FS report.
we are going to do briefly is to update the types of contaminants,
where they are located, the COC’s which we need to look at for evaluation
remedies, and identifying any additional data needs, and the next
couple of slides are going to cover each one of these three bullets.
terms of nature and extent of contamination, this is not a surprise,
but there is a site update with new information about the latest
wells we put in. The RDX plume extends about 3500 feet west of Demo
Area 1 and is about 400 feet wide. The latest wells that we put
in are at MW-114, 129 and 139. And what we are drawing here are
different concentrations of RDX in the Plume, the outermost concentration
being anything above detection limit but less than health advisory.
The lighter orange being between health advisory and 100ppb. And
the brown being the most concentrated, above 100ppb.
color report also identifies plumes for other contaminants aside
from RDX, and there’s other figures in the reports that address
those, but RDX is basically the one to be worried about or looking
at. The other explosive plumes occur inside the RDX plume, the other
explosives aren’t as mobile as RDX either because of transport properties
of because they break down more quickly, so those are contained
within the RDX plume, they do not extend as far as the RDX. The
last point here is that perchlorate has recently been detected and
it appears to be basically in the same area that we have the RDX
added perchlorate as a groundwater analyte starting in August this
past year, and when we found some initial detects of perchlorate
in the Demo 1 area, we expanded the numbers of wells that were being
sampled for perchlorate to include all the wells in the plume area.
Recently we obtained the additional perchlorate information, which
suggests that the most concentrated levels of perchlorate are up
here, towards the front end of the RDX plume. There is a fairly
low level here at MW-139, which was cleanup RDX but has about 8ppb
of perchlorate. As we mentioned in last meeting there is not a federal
drinking water standard this time for perchlorate. There are the
numbers that California uses for drinking water criteria, which
are 18ppb, and also as Todd mentioned last time there’s an effort
under way to propose a federal standard of around 32ppb."
Borci said, "Marc, I actually heard today that it might actually
be 18 or lower, so…and 18 is also, Region 9 has a PRG ‘Preliminary
Remediation Goal’ and that’s 18ppb also."
Grant said, "OK. So the level we are seeing out in front at
139 is a little bit below the 18. And then we have much higher levels
here in the plume, in the RDX plume, these data are not validated
yet, but these are in the order of a couple hundred ppb in here
Zanis said, "Marc, can I uh…"
Grant said, "Yup."
Zanis said, "Back in the beginning when we talked about all
the chemicals of concern that we are looking for; and I talked about
rocket fuels and all this…how did this get left behind? Perchlorates
– when we know they’re out there in groundwater, they are a problem.
What happened to that?"
Grant said, "I’m not sure what the history of…"
Borci said, "I mean, perchlorate is something that, that most…it
started out in California because there is a significant number
of rocket plants and most municipalities are going to be testing
for it next year in water supplies. But it has only come about as
a contaminant of concern at a lot of sites recently and when it
comes to open detonation; open burn areas like Demo 1 is, its just
recently, I believe there are only a couple defined perchlorate
RDX plumes in the country, so…"
Zanis said, "I know, but we have discussed this three – well
- how many years ago?"
Dolan said, "Paul, I just want to throw in that over a year
ago we started looking at additional analytes to…we should consider
and it was all documented in a…we call it a ‘PEP Analytical report’
and they started working on that over a year ago. So, it took a
while to get to this point but we were thinking about it."
Grant said, "Yes, it does take a little bit of time to add
the analytes and when we add the analytes, not knowing how important
it was going to be the fact that we would have these detections
at Demo 1; we didn’t add them for every well, we added them for
a selection of wells that we thought would give us an idea of how
pervasive perchlorate would be or whether it would be found at all…"
Zanis said, "I see we have to resample…our whole study could
change because of this. The KD Ranges, the old rocket ranges, we
might have contamination of perchlorates all over the place and
don’t even know it."
Grant said, "Yes, there’s definitely some other locations.
Today, we were talking in today’s tech meeting about the future
places we should be looking for perchlorate; but the August sampling
round did include a large number of wells that were kind of scattered
throughout and included some far field wells too and the majority
of those were coming up clean. The only perchlorate detects we have
so far appear to be in Demo 1 and then the J-3 Range area. So, it
is possible that there are things like the KD Range and we need
to look at that, but it doesn’t look like a pervasive problem in
terms of something that we’ve totally missed."
Zanis said, "I mean how about the old rocket ranges where that
water - since perchlorates are even ahead of RDX – so some of these
old rocket ranges that are so old; the perchlorates could already
be way off base. They could have moved."
Borci said, "Paul, we - when we chose the first wells to look
at to sample for perchlorate, we tried to cover almost all the far
field wells, and they were scattered spatially over the entire base.
So Demo 1 was the only area that came up. After that, after we knew
that we had it at least at Demo 1, we took an even closer look and
we sampled some other wells in the J Ranges and now we are taking
an even closer look and we’re going to spot points exactly like
you are mentioning. A lot of the rocket, three and a half inch rockets,
we’ll go into any firing points, any wells that we have downgradient,
I mean we are giving you a very close look right now so…"
Zanis said, "Could this account for some of the TIC’s that
we are getting?"
Grant said, "Probably not. The TIC’s we generally have a good
idea of the type of chemical compounds that are involved, and generally
they haven’t been this kind of inorganic ion that we’re measuring
with a separate test."
Zanis said, "Do we know what it breaks down to, what its daughter
products are? Do we have that now so we can look for them maybe?
As we sample."
Grant said, "I’m not sure what the…"
Zanis said, "Jim, do you know?"
Stahl said, ", I’d have to look it up."
Zanis said, "I think we need to know. I don’t want to drink
Grant said, "OK, the next one of those purposes that the report
addresses is identifying contaminants of concern which we kind-of
like call COC’s and the ones that are addressed are identified in
the report are explosive compounds, RDX, HMX, TNT, TNT a couple
of TNT breakdown products and also 2,4 DNT which is an ingredient
in propellants. Those are the ones that are definitely identified.
The report also mentions perchlorate as a likely COC, but at the
time, they were getting the report information wasn’t coming out
quite fast enough to work into the report. So at this point, it
is something that we’re going to have to address in the future in
terms of getting that as a COC.
are some other compounds that were detected in groundwater in the
vicinity of Demo 1 that were looked at in this groundwater report
that were said not to be COC’s and the process for doing that was
something that was approved by EPA. It is basically - we call it
a ‘Risk Management Evaluation’ it includes – although EPA approved
the process it didn’t obviously give up their right to reject any
arguments that we make in following the process – in this particular
report the arguments that we make are that ammonia, six metals and
four organic compounds are not COC’s due to one of several risk
management evaluation options, such as: comparison to background
levels, look at the frequencies of detections of those compounds,
whether the compounds might be an artifact of sampling analysis
or some other factors. And I think this was highlighted as one of
the topics that the agencies are looking for input from the review
Borci said, "I just want to jump in and add to what Marc is
saying is that we have a whole list of contaminants that have been
detected and just because it is detected doesn’t mean that we are
going to be designing remedial system; and that’s what the - when
says risk management – it takes a look at; the high hit wasn’t at
the source area and was outside of what we would consider the plume
therefore we are not going to design a treatment system to go after
something that is probably a background level. That’s what we’re
talking about. We are starting to narrow down the list so that we
can design – start to think about the design for the remedial system."
Murphy said, "Richard…"
Hugus said, "Yeah, you’re asking for input on the things that
have been selected out. Is that correct? The contaminants of concern
Borci said, "Yes. In the report it lists why ammonia isn’t
a COC and…"
Hugus said, "Well, let me ask you, do you think there are certain
things that should have been selected out? Should not have been
selected out? I know that the Guard doesn’t feel that arsenic, thallium,
dieldrin, benzene, BEHP, and antimony are concerns."
Borci said, "Right now the report, I think, is a very good
report and I think the reasoning in the report is valid and the
COC’s that we come up with at the end that will design the remedial
system for…I agree with them. So, we haven’t formally submitted
our comments, get some feedback tonight on how you folks feel and
then we’ll be submitting our comments."
Grant said, "The last one of the topics addressed in the report
is additional data needs. And there are a couple of things we are
doing here – one is we’re continuing long-term groundwater monitoring,
both for explosives and perchlorate. We do have one complete round
of perchlorate data for the Demo 1 area now. Obviously we want to
collect additional rounds to see if there are repeatability of results,
if there’s apparent changes or trends in concentrations over time.
129 and 139 were the three newest wells. Again, those have been
sampled just once, even for explosives, never mind perchlorate,
so we would like to collect some additional data for those wells.
There’s obviously always the evaluation of whether we need to put
in additional wells. In this case, as we have in the past, the most
likely place for those additional wells would be the leading edge
of the explosive plume. Particularly if we were unsure of how the
perchlorate looks in that area. Again, at this point the perchlorate
data is so new we haven’t even mapped them up the way we have for
RDX. So those are things we will be considering in the next weeks
and months as we move forward to decide whether we need additional
wells, those could be put in now in the tail end of the site characterization
effort. They could be put in later if they weren’t critical to designing
the solution – as the solution enters preliminary design"
Zanis said, "Marc, I think we need to find the leading edge
of the RDX, the well 114- is that still over 100ppb?"
Grant said, "Yeah, 114 is 142ppb in the first sample, the first
and only sample that was collected from that well. MW139 was non
detect for the screened sample, however, when we profiled that location
we were getting some low level RDX detections, so it looks now like
139 is right at the very leading edge and we are kind of at a spot
where we are going in and out of contamination. As we continue sampling
rounds at 139 we may start to notice low levels of RDX creeping
Zanis said, "I mean, I’d tend to think the void in between
139 and 129 could be turning more to the south, and like we said
before, you still have over 100ppb past 139, just south of it, and
that well 139, there’s a beam of the center part of the plume."
Grant said, "Right, as Jim mentioned we’ve been finding that
this plume is moving a little bit further south than the groundwater
modeling originally suggested, and that’s why we wound up with a
lot of wells to the north like 33, 32 and 35…"
Zanis said, "A little off course - the time frame doesn’t figure
on the length of that plume, in my mind. I’d hate to see us miss
Grant said, "Right. Another point of interest, MW-78 which
has been clean for RDX so far has a little perchlorate in it. So
again, perchlorate generally is in the same area, it may be a little
bit wider or a little bit further south for some reason. So once
we look at the perchlorate plume geometry, and match it up with
RDX we’ll be thinking about what we need for additional wells in
Zanis said, "So we definitely do, I think, we need a couple
of more wells as far as south on 139 at least."
Borci said, "Yes, Paul, one of the points is that we have enough
information on the characteristics of the contaminants to start
going forward …that’s why the feasibility screening report…"|
Mr. Zanis said, "I understand…"
Borci continued, "Also, where the plume is we’re sort of lucky,
is it Frank Perkins or Burgoyne Road – actually you can’t really
see it, so we have a nice wide road that we can…"
Grant said, "Frank Perkins is right here and then you have
a tank trail just inside Frank Perkins over here. So you’ve got
a couple points of access over here to the west which; so far, we
think are still clean."
Zanis said, "Nice place for a treatment facility."
Mr. Murphy said,
"Peter, do you have some comments?"
Schlesinger said, "Yeah, I was going to bring them up later
but I can’t control myself. So, first I don’t think that the lateral
extent is well enough determined. I think that we don’t know that
the bounds are - I mean, I just question that the amount of information
we know gives us the ability to draw such a narrow plume up towards
the source and question, why aren’t we looking for more of the shape
of the plume from the source. I mean, we have so few wells near
the source how can we say it…"
Grant said, "Well, the concentration gradients have been really
sharp telling us that it does appear to be very narrow. This location
is far enough away from the top of the mound so there probably isn’t
a whole lot of wiggle going on, at least we are not seeing wiggle
in the concentrations we’ve measured so far."
Schlesinger said, "But you are already saying that it’s moving
farther south than you expected."
Grant said, "It’s right, it is…"
Schlesinger said, "So therefore you don’t have a…"
Borci said, "Peter, the five wells that go through the center,
that was their purpose. And where the outer two are clean, you know,
you are also looking at a map, but distance wise those are pretty
tight for a well fence going the width of the plume. So, where 78,
we’re going to keep an eye on that and where 129 has a hit also
that’s going to be taken into account when we place further wells
downgradient. But that plume shape doesn’t match what we would expect
to see coming from there."
Schlesinger said, "I just question why we don’t have a well
south – I can’t read the number because of my angle where I’m located
in this room – but is it the single well that’s located just downgradient
of the source, what well is that?"
Borci said, "Thirty-one"
Schlesinger said, "Thirty-one, I’m just questioning why there
isn’t something further south than that point."
Borci said, "Because the distance between 31 and that well
fence is actually pretty short and we could put another well there
but you don’t necessarily - 78 gives us that information."
Schlesinger said, "I just - our folks, our colleagues from
MIT constantly expressed to us the need to establish the extent
more at the source than at the very end. And I’m just hoping that
we would spend more time trying to find out where this stuff is
coming from, remove it, instead of spending all sorts of time defining
the end; and then stopping it there and letting it drain on down.
It just seems bizarre."
Culligan said, "I think what is important is to identify the
source because unless we remove the source, this is going to continue
to seep into the groundwater. So, that’s a little bit different
than identifying the plume at the source. I think as the remediation
efforts go ahead and the design is going forward we can identify
more closely what the plume looks like, but I would agree with the
comment now that we should be thinking about; also in tangent, trying
to see how to remove this from the groundwater. I think we do have
enough information to go ahead with looking at schemes for remediation.
the modeling effort I think, could help a little bit identifying
where this is and I’ve got some comments on that but I was going
to keep them for the end of the report here."
Murphy said, "Joel, did you have a…"
Feigenbaum said, ", yeah, it looks like it’s a pretty intact
plume, its sort of classic. And you’ve got, Peter, there is a lot
of confirming information in terms of these…of the gradients of
the concentration across the plume at several locations and it seems
like its bounded pretty well by non-detect. So, I think this is
a classic case where having a non detect contour for us to look
at really helps to give confidence to the plume outline is drawn.
Especially in comparison to – I don’t want to jump ahead too much
– but to the detections RDX…detections in the central Impact Area,
the very wide area between the non-detect and the point, the two.
So I feel that…well first I want to continue to commend you for
taking the trouble for giving us the non detect boundary. I think
since both AFCEE and Jacobs are here they ought to take a good look
at what a good job looks like and…, I think we’re ready to start
talking about remediation, but. What’s it going to take to find
the source, are we going to have to excavate the Demo area or what?
What are we going to do? What’s the plan?"
Borci said, "That’s the next meeting. That will be the soil
report. Soil report will lay the foundation to start to talk about
that. The groundwater we want to get a hold on quicker because its
further out and then we’re trying to track the source control right
on top, right behind the groundwater control so that we don’t have
a wide gap between when we start to address both; but, the soil
screening report which was April 1st?"
Grant said, "Yes. Early April, yes."
Borci said, "That’s when we start to discuss what the options
are. That report would lay out a whole multitude of options and
then that will be…we’ll be able to gather input and focus those
down to what ultimately is."
Feigenbaum said, "Well, then, just informally, since the issue
has been raised and is of a concern, I mean, what would we plan
to do? To go in there and dig around or what?"
Borci said, "To be honest we have not even discussed it yet
and I just don’t want to go off on that tangent. We could probably
name about fifteen or twenty things we can do, but…"
Feigenbaum said, "Because I think the point is well taken that
from the shape of this it looks like is a pretty well defined, almost
point, point, some object in there that’s…or…"
Borci said, "Very concentrated source."
Feigenbaum said, "Or another buried 1500 rounds or something
is leaking here. But we certainly want to, you know, get it out
of the ground otherwise you’re going to have to operate the remediation
Borci said, "The fact that we are in a hole that’s only 40
feet from the water table, its bottom is going to cause problems.
But that’s why it’s going to be something that we’re going to have
to discuss and deal with."
Murphy said, "OK, David, and then Richard."
Dow said, "This is David Dow. I had a question about the policy
of not considering the heavy metals and four organics. Is that just
for Demo 1, or is that going to be a policy applied to the other
plumes? Because one of the concerns I have is if you have plumes
that are in a zone of contribution, you have an off-base public
water supply well, one of the new ones, I’d hate to see any of these
heavy metals or organics in the water supply - even if they are
Borci said, "It’s going to - it is strictly for Demo 1. And
the reason that they eliminated most of those metals was because
they were not in the source area well; or they weren’t detected
enough to say that there is a plume of metals. I mean, metals are
going to be in every sample, then you need to compare how high above
and we all know that thallium, other metals, have been an issue,
but I think the way it’s written up in the Demo 1 report is accurate
and it’s not something we are going to be designing a remediation
do want to point out though, that the history of remediation systems
on-base; like FS-12, I think SD-5, they - a lot of them need to
have green sand filtration prior to going through any type of treatment
and that’s because they need to deal with manganese and iron. And
I think that the manganese and iron concentrations here may be the
same, but those would tend to take care of some of the metals that
we’re talking about, so…"
Dow said, "My recollection though; in the past, is that passing
the stuff through the green sand filters has caused problems in
the activated carbon treatment and hasn’t been an entirely successful
Borci said, "We may or may not be using activated carbon for
the…that will be in the screening report that comes out in two weeks."
Dow said, "The second thing was it is true, though, that for
the dieldrin and these metals that they are above the MCL levels."
Grant said, "I don’t know off hand what the single dieldrin
detection…what the level was."
Borci said, "The dieldrin detection was back in the beginning
of the program, we’ve only seen it once, and we’ve sampled the well
at least six times. Thallium was detected at I think 3.8ppb; it
was an estimated detection, the problem is the detection limit is
right around what the health base number is, so you have to consider
Dow said, "The final thing was it’s my understanding that EPA’s
in the process of revising downward their arsenic MCL, is that going
to cause the arsenic detections to be below the new proposed standard?"
Borci said, "Arsenic is spilling from 15ppb to ten. And I believe
that there were no detections for arsenic in this plume above ten."
Dow said, "Thank you."
Murphy said, "Richard and then Tom."
Hugus said, "I had a quick question about this dashed line.
Marc, does that indicate that you’re not sure about the boundary?"
Grant said, "Yes."
Hugus said, "And, so I mentioned, is there wells going in to
give you confidence?"
Grant said, "That’s the most likely area that we’d focus on."
Hugus said, "OK. I’m not sure what the right point to give
comments to EPA about the contaminants of concern document. Is this
it? Or you want - when Marc is done?"
Borci said, "Whenever you’d like…"
Hugus said, "Well, I’d like to echo the comments David Dow
just made, and add to them that I think that MCL’s rather than risk
management should be our basis for deciding what is and what isn’t
Borci said, "What the order requires is that things are cleaned
up to background. So that’s why one of the other agenda items –
it’s for soils, but, the overall issue that we need to kind of…"
Hugus said, "But I’d make the same comment about backgrounds.
I’m prepared to make the same comment after looking at that book.
That rather than - when you establish background levels you have
the problem of whether the place you went to that you thought was
clean, was actually clean. And that there’s some doubts about that.
So, it’s the same issue with background levels. If a contaminant
is above the MCL, it should be something we worry about. Not whether
its above background, because we are not sure about background;
and the same is true for these contaminants in Demo area 1. Also
I would definitely add perchlorate to the COC list, there is no
question about that."
Murphy said, "Tom, you have a comment?"
Cambareri said, "Yeah, I just want to support what Paul was
saying about trying to define the toe of this plume. It’s conceivable
if you just project the core of that plume that you can get right
by 139. , so, haven’t seen, you know, some pretty narrow petrolium
plumes and MTB plumes and how they behave across Cape Cod sand and
gravel aquifer; it just seems…you know that’s something that you
want to…follow through on. So definitely some more wells are needed
then also I think it’s instructive in what you said that that projection
of this plume appears to be maybe twenty degrees off what the groundwater
model predicted. And I think the groundwater model is a great tool,
has some good accuracy, but as it was being used prior to plot precise
well locations, we need to be, I think this has proven that – it
puts you in a ballpark - but its not precise. So, as we go forward
with other investigations in this area we need to keep that in mind,
that it is just a tool to use in this investigation. It doesn’t
give all the answers.
I noticed in the draft report there was a number of water table
contours. I didn’t have time to look at flow paths from that, but
were those flow paths more in line with what you saw here?"
Grant said, "I’m not sure, it was such a slight gradient I
don’t think there was any huge difference from the plume shape."
Cambareri said, "I would imagine if one plotted it back you
could get that projection rather than another one though. I would
assume - it is always good to get the draft reports for the team
so that we can be advised as of what’s going on. I hope we continue
to get the draft reports through this effort depending on whether
it’s a Guard contract or it’s a Corps of Engineer contracter; that
draft reports will continue to be made available to the team."
Murphy said, "We had Joel, then Jim, then Jan."
Feigenbaum said, "Yeah, I’d agree if there was a weakness in
the depiction it would be that maybe we’re missing one toe well
down there - is there any plans to put at least another one? One
would go a long ways I think; because we’ve got the target drawn
on the wall here and so if we put the dart into it we know what
we’d be looking for, so is there some plan there?"
Borci said, "That’s part of the recommendations that’s going
to come out of the review of this report. So I think clearly what
we’re hearing tonight, yes there will be additional wells at the
toe of the plume."
Murphy said, "Jim..."
Stahl said, "I just have a couple of comments. One- I agree
with Trish’s comment that we have to go after the source and I’m
sure we will. And I think that that’s very well at least we have
indirect evidence, if we look at the table on page fifteen of the
groundwater report it is a table that shows the explosive residual…the
amount of RDX, HMX and dinitrotolulene underneath some sources found
on a soil surface for subconisance versus a random grid sampling.
And you can see that the concentration of RDX in the random sample
is about 1.2ppm, and they only found nine out of eighty-four samples
containing sample. But underneath places where they found contamination,
twenty-eight out of thirty had RDX and the average concentration
was 540ppm, so that’s about five hundred times more. Really, when
we get to the soil it seems to be prudent to go after…we’ve got
to find the sources of the contamination. You’ve got a maximum concentration
of 1.4 percent RDX in one of those contaminations that they found;
and so it won’t take very many of those to contaminate the water
and continue to contaminate the water."
Murphy said, "Jan."
Drake said, "To follow up on what Tom brought up, actually
I am half way through the review of this document and one of our
comments was - had to do with the figures. It doesn’t site the source
of mortar level data and I was wondering whether you did all surface
- shallow wells - an average of elevations or what the vertical
gradients were. And perhaps that might have something to do with
the trajectory of the plume. And I agree with the group here, that
we also are going to be recommending additional wells for better
plume definition. So, can you answer the first question from here?"
Grant said, "I can’t - I know they are all relatively shallow,
the plume depth is only fifty or sixty feet so I’m guessing there
wouldn’t be any significant vertical gradients over those depths.
And most of these wells have a screen pretty close to the water
table so we’re probably using that top one for definition."
Schlesinger said, "Quick question, Marc, how much time would
it take to get from the RDX to the Demo 1 to the groundwater?"
Grant said, "That’s not a quick question."
Schlesinger said, "OK, based on our knowledge of doing this
Borci said, "It’s almost a comparison that you can’t make.
I mean - you want to make a guess."
Grant said, "Well, I think the water, to get from ground surface
to water table is a year or less, a couple of years maybe. But the
RDX is such an unknown at this point because it takes a while to
dissolve in precipitation before it makes that move."
Borci said, "And that’s what some of the fate and transport
studies going on that AMEC is conducting, and that’s one of the
answers that we’re hoping to get. We’ll have that answer hopefully
before we get to the design. But we’ll have probably wells in the
ground that say; yes- that’s what the plume looks like, or no -
it's longer. Before we even get to that point, I mean its going
to be all part of the decision process leading up to the remedy."
Grant said, "Perchlorate, by the way, is typically much faster,
so there’s not that ‘long time to dissolve’ get into the solution."
Culligan said, "Can I follow up on that then? Because it's
related to the comments that I wanted to make about the modeling.
It says in figure 7.1 of this report the modeling is actually being
completed, yet I’ve seen nothing that has given us any information
about how that model development went on, how it’s actually being
validated, what perameters were determined. And if you look at page
12 the things that this model is going to be used to do it are going
to be pretty extensive. Looking – the basic point that Peter raised,
how long does it take for the contamination to get to the groundwater
– are decisions going to be made about cleanup of soil on the site
based on that groundwater remediation schemes are going to be developed
based on that; could you comment on what state the models actually
have? And when were we going to see output from that? That we can
comment on because that seems crucial to the groundwater efforts
at this time."
Grant said, "At this point, most of the studies that we’ve
had conducted at the University of Texas to get input parameters
for the model are complete and we’re starting to develop the unsaturated
zone model, but it’s not very far along in terms of providing that
for discussion to the agencies or to the group."
Culligan asked, "Are we able to see the reports from the University
Grant said, "That is something that we issue a monthly progress
report on which goes to maybe just the technical team."
Culligan said, "And related to the unsaturated zone modeling,
we’ve attended some of the technical meetings and I just want to
voice again my concern about validation for that model because the
last update we had there wasn’t any program in place to take samples
from the unsaturated zone to basically validate that that model
was a reasonable model."
Borci said, "I think what we can do is get you the latest.
Catch you up with the monthly reports, and then we can probably
either meet separately or further discuss those comments after you
have a chance to look at those to see if the answers are contained
in those reports."
Hugus asked, "Can you make that an action item so that we can
hear back about whether our technical advisors got the information
they needed at the next meeting."
Murphy said, "OK. Mark, you got a wrap-up slide there?"
Grant said, "I do. In terms of the next steps for groundwater,
This is a little bit if a repeat of the second slide; but, again
we’ve got this FS screening report which we started finishing as
soon as we got comments from the agencies on the contaminants of
concern. That is coming out next week. And like most of these reports
there is a three-week window allowed for agency input on these reports.
We’ll be conducting Treatability studies for remedial technologies
that might work for groundwater at Demo 1 and that’s going to be
starting, I believe, in late February or early March and continuing
on through early July. And the next step after that, once we know,
or we think we know what works is to conduct the feasibility study
to evaluate the remedies that might work. And that’s the draft of
that…looks like the end of September timeframe for this year.
the draft goes through the review comment process and gets to a
final…the last then is…well…not the last step…the first step in
completing the remedy is to select it. And there’s this public process
where we recommend a remedy out of the final FS and the EPA attempts
to develop consensus among the stakeholders for remedy. And that
whole process is described in the FS workplan, it’s not described
in detail in this report. Except for Demo 1."
Murphy asked, "OK, any additional comments on Demo 1? Go ahead
Schlesinger said, "I got up the lateral extent…I don’t feel
that we’ve defined the plume. I feel that the plume is too…what
we defined this far out great, its not long enough. I don’t think
it’s adequate. I think there’s a…if you look at the Figure 2-11
I think it was…and there’s another one in figure 4-6, you can’t
tell in the one in 4-6, but the one 2-11 that Marc had up on the
screen a moment ago, you could see that the…there was a - I mean
it’s not that one. There’s one that shows the concentrations along
the plume, I guess you could see it on that one to some degree…there
is a pulse. It seems like there’s a strong pulse of RDX at the source.
It seems to die in the middle. There’s a pulse at the end, and we
know it dissipates from the information we know. We don’t know how
far it goes down, it could go right back up again. Maybe it is not
a trend, but it very well could be, so I thing that we haven’t established
enough information to say that we know that this is where it is."
Borci said, "Do you have more? Because I was going to say more
wells…I get that…and then I think what we can do besides incorporating
those comments into the revision of this report but maybe have an
action item that at the next meeting we can say when we think ballpark-
we might be able to be out there installing some additional wells.
Does that sound…"
Schlesinger said, "Great, yes, please. The other comment is
more of a general one and I brought up a number of times before
and it seems to be corroborated by the summary of the first sixteen
interviews that were sent out, but you take a multi-source contamination
and make it into a point source investigation and this document
here which were are probably going to talk about elsewhere in the
meeting shows that there are things that have been all over the
place. You know, we are just assuming that we’ve done it Demo 1
and down there in the hull, , I just hope that we’re going to expand
our search a little bit beyond the narrow limit of what we consider
to be this one simple line in this plume. I’m guessing that if this
thing veers to the, and Paul agrees, to the south."
Murphy said, "OK, any more comments on, uh, Demo 1?"
Feigenbaum said, "Just of the time scale, as long as some people
are not really satisfied about the depiction of the plume, when
do you think we are going to get a couple of more wells in there?"
Borci said, "We are going to have to go and talk to the Guard;
but, I mean, everyone knows it was on the plate before we even heard
it tonight so…we’ve had discussions with the Guard that required
some more wells out here, they’ve said, ‘we realize that,’ and now
it is just a matter of how soon in fitting it in with the other
well installations that are going on around the base."
Feigenbaum said, "Why, we wouldn’t do something like go into
a design phase and then try to fill data gaps after we’re into the
Borci said, "I think we’ll have the wells in the ground much
Feigenbaum said, "Because there are certain other folks operating
in the area that like to do things the other way; they like to design
systems before they have the remedial investigation complete. I’m
glad to hear that we’re not going to do it that way."
Murphy said, "Jim, comment? Joe, could you get that mike down
Stahl said, "Yeah, I have a question about the…there is a whole
number of technologies listed out on the feasibility study work
plan and you said that that is all going to be finalized by February.
Are all of these being investigated? Or some of these? Or…"
Borci said, "That is what the February report will contain,
which ones look like they have promise towards the site and that
document will be able to be commented on."
Stahl said, "So the actual work on the..."
Borci said, "It is far from finalized."
Stahl continued, "Not going to start until after the February…"
Grant asked, " In terms of treatability study work?"
Stahl said, "Right"
Grant said, "Right. That FS Screening report will be the precursor
to treatability studies."
Borci said, "There are some ‘in general’ treatability studies
that the Guard has going, and they may be discussed in this…I mean,
I don’t know what is going to be in the screening report to that
level of detail, but they are probably going to have to e additional
treatability studies so…"
Stahl said, "OK, Thank you."
Item #4. Investigations Update – AMEC
Murphy said, "OK I think we are ready to move on to the Investigations
Update. Darrell, I think you wanted to say something again…I just
want to remind people that we’re going to stop at eight, or at some
place as close to eight as we can depending on where we are, for
Deleppo said, "Just to…again to remind folks that we’re looking
for the feedback on this previous presentation on the Contaminants
of Concern for the Groundwater Report by the eighth of February,
though we’ve got quite a few tonight. And then , just to kick off
Marc’s next presentation: There’s another situation where we are
looking for your input, and that’s on the Soil Background Calculations.
Again, we are looking for feedback by the second of February on
those and Mark will go through that at this point. First, he is
going to talk about the J Range and off-post explosive detections
and response plan to that. And also he is going to talk more about
the ah, upcoming documents that are coming our way."
Hugus said, "Darrell, you consider that the verbal comments
we made here about the COC’s to be comments, right? OK."
Grant said, "The Impact Area Groundwater Study update is …
again we have handouts that have the word slides, at the back of
the handouts are maps, that will be presented. The other thing that
we will provide to the IART members at the table, which is not a
public handout, is the detection maps. Each one of these maps, there
are five different ones; for five sets, I should say, that go with
different analytes. Each one has a set of tables at the end that
list all the detected analytes both validated and non validated;
it is just the beginning of the study. So again, these are provided
to the IART each time we meet in order to keep track of where we
have detections in the different analyte groups.
we usually do, we first cover the latest well installations, and
in this case we have got one additional well in the Impact Area,
which is the last one for a while that we are going to put in, it
is MW-141 and is here between the inner and outer transects of the
Impact Area. There is one more response well to be put in, P-30.
I think we mentioned last time it is a little bit too close to the
UXO exclusion zone for the HUTA. So we have to hold off on that
for a little bit longer until we get a window of a couple of weeks
at least where we can install that well.
141 was installed in December, there were; ah, oh, I should mention
that as long as I have this figure up, this is the latest RDX extent
map for the Impact Area, showing it is at Demo 1, we’re showing
a couple of different levels of contamination, in this case just
anything above detection and anything above 2 ppb there are not
that much higher levels of contamination that you would see at Demo
shapes of these extents have changed very slightly since our last
meeting. I believe the biggest change is down here that’s MW-135,
where we had – I’m not sure last time if we even had a profile detect
there, but now we have a monitoring well detect of RDX. The detection
is at such a depth that is appears to be coming from a location
far back beyond the CS-19 which is in this area, probably more towards
the center of the Impact Area. So, that MW-135 does not appear to
be related to CS-19 so much as the Impact Area itself. There are
some minor changes up here to the North in the vicinity of MW-97."
Drake said, "Marc, can you describe why the separation between
135 and 108/110 to the North…"
Murphy said, "Jan, could you just repeat that so we can..."
Drake said, "Yes, I asked Marc to describe why the separation
between the little blob to the North of 135 which is 108 or 110.
Different depths or what?"
Grant said, "I believe the depths are actually similar but
110 came up clean and 108 did not so we are drawing the little blob
around 108 and using 110 as the boundary for it."
Zanis said, "But shouldn’t that little blob go back to the
Central Impact Area?"
Grant said, ", actually it doesn’t because it is not deep enough,
and that answers your question about whether it is at the same depth,
, if it was deep enough we would draw it further back but in this
case it is probably just a shallow detect at 108. I don’t know what
the depth is off hand, but that is usually why we pick the length
of something like this is based on how far you would sort of back-track
the area or the source."
Zanis said, "No kidding, that doesn’t go back to the Central
Impact Area. So you are saying that the source is outside the Impact
Grant said, "I believe that is right."
Zanis said, "And the same with the other 20 or what’s up there
with the dark…"
Grant said, "Twenty-three…"
Zanis said, "It is the same for that, it is way outside the
Grant said, "Actually 23 does have a very deep component, I
think the reason we are not drawing it back is because we are taking
it half way to 43 which is on the same sort of particle tract. So
43 does not have a level above 2ppb, it has a level below. And it
looks like the level above, that we see at 23 is coming from this
area but it has to stop somewhere before it gets to 43."
Zanis said, "Unless the particle tract is wrong once again…and
it is going between and…all that stuff all over."
Grant said, "It is possible… right…yep…"
Zanis said, "OK."
Feigenbaum said, "What would…what’s the , concentration…the
highest concentration at MW-23?"
Grant said, "Twenty-three is…I’m going to say around 4 or 5…"
Zanis asked, "Has the helicopter flown that area?"
Grant confirmed, "Six point six" to Dr. Feigenbaum.
Feigenbaum said, "Six point six, now when you drew this little
baby plume down there, around MW-23, certainly there must be some
other wells in there."
Grant asked, "At 23?"
Feigenbaum said, "Did you just…did you draw that little plume
on the basis of just well…"
Grant said, "We’re using results for 23, 124 and 51 in this
Feigenbaum said, "Oh, Twenty three…."
Grant said, "124 is just the next well to the south and 51
is the next well to the north."
Feigenbaum said, "Oh, I see."
Grant said, "So it is an arbitrary decision about how far this
extends…we normally say half way to the next clean well."
Feigenbaum said, "It’s…yeah…No, but back upgradient, how do
Grant said, "Oh, that too is, you know, without wells in this
area we have to say maybe it goes half way from 23 to 43 but it
is not above 2 here, it is above 2 here; so you have got to guess
at how far that goes."
Feigenbaum said, "Well, it looks like you’ve got a fairly well
defined question there about indication…about where to put another
couple of wells."
Grant said, "If it becomes important to look at concentrations
that finely, but it is levels around 2 ppb so it’s not a whole lot
of changes there."
Feigenbaum said, "Well, that one is at six though."
Mr. Grant said,
"Yes, at 23 it is at six."
Borci said, "Joel, I think your comment, at least from my part,
is noted that at the end of February, February 28th is
the Impact Area Groundwater Report; which is going to come out.
It is going to go through all the hits, makes some evaluations and
then propose additional work; and I think your comment would be
a comment on that, so…"
Feigenbaum said, "Thank you."
Murphy said, "Paul, did you have a question?"
Zanis said, "Yes, wouldn’t that be a good prospect for the
helicopter to fly and see if there is anomolies over there? "
Borci said, "Right, and I think that is one of the things that
we can consider, I mean we are looking at site history, aerial photographs,
and then any other technology that we can use to our advantage."
Zanis asked, "But it hasn’t been flown yet?"
Borci answered, "It has not. We’re awaiting data on the second
round of airborne magnetometry, and that should be in early February.
Based on that we’ll probably have to go out and make some evaluations
of how useful it was and then we could propose additional, but in
the meantime, you know, we still take a look at the histories and
that is something that the groundwater report might touch on."
Zanis said, "That would be nice if you flew that track theoretically
and found a hot spot, went there and found source, remove it, then
Borci said, "You have to keep in mind that this is a nice pretty
picture on a map and it’s very rough rugged terrain out there, we
are talking very large areas it’s…you know…"
Murphy said, "Let’s see if we can, if we can let Marc try to
run through as much as he can because we are going to have to stop
the meeting, or pause it at eight o’clock, so……"
Cambareri said, "Can I have a clarification on…
Murphy said, "OK, sorry Tom, I didn’t see you…"
Cambareri continued, "Number ninety-six, was that shallow or
Grant said, "I don’t know off-hand. I’m guessing it was somewhat
deep, because we’d connect to the back. Again; that was the latest
extent of RDX including the last response well, at least for now,
in the Impact Area. …additional wells we have installed in the J
Ranges are shown on the next two figures. These are unnumbered figures
in your package, but they also appear – these are the figures we
use in the weekly progress reports - this one figure that shows
the total base with inset A for the Coast Guard, and inset B for
FS-12, J Range area. And if you go to inset B, - is it A and B -
which is the eight and a half by eleven map; you can see some of
the recent wells we have done in the J ranges. Many of them are
along Greenway road – recall in the J-3 Range area which is here.
We were setting up a fence of downgradient walls along Greenway;
ground flow direction being to the southeast, or south-southeast.
So, the recent ones we’ve completed here are…include 142, 143, 144,
145, 148 and 146 – I forget where that is – also we installed 140
downgradient from the L Range which is just over here, just to the
east of J-3. We are continuing to install wells in this area, there’s
a few more green dots that we haven’t done yet……those green dots
on this inset B map, and the overall map…and we’ll be continuing
to install those in the next couple of months.
also be starting on Phase IIb locations in actually about the next
week we’re set up to do inactive demo sites. Beginning about next
week, if you turn back to the second figure, these little green
dots that are kind of scattered around, they are not in the J Range
area, not in the Impact Area and those are the Phase IIb wells.
So you’ve got wells out here at the Gravity Range, proposed for
Demo 2, proposed for inactive Demo sites, K Range, things like that.
Those are going to start to get underway and should be completed
by about the end of March. That’s it for well installations."
Hugus said, "May I ask, Marc…did , on inset B you mentioned
new RDX detections, you went through it kind of quickly, could you
show where they are again?"
Grant said, "Yeah, we’re going to do a couple of slides – both
word slides and maps on the latest groundwater detects for RDX."
Hugus said, "Later?"
Grant said, "Yup, about three slides down."
Hugus said, "All right."
Grant said, "The next slide is our usual update on groundwater
sampling status and we keep ‘raising the bar’ so to speak, we put…six
rounds up this time, we completed the December long term monitoring
round, which was the sixth round for the oldest wells and the fifth
or fourth founds for the younger wells. The Impact Area response
was a little bit unusual, there are so many of them we’ve installed
them over such a long period of time that they range between one
and three rounds, I just depicted them in here as having two rounds
at this point."
Grant continued, "OK, so…Groundwater Sampling Results…with
this slide you may also want to refer to the fourth map in your
handout which is from the J-1-3-L Range work plan. There are several
new detections of explosives in groundwater. At the J-2 Range we
have a well, MW-130 which is up here at the very end, close to the
Impact Area it is in Disposal Area 2 and we had detects there of
RDX, HMX and a TNT breakdown product, 4-amino-DNT."
voice that was picked up by a microphone said, "what level?"
Grant answered, "The levels were fairly below health advisory,
about less than 1ppb. …these are all at the water table and the
soil in this area has both propellant related compounds and a TNT
breakdown product; not the same one, but a different one so it looks
like we are probably getting these low level hits from Disposal
Area 2 itself, whatever source materials are located there. That’s
the one new hit on the J-2 Range."
Zanis said, "Marc, could it be that’s all just left there?
And then it has already traveled down?
Grant said, "It could be, yes."
Zanis said, "So are we going to put any more wells in the chaff
site because that is a zone of contribution, I think of the new
water supply well three."
Grant said, "That is the subject of another document, that
is the J-2 additional delineation work plan which is designed to
determine whether we know enough about J-2. We’re kind of doing
all this stuff real quick, but we haven’t written the J-2 Range
report yet so you haven’t missed that. But we are trying to figure
out already whether we know enough about J-2 to anticipate the next
steps in terms of well installations."
Zanis said, "I mean, I know from the 16 interviewees; I mean
when I was a kid the J-2 Range was the place to go. But I never
imagined that there was so much disposal going on there."
Grant said, "Right, and that’s something that we are looking
at right now…they do…"
Zanis said, "The water people should be very concerned about
reading these interviews and realizing what is upgradient of their
Grant said, "OK. The additional delineation work plan should
be out to the entire review team within the next couple of days,
I believe the agencies got their comments in the last day or two."
Murphy said, "Jan, you have a comment."
Drake said, "I don’t mean to interrupt, but I wanted you to
look at the figure 2, the FS-12 area wells ETR System are, I think
that the water table flows over the other side of the mound with
well 132, at least according to current understanding of groundwater
flow; so it’s not flowing in a direction of the new water supply
wells, it’s flowing towards the J-3 Wetlands Snake Pond area."
Zanis said, "I don’t confer with that. I’ve already…I’ve seen
Murphy said, "We just…"
Zanis continued, "I’ve seen the hand drawing zones of contribution
that the JPO has drawn and it comes right from there."
Grant said, "I think we are talking about 130, right? Is that…on
Zanis said, "Yeah…yeah."
Grant continued, "You were talking about 132 Jan…You were talking
Drake said, "I’m sorry, I thought you were talking about…"
Mr. Grant said,
"Yeah, we were talking about 130…"
Zanis said, "On the other side of the mound…"
beg your pardon," Ms. Drake said, "I’m sorry."
Zanis said, "OK"
Grant said, "OK…so that’s the latest detect at 130. At the
J-1 Range we have got RDX and HMX detected at MW-136 which was installed…the
biggest thing here is the 1,000 meter target, but this one particular
well was installed in the vicinity of the burn kettle which was
also an area where wastewater from the J-3 Range Melt Pour building
was disposed. So, there is a lot of stuff going on here, but in
this particular well again we had some sort-of low level detects,
the levels are around 1ppb, little bit less detected at the water
table so; again, it looks like that is coming from that immediate
vicinity. The last new detect at the J Range is one I want to mention
at the J-3 Range and that is MW-132. We had non explosives here,
which…we actually have profile samples previously – but Perchlorate
this time detected at MW-132 - and the concentration is…again we
are not showing any of these numbers because it is not validated
data yet, but it is a little bit less than 40ppb. So it appears
to be well over the numbers that are being kicked around by California
and by potential federal drinking water criteria…"
Zanis said, "Now, will that water head towards the FS-12 water…."
Grant said, "That water is heading towards FS-12, right."
Zanis said, "But well 136, is that kind of vague where that’s
heading or is that heading out into the Impact Area?"
Grant said, "136 is pretty close to the top of the mound. The
top of the mound is around 127 in this area. So it’s…ya know…that
was the top of the mound at the time we happened to measure it.
There’s probably some oscillation going on where the top is kind
of moving around here, so depending upon where the top is, any particular
year, 136 could be flowing out this way, or maybe this way, it is
probably never going to go towards the southeast, but…."
Zanis asked, "Could it go towards the east though, towards
our new supply wells?"
Grant said, "It is really hard to say we just don’t know enough
about how much the top moves around yet."
Zanis said, "But it’s out there, I guess we got to find it,
are we going to do something about it?"
Grant said, "well…again, this is the first phase investigation
for the J-1 Range, so some of what we did for J-2 came up with some
additional delineation work plan will do the same thing for J-1.
Actually where there are still some other wells on J-1 we need to
still install, but there will be some follow on work there."
microphone picked up a voice that said, "Marc, are we going
to mention MW-13?"
Grant said, "…I did not mention MW-13, just because at the
time I prepared this we hadn’t really talked about it in the tech
team. It is a new Perchlorate detection."
Zanis asked, "Where is it?"
Grant said, "MW-13 is just to the north west side of J-3 Range,
and in this area groundwater is probably, usually flowing to the
west or maybe south west. But this was a deep detection and most
likely source would be back in here towards the top of the mound
in the J-1 Range area."
Zanis said, "Boy, they tested a lot of rockets over there so
it’s a…who knows where are that Perchlorate is going."
Murphy said, "OK, Marc, maybe we could stop before you get
to the next slide…Richard you want to make…"
Hugus said, "Yeah, I know you are trying to finish but…do…"
Murphy said, "We will get back to it…regardless…"
Hugus continued, "Do you have some kind of an estimate about
the J-Range Plume yet? Do you have any…any overhead of… to that
Grant said, "We haven’t tried to outline it and this series
of wells along Greenway Road boundary will help us quite a bit on
that. We are just now to the point where we are starting to look
at cross-section views and trying to figure out…you know we’ve got
a bunch of detects that we’re trying to figure out what depths things
are at, trying to match them up. , there is probably a bunch of
different plumes that will eventually be drawn there. It doesn’t
look like one big hunk and thing that’s all got the same source."
Hugus said, "Well, I’d like to see some kind of conceptualization
here because the whole thing is so confusing as a bunch of separate
detects right now."
Feigenbaum said, "Marc, can I just get a preview of coming
attractions, , Robert Gill, told me that you had a hit of RDX and
EDB at … somewhere along the root of the pipeline…is that, are you
going to report on that later?"
Hugus said, "I have another question…"
Grant said, "Unfortunately, I wasn’t including the EDB results
in this report, but was going to talk about all the RDX, HMX hits
in that area. That’s the last…"
Feigenbaum said, "Are you familiar with the well…"
Mr. Grant said,
Mr. Zanis said, "What well is it Marc?"
Dr. Feigenbaum said, "Could you mention that when we come back?
Grant said, "Ahhh…Yep."
said, "If you could just gather your data?"
Grant said, "OK."
Feigenbaum said, "Thank you."
Murphy said, "OK we’re going to pause and have this ah…a public
hearing on the , EPA Administrative Order number Four. …and what
I was…uh…the way we are going to proceed is Margery Adams of EPA
will essentially give an introduction explaining the order. …we
would then like to have an informal period where people can ask
questions and……Margery will try to answer them and then we will
start the hearing and people can offer formal comments and those
won’t be responded to tonight. So…any questions on that…procedure?
No? OK, so…and we have a court reporter to take all the comments
Item #5. Administrative Order #4- Public Hearing
public hearing commenced. Dictated by court reporter.
Item #4. Investigations Update Continued. - AMEC
Murphy said, "And not it is time to get back to the not quite
as formal meeting. So, Marc you are going to resume? It now being
9:50 p.m. I just had a question as to ah…how we want to proceed.
We have Marc…8:50 p.m. - there we go, I guess I’m in…I paid a lot
for these glasses…OK it’s now 8:50. We have Marc’s another one and
a half presentations. , then we have followed by the Status of Small
Arms Range Air and Sampling Soil, and then the Other Issues. So…uh…can
I get some feedback as to how we want to proceed? We just want to
continue through the agenda?"
Borci said, "If you could fly through the rest of your stuff
so that we can get to the small arms and then we can re-evaluate
at that point."
Murphy said, "Sounds good."
Grant said, "OK, so at this point in the groundwater results
we had just talked about the recent detection, the J Ranges again
a couple of low-level detects in source areas on J-2 and J-1 for
explosives and it looks like Perchlorate at a source area in J-3.
next part of the Groundwater Update is to talk about new detects
off-post. And there is a figure, it is actually labeled Figure 2
but it is the fifth figure at the end of your handouts, that shows
some wells in the FS-12 area along with water table contour lines
and groundwater model particle tracts. Roughly perpendicular to
the contour lines. Just one thing to note here, in best of all possible
worlds you would have your groundwater flow going exactly perpendicular
to your water table contour lines. It is not obviously the case
in all portions of this figure. Again, that is because we’ve got
a set of reality base measurements which is a water table at a certain
point in time that is contrasting with the steady state model which
is designed to look at more of an average condition of what’s going
on, so there is some disagreement I think in terms of what the fine
points in the groundwater flow direction might be; although generally
you can see that we are saying in both cases that it is coming from
the J-3 Range down into the north end of Snake Pond.
significant detect is that we have for the first time RDX and HMX
detected in 90 MW-54 which is down here a bit further west of our
previous detections. Remember we’ve had detections in the vicinity
of J-3 Wetland or what is also called the Camp Good News bog, 54
is a bit southwest of there and if we look at groundwater flow paths,
the source of this detection is probably more to the west of the
J-3 Range than J-3 Range proper. It looks like the J-3 Range was
more related to previous detections, this detection is a bit off
to the west, although again, is possible to…if you follow your line
perpendicular to your contours that you’ll come into the J-3 Range,
so it may be just a fine point.
we have a couple of profile detects, we collected split samples
from some borings that AFCEE was installing at the north end of
Snake Pond identified as 101A and 102A, and those detects of RDX
and HMX also backtrack to this recent detect of 54. I should mention
that 54 was sampled about 3-4 times previous to this detect with
no detects in the well, so it looks like maybe RDX is just entering
this area for the first time, at 54, again we are seeing it at 101
and 102 a bit further south. These levels are in the vicinity of
1 – 6 ppb in the profile samples in the monitoring well.
other significant thing we want to point out in terms of new results
is that we’ve got all these new wells, they are actually shown as
light blue wells here, and there is kind of a mixture of existing
names and proposed names but we’ve got 142, 143, 144 and 145 up
here, with a bunch of profile detections. Again we’ve installed
well screens but we don’t have--- wetland, but it is starting to
give us a sense for how broad the area of contamination might be
along greenway road. And Joel had asked about the EDB, we saw a
couple of detects in EDB in the profile samples that AFCEE had split
with us and analyzed from MW144 in this area. So we are starting
again to draw a better picture of what’s coming through from the
J-1-3-L-Ranges right here, area, into the North end of Snake Pond.
the last part of this update, just let me go to this one it may
answer a few questions in terms of what we are doing about it. We’ve
got a new response plan underway. We’ve actually submitted a draft
to EPA just after the 1st of the year, and we’re expecting
to provide a final response plan to them tomorrow. It talks about
additional sampling, we’ve got about 19 monitoring well locations
identified under the plan, and we actually have already started
sampling those monitoring wells, those are shown as wells proposed
to be sampled in dark blue on this particular figure. Those are
being added in, they have never been sampled previously and that
will be sampled for explosives.
is also a couple of wells that are supposed to be installed, …in
this response plan we have identified two locations, SP2 and SP1
down here at the North end of Snake Pond that will help us get a
better feel of where contaminants may go as they enter this area.
And I should point out that aside from what the response plan talks
about, we are still installing wells along Greenway road that were
intended to give us our first pass at J and L Ranges. There is all
this activity going on in tandem, the response plan to address these
recent detections of RDX and then the original site characterization
in this area, it looks possible that we may be moving some of the
original proposed well locations around in order to get a better
sense for where the contamination resides, particularly around the
south end of the Greenway Road area. And that’s pretty much what
I have on the off-post detects."
Zanis asked, "Marc, have you tested for perchlorates?"
Grant said, " That is part of the response plan, we have not
for many of these wells…we did get a perchlorate detection up at
132 I mentioned, and that has prompted some additional sampling
downgradient of 132. We should have results of that in the next
month or so, but at this point we have very few data."
Mr. Zanis said,
"There is a lot of wells already over there but there not screened
at the right levels, are we going to bather testing those anyway?
Or are we going with new?"
Mr. Grant said, "No, there’s some wells that are at the right
levels and what we’ve got here obviously, is an FS-12 release that’s
a little bit different than our RDX, HMX release, so it’s cross-gradient
a little bit, but the depths are not too bad in many instances and
we are using many of the FS-12 wells. There could come a point after
we get this next round of samples out of the nineteen or so locations
and actually more than 30 different screens because some of them
we’re taking samples, AFCEE has some extraction wells, or re-injection
wells I guess, that are turned off right now, but they have a 60
foot screen, we are taking samples every 10 feet, kind of like a
profile situation, so we’ve got a better sense at the end of that
sampling, as to whether we need additional wells in that area. But
we are seeing both from the…this particular detection came about
because of a long-term monitoring plan, it was just routing monitoring
of a well that never showed detections previously but it was an
area of detect so we were interested in it. We’re getting detections
in the LTM plan, we’re getting a lot of detections in our first
pass at the J- Ranges, so its all kind of pointing towards additional
work to define plumes in this area. We are at the point now where
we can’t really draw lines around things and try to circle them
up, but we are getting to that stage, we’re starting to look at
all how the detects piece together."
Zanis said, "This is like a whole huge separate problem, especially
if the treatment system…"
Grant said, "Yeah, yeah, it’s a very interesting area. Because
you’ve got the treatment system going, you’ve got…your close to
the top of the water table so you’ve got the mound kind of shifting
around, probably blurring things around a little-bit making it tough
for us to see exactly what the source areas are."
spoke in the background. Mr. Grant said, "Got the what?"
That person repeated what they said but it was inaudible.
Grant said, "You’ve got the pond where groundwater is probably
discharging and going…."
Zanis said, "I mean…with this…you’ve gone this far. And I…you
have a lot of experience now of what’s going on here. How’s it going
to be for a new contractor to come in and take over this study?
I mean, I think it is almost undoable. They are going to have to
read all this data, they’re going to have to get caught up. What’s
it going to take, two years to catch up? To this process…of what’s
going on here? Is the Corps of Engineers…Do they fully understand
Grant said, "I think, you know, most of what we are doing now
for us has become standard anyway, we are putting the data out to
a lot of folks, I don’t think there is a whole lot of mysteries
about how to do this type of investigation. I’d like to say we’re
unique in doing something like this…."
Zanis asked. "So your company is not keeping some of your knowledge
to yourself? You’re sharing it with everybody?"
Feigenbaum said, "Make it proprietary, proprietary."
Grant said, "Well we are sharing it with the Guard and eventually
it is going out to the public, the Agencies and the Public so there
is no secrets there. We can’t really keep something to ourselves
if the Guard is paying for it, so…"
Dolan said, "Mark, you indicated before the hearing that this
response plan had been sent out to the Team? Did you say that?"
Grant said, No, I didn’t…and actually this response plan has not
been sent out to the team. I’m not sure if that has been done in
the past, but the response plan we provided to the agencies on the
second was just to EPA, MADEP and the Corps."
Dolan said, "OK I would suggest that after we get the final
plan tomorrow it be distributed to the team, and should they have
any comments to send them to me."
Grant said, "You mean after there is agreement on the final
plan or as the…"
voice was picked up from the PA system that said, "because
you are agreeing and we get to comment…"
Borci said, "This is obviously an ongoing process so, we are
constantly re-evaluating which wells we are going to be sampling,
Schlesinger said, "Mark, I’ve got 2 quick questions. The FS-12
fence, is it likely to capture these…"
Grant said, "Probably not the further west ones, like around
54, it looks like AFCEE is modifying their extraction, to pulling
things in this area, but I think the revised extraction zone, if
I am not incorrect, falls just short of the recent RDX detect."
Schlesinger said, "The other part is regarding Perchlorate.
, actually it is two parts. One is, …will FS-12 fence clean Perchlorate?
Number one, and two on Perchlorate is, I understand that you are
going to test some priority locations for Perchlorate but don’t
forget we tested areas of civilian land, citizen, residential land
around Snake Pond and we probably should think about that as well
if there is anybody drinking water over there. I just don’t want
us to forget about it."
Grant said, "OK."
Hugus said, "Mark, you just told us that…ah…I think the team
should pay special attention to what you’ve just told us…a whole
rash of new detections of RDX have been found, and I just want to
review those, you said that the new detections its 143, 144, 145,
045 and 101A and B?"
Grant said, "OK, …yeah, some are new and some are not. These
are pretty close together and I think you might be able to say this
is all sort of related. You’ve got the detected 54 which is in a
well screen and then you’ve got detects in 101 and 102 which are
from profile samples and it all appears to be following along this
general path, and then we’ve got, what I’m thinking, is not so much
new detects, but better delineation of an existing groundwater contamination
problem here from the J-3 Range, so we already knew that RDX and
HMX was coming down from the 90MW22 area, through the south end
of Snake Pond where AFCEE installed those dry points that we got
splits on. Now we are just getting better information about – it
is a little bit wider than we knew previously, and we are saying
the same kind of HMX situation up here as we saw previously, so
its, I think this western thing is a significant new find, but this
is just better delineation of what we knew."
Hugus said, "Well, I asked you earlier about…I commented about
the need for some kind of picture conception of what’s going on
here so we don’t have to juggle all of these separate detections
in our heads. Is there something about these detections and their
level in the groundwater that makes you think that they are all
separate, and not coherent, or…"
Grant said, "Not at all. In fact the way the water table mound
shifts around you know, you’re probably – it could all be from a
single source and they’re just getting smeared around. I don’t think
there is any resistance to us trying to delineate plumes here if
we can, it’s just the fact that we are just getting data now and
we’re trying to work through it as we get it. You’re getting those
as fast as we are so we are not to that stage yet."
Hugus asked, "Well, I think we have as much information in
the Central Impact Area, Area. Where you have drawn plume shells,
so once again I’d urge the regulators and the Guard to provide that
to us, so we have a picture of what’s going on. And finally, you
said that the L-Range might be a possible source area?"
Grant said, "L-Range is just to the east of J-3 Range and it
appears if anything it is a possible source related to the RDX that
goes through 90WT13 or pass through because I think the well is
relatively clean now and follows this path into the extraction system."
Mr. Hugus asked,
"And what about on the other side, to the left? West of J-3"
Grant said, "I’m not sure that there is any obvious source
area in this location, again backtracks are a little bit fuzzier
here because the top of the mound issue and you might just as easily
draw a perpendicular line through all of these that swings right
back into J-3."
Feigenbaum said, "Marc, that was part of the question I wanted
to ask you, about these particle tracts; they are not perpendicular
to the contours. They are not even close."
Grant said, "Right, what we are looking at is a snapshot in
time of the water table with the contours and then the steady state
groundwater flow model that’s picking out some set of average conditions
that don’t necessarily apply to our recent measurements."
Feigenbaum said, "I don’t understand that. You’ll have to break
that down for me a little bit."
Mr. Grant said, "I think the model is trying to pick sort of
an average case and that average isn’t well represented by our recent
measurements. So, maybe if you looked at a longer term thing you
might say that the groundwater would flow in these paths, but if
you look at how its flowing last month when we took these measurements,
it is slightly different. It could be because of pumping changes
but I think because the water table is very flat here it is probably
shifting around a little bit, oscillating…"
Feigenbaum said, "Wait a minute, so you’re saying that particle
tracts are at time averages over what’s known about the gradient?"
Grant said, "My understanding, maybe we are getting beyond
my knowledge of modeling at this point, is that the groundwater
flow model is set up to represent some average set of conditions,
it’s not calibrated to December 2000…"
Feigenbaum said, "But these…the contour lines represent a snapshot?"
Grant said, "Yes, that represents our measurements last month."
Feigenbaum said, "Well, it’s kind of…it’s a little bit confusing.
Grant said, "That’s why we’re saying keep the particle tracts
in this area as sort of a fuzzy indication of things, we feel a
lot more confident in an area like Demo 1 that’s away from the top
of the mound that’s not going to swing around, but in this area
it could swing quite a bit."
Feigenbaum said, "Because unfortunately, you are providing
the most recent data about the Snake Pond area in terms of not only
potential explosive contamination but also EDB contamination. And
you draw these particle tracts a little differently and you get
some of your material going down to the west side of the pond, not
on the east side of the pond and that is a critical difference in
terms of the containment system. Do you follow what I’m saying?"
Grant said, "Yes, I follow what you’re saying."
Feigenbaum said, "It would be nice to get a little better understanding
of this because sometimes we get told by AFCEE folks that nothing
possibly could be going on the western side of the pond given their
particle track extrapolations, but if there’s two sets of data we’re
keeping two books here, so it’s a little confusing."
Grant said, "The best sense of what is really happening is
partly obtained by water table measurements and one of the things
the Response Plan that we propose doing is collecting a bigger synoptic
set than this last set, this last set was based mostly on wells,
as you can see, on post and to the North and the next set would
like to go a little bit further south."
Murphy said, "Ray, do you have a question, Ray Taylor?"
Taylor said, "No, I think he answered that he doesn’t believe
that pumping is causing that convergence there."
Grant said, "This particular set of flow passes with the pumping
system on, so you get a different set of tracts if you switch the
Taylor said, "So you are saying pumping has something to do
Grant said, "Pumping is probably producing these kind of situations
where this is, you know, circling in. With the pumping system off
I think the tracks will generally go straight south in this area."
Cambareri said, "I just want to say on that the water table
fluctuates so wildly over time in this area the fluctuation seasonally
could be 6 feet more or approaching record lows now…"
Grant said, "…over years…"
Cambareri said, "Over you know, 30 years a period of records,
so there are these slight changes and if you have water table information
I think the key thing would be to just plot the map, the flow lines
from the water table information."
Grant said, "Right, and that gives you your present case rather
than your sort of average case. Yes."
Feigenbaum said, "Because those determinations are crucial
for thinking about the future of this whole system."
Murphy said, "Peter, go ahead."
said, "Marc, if we don’t know whether FS-12 came clean perchlorate,
can we make it an action item to find out?"
Mr. Grant said, "If FS-12 can clean perchlorate? …I think the
short answer is granule activated carbon is not effective for perchlorate."
said, "Is not."
Grant said, "So you’d have to combine it with another system.
But again at this point we don’t have an indication that it is going
into the system; it is something we are trying to investigate. That’s
it for the Groundwater Update part. I was going to shift gears to
Murphy said, "Yeah, we’ll see if we can get through this as
much as possible without question just so we can try to make up
some time, unless you really need to ask a question. You can ask
Grant said, "I kept this part of the presentation fairly concise
and simple because I have difficulty explaining all the statistics
myself. So this first slide just talks about why we are interested
in soil background. Background is something that defines the so-called
natural site conditions. In this case what we are talking about
is conditions in the absence of military use of the site. Obviously
defining background is critical to noting whether there is an impact
or release. So, if you know what background is and you know that
there is a level above background then there has been some sort
of impact. If not then it doesn’t look like there has been an impact.
how background is determined gets a little more complicated. Basically
what we are doing is measuring these levels of these analytes. Each
analyte probably has its own background level at least for certain
analytes. Many analytes, such as explosives, would have no background,
or background would be non-detect. But what we do then after we
collect these measurements is we have to combine them somehow because
if we take something that may be naturally occurring in soil, say
potassium, we are going to wind up with a range of different values
and we need to represent that somehow statistically and reach an
agreement upon what – if we make a measurement of a particular area,
whether that measurement is consistent with the background value
for potassium. So that’s what all these statistical generations
involve is trying to figure out how to represent the data to come
up with an agreement on background.
analytes are naturally occurring, mostly inorganic compounds. There
is also some man made compounds that we think have background levels,
and those are basically from non-military sources such as pesticides
that would be used for mosquito control. Relatively few but a few
the background tech memo, it’s a rather daunting couple of inches
thick and it was recently released, I think it was the first week
in January. I don’t think the text is that daunting, there is only
about 20 pages of text describing what we did and the results we
wound up with. There are additional tables that summarize those
results, but the text itself I think you can get through without
too much trouble. Most of this is just back up showing the statistics
and how we came about some of the evaluations and distributions
and outliers and things like that.
we would end up doing, we had about over 200 different analytes
in this study, and we were proposing background levels for about
44 of those. And 29 of those are inorganic parameters, another 11
are semi-volatile organic compounds, generally these are combustion
by-products and they have anthropogenic sources such as aerial deposition
from combustion, or combustion of vegetation due to burning. And
then another 3 pesticides and one is herbicide, and again we believe
these can have anthropogenic sources. Those 44 comprise the total
number of analytes for which we’re evaluating background. All the
other analytes we will assume that background is zero, or ND.
these 44 what we did is we took a very large soil set, basically
we had hundreds of samples, we talked a little about this last meeting,
both on-post and off-post soil samples. Then what we did is we looked
at graphical and statistical analysis to make sure that the off
post samples we were using were not representative of a release.
So we were looking to see if there are any trends or differences
that suggest that a particular group of samples we collected on-site
were impacted by a release versus not being impacted. If they do
not appear to be impacted then we can include them in what we call
background. We are trying to get as big of a data set as possible
because the bigger the data the more confidence we have in what
the levels are.
term of results what we wound up with is pretty consistent with
previous studies. Those studies include Phase I. You may recall
that in July 1998 the completion of a work report we came out with
something we called "Proposed Background". IRP has a background
set that they use under the Risk Assessment Handbook and MADEP has
non-urban background levels that they use. So, in this document
in one of the tables we compare these new background levels that
we came up with all those other background levels and there really
aren’t too many differences. So, that is good in terms of consistency.
guess what we’re looking for, at this point, is input from stakeholders
on how to proceed with this. Just to reinforce; background is something
that is critical for us in order to determine what are the COC’s
or the Contaminants of Concern. If we don’t know what background
is then we don’t know if a particular measurement is something that
represents an impact and has to be potentially remediated or if
it is just a natural site condition. So, I’m afraid that we’re kind
of under a time-crunch because we’re trying to get the COC’s determined
as fast as possible so we can proceed towards remedies, but there
is a sign-post along the way that says ‘what is background?’ and
we’re kind of there now and we need to get the input on that."
Murphy said, "Ready for the questions before you go with the
Grant said, "Yes."
Murphy said, "OK. Richard."
Hugus said, "Well, you are asking for input Marc, and I appreciate
that, but this book isn’t something that the layperson can read
and provide input on. It is just not written for people outside
of the business to understand. Could you for instance, tell me what
…ah…well, let me put it this way. My understanding is that when
you find a background level, you say that level is acceptable; i.e.,
it’s OK because it is background, is it alright to say that?"
Grant said, "Yes, basically. If we come up with a level that
everybody agrees is background then that is a level; if you have
measured that level someplace like at Demo 1, that means it is OK,
you do not have to do remediation on that."
Hugus said, "But you have been elsewhere outside the base to
places you think are clean and found background levels there. As
I said earlier, there is all kinds of room for confounding when
you do that. For instance, if pesticides were used in an area where
you thought was clean, you have a false background."
Grant said, "Right, and what you are getting at is the idea
that we don’t have a huge off-post data set, we do have all these
on post samples and what we do is try to include as many of the
on-post samples as possible. So the threat is that you will include
some on-post samples that had a military impact. What we are doing
in the statistical analysis is looking at trends to see if there
is a break in the distribution of data: that may look like a set
of data represents natural conditions, and then there is a higher
level that represents some sort of possible releases; and that is
what we are doing in the out lying analysis and looks at distributions."
Hugus said, "Well, can you tell me; for example, what background
level for MCPP is?"
Grant said, ", give me a sec, I think I…"
Hugus interrupted and said, "What level of MCPP that it is
that the Guard thinks is acceptable."
Grant said, "Again, we only had 3 pesticides and one herbicide…"
Borci said, " MCPA is a related herbicide and …"
Murphy interrupted and said, "Excuse me; Mrs. Crocker, I just
wanted to address something you brought up during the hearing since
I saw that you were leaving. You had said that you didn’t know how
to apply for membership on the team…"
Crocker said, "No, I don’t think it was me…"
Murphy said, "OK, well, I just wanted to put it out there the
way the team, the team has been set up by EPA members. The only
additional members since the original one I think was Peter Schlesinger
who followed the procedure of writing a letter to EPA requesting
membership on the team. It is then evaluated by EPA and talked about
by the team and that is the process, just so you know."
Crocker said, "Well, it would be nice that you could advertise
that through me."
Murphy said, "OK, I just wanted to get that to you before you
Crocker said, "I’ll try to help advertise that, thank you."
Murphy said, "Thanks."
Crocker said, "Thank you, Jim."
Grant said, "Did we not answer that…"
Hugus said, "Take MCPA, what is the acceptable background for
Borci said, "I think, ‘what is the proposed background’ is
Hugus said, "OK, proposed, see."
Grant said, "…don’t agree. The proposed level from the current
document is 20,000 ppb. There was also in our Phase I report a proposal
for MCPA, that was 48,000 ppb."
Hugus asked, "So which is it?"
Grant said, "This is 20,000."
Hugus said, "You are saying that it is OK if 20,000 ppb are
found in soil?"
Grant said, "We are saying that our analysis indicates that
level as background. It is not a level that resulted from military
use of MCPA, it is a level that you could find any place on the
Hugus asked, "And what level was it when God created the earth?"
Grant said, "I wasn’t there."
Hugus said, "You know everything though, don’t you?"
Grant said, "It was probably zero."
Hugus said, "OK, my point is that the whole business of background
level is subject to confounding and error and my comment as a stakeholder,
which you asked for, is that we should not be caught up in background
levels in order to decide what is clean and what isn’t. We should
base that decision on maximum contaminant levels. That way we avoid
the problem of confounding with off-site sources or sites that may
be contaminated themselves. And that has to do with…. I picked MCPA
because I knew you were going to give me a high figure. 20,000 ppb
in soil is not clean. I wouldn’t want my children to play in soil
that had those levels; I mean, it is just not acceptable. And I
am sure there is others, but I can’t really understand this book."
Grant said, "There really are only 4 pesticides and herbicides
that are proposed, the rest are either semi volatiles or inorganic
compounds, so, I agree, those 4 are going to be something that will
probably generate the most comment.
Borci said, "I think I just want to clarify one thing that
you said, Richard, when you said maximum contaminant levels are
you referring to state cleanup standards? The way the order is written
is that it has to be below background levels. There is a minimum
level of protection and whatever outstanding clean up numbers are
out there, these levels would have to be below those…"
Hugus said, "Well, take this for example, suppose that we,
ah, were taking trichloroethylene as a background, trying to establish
a background level…"
Borci said, "Background is non-detect."
Hugus asked, "What?"
Borci said, "Background in non-detect for TCE"
Hugus said, "Not if you go test where the BOMARC plume is."
Borci said, "That is one of the things of our study, that is
one of the things that Marc was saying is that we just flat out
eliminated that right off the bat and said any TCE is….."
Hugus interrupted and said, "I know, I know, I’m just
trying to give you an example of why the whole business of establishing
background is subject to fault. If you are already in a contaminated
area, you are not establishing clean standards. You know, and I
just don’t want that done here. There are levels that you guys are
going to say are acceptable that aren’t acceptable."
Dow introduced himself and said, "I guess the concern I have
is the general presumption is that if you have a point source that
leads to a plume, that can tell you the area is contaminated, but
seeing it is quite possible, especially for plumes that military
activity could deal with non point sources. And if that is the case
then the background, unless it is someplace far from the base, could
give you an advertant viewpoint of what the actual background is,
so especially for the heavy metals, maybe even some of the pesticides
and herbicides, that you could have military activities that occur
on the base that were non point sources rather than point sources.
And when you delineate to background you should think about what
the potential sources for those are, and separate them out. It makes
a critical difference for things that are airborne. A lot of things
are not airborne so that you can go ahead like you proceed, but
other ones obviously are."
Grant said, "Yup, I think the distribution of the samples is
pretty widespread. It is certainly not focused on the Impact Area,
although there is a lot there, but there is a lot on the training
ranges, so if your going to have this non-point thing that you are
describing, it would have to be a really big non-point source in
order to bias all the samples. But if you had such a source, then
yes, you would not be able to see the obscurence of background.
Unless you went to way off post."
Dow said, "When they used to burn all the howitzer rounds that
they couldn’t fire, the mortar rounds, that could make a fairly
large non-point source since the stuff is airborne."
Grant said, "Yeah, although there are going to be predominant
wind direction that is going to influence that, but it will be a
Murphy said, "Peter, do you have a question down there?"
Schlesinger said, "Are you done so I can ask all my questions?"
Grant said, "Yes."
Schlesinger said, "OK I’ll start at the beginning and please
bear with me because I did make an attempt to go through this whole
thing. First, on page 3, in the second paragraph of 2.1.1 under
Phase 1 methodology, I don’t understand...I mean, I do understand
the issue of the, criterion that was used, the 71 percent criterion.
I understand it is not known in Phase I why it was used. But instead
you chose to increase it by upping the number of detections to 20
detections as a means of determining whether or not an analyte stayed
in the batch that you were going to calculate background for or
not, and I didn’t find this explanation clear enough that I could
understand why this was plausible. I just want to follow that up
by saying I did go back into your chart, into your tables, pages
29, 30 and so on… and found that pentachlorophenyl and dicamba were
kicked out or eliminated from your consideration because of that
criterion. And I wanted to ask a question of whether any of the
substances removed because of that detection level have high values
Grant said, "So you are asking if things that were kicked out
for low frequency of detect had elevated…"
Schlesinger said, "See, right now you are kicking things out
because they didn’t exist…their frequency was low, but..."
Grant said, "Kicking out analytes…"
Schlesinger said, "Kicking out analytes from the background
concentration because you didn’t find them very often, but that
doesn’t assess as to whether they were high or not."
Grant said, "No, and this is not intended to be sort of a broad
characterization of site soils and trying to identify hot spots,
it is really just focused on background, that sort of evaluation
of whether something exceeds background, whether there is a hot
spot in any particular area, is done in a site characterization
for that area. So, for instance, the gun and mortar positions, we
would look and see if there was any exceedences for that particular
analyte that we kicked out; if there were any high levels, and if
there were; we would say these are a concern, and then we would
go to background, not have one. Then we would say that that analyte
is a contaminant of concern, and then we would have to consider
it in the FS process."
Schlesinger said, "OK, I didn’t know, I’m glad you cleared
that up. I know you just talked a little bit with David about the
issue of heavy metals, but I didn’t find them dealt with very well
– there are a couple of sections on metals – but I didn’t find that
anything regarding the heavier metals that I was looking for in
this document. Maybe I missed it, but I thought I covered it pretty
carefully. On the issue of MCPA, page 15, last statement on the
page is a confusing statement. It says ‘the finding that MCPA
concentrations off site are similar to and in many cases higher
than concentrations on-site suggests that MCPA in soil is not attributed
to improper use during military training activities and represents
anthropogenic background conditions’ I think that is in totally
unwarranted because we don’t have information that says how that
MCPA got to that location: ‘the areas we have chosen for off-site
in Phase I investigation are right on the fringe of the base’,
yes they are right just over the current Route 6, but before route
6 and many, many years ago, when all sorts of...…training was going
on, route 6 wasn’t there. There was all sorts of movement of people
back and forth …"
Grant said, "OK so you are saying that we saw a good comparison…source…"
Schlesinger spoke over Mr. Grant saying, "we…we...the...the…to
say that the fact MCP there is not attributed to improper use, remote
training activities…is just not --we don’t have enough information
to say that."
Grant said, "OK"
Schlesinger said, "It may be true, but we don’t have the information
to say that. On page 17 - I dealt with that answer - on page 17,
‘eleven SVOCs were omitted from the evaluation’ and it said
that, "look at the graphical analysis in Appendix A-6 ‘to
show that these are distinct from the remaining lower concentrations’
well I would have had to rip this book all apart in order to see,
to actually check that. Because the…you can’t look at them all they
are all on different pages. You put two on a page or something like
that or three on a page, so you can’t actually compare it to verify
that the statement is actually correct. It may be right but I can’t
see that. I have to go all the way back. I am assuming you are talking
about the graphical representation in the back that shows some little
squares and…it is a little hard to find, you go into there … see
what I mean?"
Grant said, "Yes."
Schlesinger said, "The point may be true but I can’t make it.
I can’t see that it is correct. Two other ones, Oh, I wrote them
down here…one of them I think I already dealt with…Oh, , on the
page that talks about metals. Table 3-2 the last page, page 31,
‘Cyanide was removed due to low number of detections’ I was
wondering, does Cyanide occur naturally?"
Ray Taylor said, "In peach pits, almonds, it does in some instances."
Murphy said, "Do we have peach trees and almond trees on the
Taylor said, "I am just giving you an example."
Murphy said, "Oh, alright. Could we have a… are you set Peter?"
Schlesinger said, "Yes, but we kicked that out and I was just
wondering why we kicked that out, if it is a low detection thing…"
Borci said, "Kicking it out means if we see it anywhere it
will become a contaminant of concern."
Schlesinger said, "OK well if I find anything more here I’ll
let you know…"
Grant said, "Again, the fact we have background for 44 means
that for 156 or more background in ND or in certain cases has yet
to be determined."
Murphy said, "For those people who have not really gone through
this thing, it is really just a small amount of text and a lot of
data and calculations…"
Grant said, "And a few good tables."
Schlesinger said, "And the tables at the end, but unless you
are going to go through and re-calculate like I did in Phase 1 all
the calculations, it is not that big a deal.
Murphy said, "Thanks Peter, COL Murphy."
Murphy said, "Yes, Sir, I would just like to note that we are
well behind and respectfully ask that possibly if you could reorder,
we have some important issues yet to cover, and to see if possibly
you could reorder the schedule for the meeting and lets see if we
can get the meeting somewhere near the tract that was planned in
the original agenda. Thank you."
Murphy said, "Thank you. Is that uh… any more questions for
Marc on this? We have…"
Borci said, "If anyone has any other comments, they can be
emailed to me, email is ‘email@example.com’ and also my phone number
should be around somewhere for the office in Boston. And we can
go over this stuff. This is going to be an ongoing process, we are
trying to get some type of resolution now, so any input and time
that Peter put in is appreciated, and everyone else that did it
also, so thank you."
Murphy said, "Thanks Marc. COL Murphy makes an accurate point
that we are significantly behind an hour and twenty minutes or so.
We still have on the agenda the Status on the Small Arms Range and
Soil Sampling, and then under Other Issues we have; ASR Interviews,
the Northwest Summary of Investigations, Richard asked that we talk
about fact sheets and maps, and then to wrap up the schedule, so,
do we want to proceed with the next item and possibly not cover
the other ones? The next one is the Status on Small Arms Range and
Soil Sampling, I think it is going to take a while, so would that
be fine to go on with that one and leave the other ones until a
Hugus said, "Not with me, sorry."
Murphy asked, "What are you interested in Richard, of the remaining…"
Hugus said, "I would like to discuss shortly the ASR Interviews
and the two things I wanted to mention, the map and fact sheet.
The map and fact sheet aren’t going to take long. I can do that
in like three or four minutes."
Borci asked, "Would folks be OK with putting Small Arms off
until the next meeting?"
Feigenbaum said, "Well…"
Borci said, "That’s the call, I guess, because we can cover
that and Tom Cambareri also had something about Water Supply One
that he wanted a quick update on that. We could cover those three
issues and then call it quits, and cover Small Arms next meeting;
we can do it first thing next meeting."
Hugus said, "Let me ask about that, do we have soil sample
data on the Small Arms Range to present tonight?"
Feigenbaum said, "Well, there is already about three pages
here and we’ve already read it, or some of us have read it. Can
we do just a little bit on this, or a quick?"
Schlesinger said, "We’ve read the statement from the State
about the air sampling, so…"
Murphy said, "Alright, so it sounds like we just want to…"
Schlesinger said, "Can we find out if there is soil sampling
data so we can at least find out some more."
Hugus said, "I also have a comment, you know, COL Murphy is
complaining that this meeting is going on too long, but part of
the reason is that we had a formal hearing on Administrative Order
#4, if the National Guard had not appealed that order we wouldn’t
have had to waste that time."
Murphy said, "We are behind nonetheless, so…you know, I’m just
trying to find out how much we’re going to cover, so should we go
ahead with the Small Arms and then we’ll take up what we can?"
Knott asked: "What time are we quitting?"
Borci said, "Small Arms is going to take the longest; Archive
Search, lets go with that, we can do Water Supply One, we’ll skip
Northwest corner to the next meeting and then go on to Small Arms."
Murphy said, "OK."
Feigenbaum said, "The Archive Search is going to take a while."
Murphy said, "We are trying to…ah…"
note: People began to speak in unison – inaudible
Feigenbaum said, "While Marc is up here can I just ask a couple
of questions quick, you don’t have to do a report. Is that alright?"
note: people began to speak in unison – it was agreed that Dr.
Feigenbaum could have five minutes.
Murphy said, "OK, Take it away."
Feigenbaum said, "I just, not…"
Murphy interrupted, "And Joe also…what time do people want
to get out of here, I think that is the bottom line."
Knott said, "We are out of here at 10:00 p.m. we have the room
until 10:00 p.m. To make it very clear, it is ten o’clock"
Murphy said, "That gives us 20 minutes, go ahead Joel."
Item #4. Status of Small Arms Range Air and Soil Sampling – AMEC
Feigenbaum said, "Number one, is, I think it said here air
had greater downwind detections greater than upwind for five metals.
Those five metals were as much as I believe two orders of magnitude
greater downwind than upwind so I think the study results ought
to be a little more quantitative. Just to say qualitatively greater
than could be one-tenth of a percent greater, but that’s not the
case, it is significantly greater, there should be some adjective
in there or some numbers. The other thing is, Why is it taking so
long to get the soil data validated that was first introduced as
invalidated data two meetings ago, in November. What’s the problem?"
Grant said, "There is a lot of data going through validation
and we have to set priorities in order to keep certain reports on
enforceable milestones, this was not one of the priorities. Other
things such as the report on the targets, reports on J-2 Range were
priorities. So this was pushed back in the validation loop"
Feigenbaum asked, "So when do you expect it will be validated?"
Grant said, "We do have the Sierra East soil and air validated,
those were distributed to the Team last week. We are waiting on
now, Golf and India soil."
Feigenbaum said, "So they are validated but we don’t have the
results? Is that right?"
Grant said, "Those are not validated yet, that is what we are
Feigenbaum said, "Now wait, but there is some validated soil?"
Grant said, "Yes, Sierra East"
Feigenbaum said, "But we haven’t got the…"
Grant said, "You got them."
Feigenbaum said, "When?"
Grant said, "They were sent in the mail last week."
Feigenbaum said, "We just have the air."
Grant said, "That was sent first and the soil was sent actually
FedEx’d with the groundwater report Friday so you should have got
it earlier this week."
Feigenbaum said, "Oh, it is camouflaged with the other report…Oh.
Could you send out another copy just in case."
Schlesinger said, "No, lets go back and check our mailing"
Zanis said, "I’ll give you mine."
Murphy said, "We are going to save two minutes on that five
Hugus said, "Except, let me just say one thing, We have gotten
the short shrift on this whole Small Arms Range report. There is
no introduction to this, it just says ‘see Range Air Monitoring
for the Air Monitoring Event’ We get books for everything else
and when it comes to this you can’t even tell what it is about."
Schlesinger said, "That’s right"
Grant said, "It is not a report. It is just the data."
Hugus asked, "Well, why isn’t it a report though?"
Grant said, "It takes time to write reports. We have not got
to this one yet, but we will."
Hugus said, "Yeah, well, I hope you’ll note the comment then."
Feigenbaum said, "Because you remember we’re supposed to be
using this data to figure out what the following study is, and at
this rate we’re grinding to a slow halt, it is kind of a acidtotic
process. And also I would urge that it be put up in the importance
queue, at least that is my feeling about it because after all, this
is, unlike the other things, an ongoing activity. And since we now
know there is up to five hundred heavy metals downwind air and some
of these ranges are close to residential areas. This is possibly
a real and present danger, and should be moved up in the queue"
Murphy said, "OK, so we have about 15 minutes left."
Schlesinger said, "ASR, are we going to start on those?"
Murphy said, "OK so we have less than 15 minutes left."
Background and overlapping conversation.
Murphy added, "We have to end before 10:00 p.m. so…"
Borci said, "We can spend five minutes on ASR, any…"
Schlesinger said, "Let’s not start it, lets just get the -
and finish this meeting."
Feigenbaum said, "That’s right."
Murphy said, "OK, so Peter’s suggestion is to hold off on the
Small Arms and just get the…excuse me, the ASR. We already covered
the Small Arms. And do the map and fact sheet."
Hugus said, "All right."
Hugus said, "What I have put up here is a map that Paul Zanis
made which shows what we have been asking for. I notice the Joint
Program Office (JPO) isn’t here tonight, we have been asking the
JPO for five months now to provide a map which shows all the contamination
at Mass Military Reservation, so far the only maps that are up for
popular distribution are the ones that show only IRP sites. And
since the JPO hasn’t fulfilled their promise to add the Camp Edwards
National Guard Bureau sites, Paul went ahead and did it himself.
If the Guard can’t come up with a map we are going to ask you to
distribute this one. And if you can’t distribute it, tell us why.
Tell us what the problems are I think that you’ve probably got a
copy by now and if not Paul can get you one. , we need a map and
the reason is that there is a lot of misinformation out there about
exactly how much contamination there is in Camp Edwards. Some of
the people have been going to the meetings and saying that Camp
Edwards is pristine and if the Guard hadn’t kept it so clean we
wouldn’t have future water supplies. It just is not true, a lot
of it. All the work that we have done over the past three and a
half years in mapping contamination has not been represented to
the public in a way for them to understand it or with easily available
information. Along the same lines I feel we need a fact sheet much
like the one we produced as a team a couple of years ago to provide
to the state legislature when it was debating a bill having to do
with turning the fifteen thousand acres of Camp Edwards as a watershed
protection area. The public again needs to know the facts about
what we’ve discovered. A lot of those facts have been memorialized
in the last Administrative Order, and I’d like to ask the team to
put both or this one item on the agenda as a major item for the
next meeting, that is the production of a map and fact sheet to
give to the public about what we found and to make it be coherent
with the existing IRP sites as this map is here. Thank you."
Schlesinger said, "I just want to say that that is a fantastic
idea. And I don’t often agree with Mrs. Crocker but this is a perfect
example of the public not getting access to the information in a
useful manner. I’m part of the public and it is really a bummer
when you can’t get a grasp of the situation in a way that it gives
you a better understanding and we need to make a better effort not
just to get the information to the other people outside this room
but to the people on this team. We all know how much paperwork this
project generates, and how many facts and how many things and some
of us do this full-time for a living, and many of us don’t. So having
an adequate diagram, map, whatever you want to call it, of the entire
picture as a working document along with a fact sheet that adequately
represents the work that we’re doing keeps us straight, and makes
sure that we provide the public, ourselves and the people outside
of this room with the information they need. Thanks."
Murphy said, "Paul."
Zanis said, "Yeah, the map is pretty easy, it is a diagram
fact sheet and with the Order #4 you can read it and look at the
map and get a good idea of with some IRP information, you can see
that LF-1 is a landfill. And the black areas are soil removal, I
think it is kind of nice and it gives you a good idea of what’s
been happening at this base. If you think that one plume is drawn
too large, well I drew them small but as we kept getting the information
I had to keep making them bigger so this time I said I’d make them
a little bigger yet because it is going to catch up to it. I don’t
think anybody can argue that point. So, I’d like to see this distributed
at the next Impact Area Review Team meeting, by the Guard over there
on that table, and if not I’ll bring them. And I’ll distribute them
outside the door if you don’t like it. So they are going to be out
there one way or the other, I’d like to see the Guard pay for it
and have them out there with the fact sheets. So let’s get it together
here and start telling the people the truth, instead of telling
them all this funny kind of information that is really stretching
reality quite a bit.
Murphy said, "OK, we have about two minutes…"
Borci said, "Just on that as an Action Item we can check with
JPO and see what the status of the map is."
Murphy said, "Richard, you had your fact sheet item?"
Hugus said, "Actually I don’t want to wait another month for
the JPO to respond to this request, no, what I want is for us to
come up with our own map and fact sheet, for people to bring their
suggestions to the next – draft fact sheets to the next meeting."
Murphy said, "Tina"
Dolen introduced herself and said, "I’m glad that you did bring
that up because I did want to mention that at the start or actually
before the next meeting, the Community Involvement team including
EPA and MADEP and ourselves are going to host an open house that
will start at 4:30 pm, at the Holiday Inn on the twenty-seventh
if that is the date that you said in fact, and if that place is
agreeable to you, and one of the purposes is to get information
from the public to find out what exactly is wanted and to provide
as much information as we can to the public about what the Groundwater
Study Team has been doing and to use it as a good exchange of information
with the support of EPA and MADEP, so I hope that you will be available
to participate in that exchange. And with respect to the map and
JPO, I think I did hear last night at the Senior Management Board
meeting, that that map is in the final drafting stage and it has
had comments and that I’d encourage you to check with Jan and she
can give you that information."
Murphy said, "Thanks Tina."
Zanis said, "I’ve heard it too many times about to make it
palatable to the citizens, the military likes to treat the citizens
like we are stupid so they give you a map with no information on
it like the SMB a couple of meetings back about the water supply
wells, they had a map on the wall with nothing on it. It was pretty
much blank. And I think this is good example…I’m going to make sure
that that map is in the schools, that the kids have them, parents
have them, everybody’s got them, so whether you like it or not,
JPO, the map is going to be out there. I’d like us, as a team to
give that the approval. It is pretty darn accurate; all the sites
are up there. There is more tank targets than listed, so if anything
I’m a little conservative and I think it is a good informational
tool. It shows the base for what it is and that is what it is right
Murphy said, "Thanks Paul, we’re going to have to end so we
can get out of the room…"
Feigenbaum said, "Just one more on this…There is really good
institutional grounds on having a joint Plume depiction because
really, in fact now, for one of the crucial plumes FS-12, the IART
is actually providing the money for the wells. So that they split
samples now for the study of FS-12, that’s why Paul has that red
overlap at FS-12. And it is just intellectually necessary to see
these things together because in fact more and more the two studies
are joining forces. There is a problem with the way AFCEE does things,
which is they only update their plume maps once a year, so the depictions
are actually fictional. That’s why Paul and I drew in that little
sloppy FS-1 there because it just turns out it is a lot worse than
they thought, also LF-1 is now in Red Brook Harbor and all of the
JPO depictions show it stopping a good deal short of that…"
Murphy said, "Joel we have to wrap it up so we can get out
of here so…"
Zanis interrupted and said, "I want to say it is real tough
to pull up a bitmap and color it in…"
Murphy spoke over Mr. Zanis saying, "Paul, Paul, We really
have to finish, LTC Knott has his thing up this will be the last
Feigenbaum said, "Well, that depends on what he says."
Knott said, "This will be the last word for the National Guard
Bureau tonight. The National Guard Bureau can not commit at this
time to a date for the next Impact Area Review Team Meeting."
Hugus said, "Why not?…Why…?"
Knott said, "That’s all I have to say."
Item #7. Other Issues
Item #9. Adjourn
Murphy said, "OK, well I guess we’ll…the date we were originally
proposing was Tuesday, February 27, so I’ll be getting back in touch
with people on that. Thanks for coming." The meeting was adjourned
at 10:00 p.m.
to hold the Approval of the Nov. 28 Minutes until the next IART
due to the fact that the presenters were not able to review them.
Status: The November28, 2000 IART minute’ approval is being
held off until the next IART meeting.
Hugus’s request, Mr. Walsh-Rogalski said he would research EPCRA
law on the subject of whether explosives that would trigger ‘Right-to-know’
in the community, and what limitations there may be on that Law.
requested the Guard to investigate and report the breakdown products
requested that Perchlorate be added to the COC list.
requested TOSC members be provided monthly Technical Reports which
contain information for modeling.
next IART, AMEC will provide information on where additional wells
will be installed
items will be included on the next IART agenda:
Corner Summary of investigations
will provide a map & fact sheet to be distributed that will
contain IRP plumes and IAGWSP areas of contamination
of Action Items