Impact Area Review Team

River River Drops of rain on a leaf

Impact Area Review Team
Christ the King Parish
Mashpee, Massachusetts
July 24, 2001
6:00 p.m.

Meeting Summary

Member:

Organization:

Telephone:

Fax:

E-mail:

Todd Borci

US EPA

617-918-1358

617-918-1291

Borci.todd@epa.gov

Jane Dolan

US EPA

617-918-1272

617-918-1291

dolan.jane@epa.gov

Margery Adams

US EPA

617-918-1753

 

adams.margery@epa.gov

Len Pinaud

MA DEP

508-946-2867

508-947-6557

leonard.pinaud@state.ma.us

Ben Gregson

IAGWSP

508-968-5821

508-968-5286

ben.gregson@ma.ngb.army.mil

LTC David Cunha

MAARNG

508-968-5883

508-968-5906

David.cunha@ma.ngb.army.mil

Marty Aker

AFCEE/MMR

508-968-4670

508-968-4673

Marty.aker@mmr.brooks.af.mil

James Kinney

Citizen

508-362-7680

 

Jamkin@capecod.net

Joel Feigenbaum

ABC/JPAT

508-833-0144

 

Joelf@cape.com

Richard Hugus

Citizen

508-540-6034

 

Rhugus@cape.com

         

Facilitator:

Organization:

Telephone:

Fax:

E-mail:

Jim Murphy

US EPA

617-918-1028

617-918-1029

murphy.jim@epa.gov

         

Attendee:

Organization:

Telephone:

Fax:

E-mail:

Tina Dolen

IAGWSP

508-968-5620

508-968-5286

Tina.dolen@ma.ngb.army.mil

Bill Gallagher

IAGWSP

508-968-5626

 

Bill.gallagher@ma.ngb.army.mil

Gina A. Tyo

USACE

508-563-7859

 

Gina.a.tyo@usace.army.mil

Henry Byers

AFCEE/MMR

     

Justin Mierz

MDPH

508-968-4366

 

Dave.williams@state.ma.us

Millie Garcia-Surette

MADEP

508-946-2727

 

Millie.garcia-surette@state.ma.us

Brian Nickerson

Citizen

   

Brian@comfacs.com

Janet Pepin

Citizen

     

Evelyn Hayes

Citizen

     

George Gardner

Citizen

     

David Doyle

Citizen

781-278-5853

   

David Dow

Sierra Club

508-540-7142

 

Ddow@whsun7.wh.whoi.edu

Lou Seijido

 

978-273-2182

   

Kevin Dennehy

Cape Cod Times

508-888-5454

   

Marc Grant

AMEC

978-692-9090

 

Marc.grant@amec.com

Herb Colby

AMEC

978-692-9090

 

Herb.colby@amec.com

Rick Carr

STL Inc.

781-455-0653

 

Rcarr@stl-inc.com

Brian Hill

Tetra Tech

     

John Blount

Jacobs Engineering

     

Ken Gaynor

Jacobs Engineering

508-548-0761

   

Doug Shattuck

Directional Tech.

203-248-9599

 

Dshattuck@directionaltech.com

Elizabeth Stevens

Guild

   

E_stevens1@dca.net

Ann Sieben

ECC

508-229-2270

 

Ann.sieben@ecc.net

Magda Kroll

GZA Environmental

781-278-5838

   

Jim Cleveland

GZA Environmental

781-278-5838

   

Kathy Driscoll

CH2M HILL

508-968-5145

 

Kathleen.driscoll@ma.ngb.army.mil

Emily Derbyshire

CH2M HILL

508-968-5146

 

Emily.derbyshire@ma.ngb.army.mil

Jane A. Pierce

CH2M HILL

508-968-4678

508-968-4927

Jane.pierce@mmr.brooks.af.mil

Jenn Coutinho

CH2M HILL

508-968-4670

508-968-4927

Jennifer.coutinho@mmr.brooks.af.mil

Deirdre DeBaggis

CH2M HILL

508-968-5631

508-968-5286

Dierdre.debaggis@ma.ngb.army.mil

Handouts Distributed at Meeting:

  1. July 24, 2001 Draft Meeting Agenda

  2. June 26, 2001 Draft Action Items

  3. June 26, 2001 Draft Meeting Minutes

  4. IAGWSP Groundwater Study Update, IART Briefing 7/24/01

  5. IART Groundrules

  6. Snake Pond Posting

  7. UXO Discoveries/Dispositions Since 06-26-01 IART

  8. Impact Area Groundwater Study Program General Fact Sheet

  9. Map: Aerial Magnetometry Results with RDX detections in the Central Impact Area

  10. Map: Groundwater Findings, Massachusetts Military Reservation, June 2001

  11. Presentation Handout: IAGWSP New Detects Update

  12. Presentation Handout: Depleted Uranium Investigation at the J-1, J-3, and U Ranges

  13. Presentation Handout: J Ranges Response Plan Update

  14. Presentation Handout: Draft J1/J3/L Ranges Additional Delineation Work Plan (J-1 1000m Berm and Petroleum-like Material)

  15. Presentation Handout: Demo Area 1 Soil Screening of Alternatives

  16. Report: Depleted Uranium Investigations at the J-1. J-3, and U Ranges of the Massachusetts Military Reservation, Draft Report, June 6, 2001

Agenda Item #1. Welcome, Approval of June 26, 2001 Meeting Minutes, and Draft Agenda

Mr. Murphy convened the meeting at 6:15 p.m. and asked if there were any changes to be made to the June 26, 2001 Impact Area Review Team (IART) meeting minutes. Mr. Gregson stated that on page 11 the word redux should be replaced with the word redox. No other comments were offered and the minutes were approved with one change. Mr. Murphy then asked the team members to introduce themselves.

Mr. Murphy reviewed the agenda and asked if there were any recommended changes or additions. Mr. Hugus requested an update on the Small Arms Ranges Investigation under "Other Issues." Mr. Murphy agreed.

Agenda Item #1. Review Action Items

Mr. Murphy reviewed the action items from the June 26, 2001 IART meeting.

  1. Dr. Feigenbaum requested that a copy of the Central Impact Area plume map overlaid with Aerial Magnetometry (Air Mag) data as displayed at the June 26, 2001 IART, be distributed to the team.

  2. Mr. Murphy noted that the map was included in the mailing and is on the handout table at tonight’s meeting. Mr. Hugus asked why there is a close correspondence between the detections shown in blue and the Impact Area boundary. Mr. Gregson replied that it is a function of how the air mag survey is conducted; when the helicopter turns around near the Impact Area boundary. He explained that those blue areas are not real magnetic anomalies, but have not yet been screened out of the map.

    Mr. Borci added that ongoing fieldwork includes examining detections on the ground to determine whether or not they are real anomalies. He said that part of the difficulty of air mag technology is the screening of air mag data to make these determinations. Anomalies that are not real are screened out of the air mag data, and the current map has been screened once so far.

    Mr. Hugus stated that he does not understand why the helicopter making two passes over the Impact Area boundary would cause apparent detections. Mr. Borci noted that the detections could include a number of things such as utility lines and overlap of other ranges. He also said that he would look into providing the team with a technical answer to this question from Tetra Tech.

  3. Mr. Hugus requested that the attendance list from the Impact Area Groundwater Study Program (IAGWSP) weekly technical meetings be distributed along with the meeting minutes in e-mail.

    Mr. Murphy noted that the attendance list is now included in the weekly progress reports.

  4. Mr. Murphy will incorporate comments made to the draft IART groundrules and distribute the revised draft IART groundrules to the team.

    Mr. Murphy stated that the IART groundrules were sent in the mailing and are available at the handout table at tonight’s meeting.

  5. Ms. Dolen, with the regulators, will incorporate comments made to the draft general fact sheet and distribute the revised draft fact sheet to the team.

    Mr. Murphy noted that the revised draft fact sheet, which is available for the team members tonight, will be printed soon after the team’s final review.

  6. Mr. Schlesinger requested that when documents are distributed to the team, that the IAGWSP office provide the name of the contact person to submit comments to and by what date the comments are due.

    Mr. Murphy stated that comments should be sent via e-mail to Mr. Gregson of the Impact Area Groundwater Study Program (IAGWSP), with copies to Mr. Borci of the United States Environmental Protection Agency (EPA) and Mr. Pinaud of the Massachusetts Department of Environmental Protection (MADEP).

  7. Mr. Schlesinger requested an update on the status of the four people who have expressed interest in joining the IART.

    Mr. Murphy noted that this is an agenda item for tonight’s IART meeting.

  8. Mr. Hugus requested that the Guard provide to the team what their intentions are for the posting at Snake Pond.

    Mr. Murphy noted that Snake Pond has been posted and a copy of the posting was included in the mailing and is available as a handout this evening.

    Mr. Hugus commented that he is glad the posting was done; however, he believes that the posting itself is not accurate. He noted that Royal Demolition Explosive (RDX), which was detected in the well located at the spit in Snake Pond, is thought to be upwelling about 250 feet downgradient of the spit, and the posting does not state that. Ms. Dolan explained that the upwelling is based on modeling, and surface water samples collected in the northern cove of Snake Pond near the spit are nondetect for explosives. She noted that the United States Geological Survey (USGS) has developed diffusion samplers that will be placed on the pond bottom in the northern cove of Snake Pond and tested for RDX. Ms. Dolan added that Mr. Gregson will discuss the diffusion samplers during the J Range Response Plan Update on tonight’s agenda.

    Mr. Hugus stated that although the upwelling of RDX is based on modeling, he believes that the public should know about it. He said that he thinks that the posting should incorporate what the modeling predicts, that diffusion sampling is going to be done, and what the results of the diffusion sampling are. Mr. Mierz stated that surface water sampling is being conducted biweekly from the beaches at Snake Pond, and results have been nondetect.

    Dr. Feigenbaum noted that the posting does not indicate that the investigation has not been completed, and it gives no explanation of explosives being probable carcinogens, which is the reason for the posting in the first place. He said that he believes that the posting should state that investigations are ongoing.

    Mr. Pinaud noted that the citizen team members would like the posting to include a statement that explosive contaminants are suspected carcinogens, that the explosive compounds are likely to upwell into the pond, and that the investigation is continuing. He said that he has no problem adding these statements to the Snake Pond posting, but is uncertain about the process. Mr. Mierz stated that the posting was a joint effort undertaken by several different agencies identified at the bottom of the posting.

    Mr. Kinney stated that he does not believe that the posting is a warning; he believes it is more of a reassurance. Even though there are nondetects in surface water, the modeling shows that contamination is upwelling, and he thinks that the posting should identify the contaminants and the potential effects of exposure. He said that he believes that the posting should include a statement that the investigation is ongoing so that the public is made aware of the potential hazards. Ms. Dolan noted that whenever new data become available; the public is notified immediately - whether the data are detect or nondetect.

    Ms. Garcia-Surette commented that the public needs to be provided with information that is factual, based on real live analytical data and detections. While modeling is a great tool to help steer the efforts of an investigation, it is easy for the public to be misled or confused about what, in reality, could perhaps be modeling. For a posting such as the Snake Pond posting, the protocol has been to identify detections, and to her knowledge, there was no deviation in the protocol for the Snake Pond posting. Ms. Garcia-Surette also said that any information that is based on modeling or potential exposure points, and is to be presented to the public, would need to be carefully worded.

    Mr. Kinney stated that if the purpose of the posting is to truly warn the public, then the public needs the information. He acknowledged that the information needs to be clearly identified, but stressed that it must be available so that people can make their own judgments. He noted that the modeling that shows possible upwelling of plumes, the potential effects of the chemicals being discussed, and the fact that there have been nondetects in surface water are all pertinent pieces of information that he thinks should be included in the posting.

    Ms. Garcia-Surette stated that as long as the public understands that modeling is used as a tool and is not reality, she is not opposed to stating that modeling indicates possible upwelling. She added that the important piece to understand is that the agencies’ approach is to depend on real data, which is why the USGS is gathering real data through the diffusion sampling effort.

    Mr. Dow stated that the posting is warning about mercury levels in the fish is too small and does not stand out against the rest of the posting as a true warning. Mr. Mierz replied that the Massachusetts Department of Public Health (MDPH) has recommended that the mercury advisory be printed in red or bold lettering because it is the posting’s most important piece of information at this time from a public health standpoint.

  9. Mr. Schlesinger requested that the Guard check on the location of residential wells on the southeastern end of Snake Pond.

    Mr. Gregson noted that five wells have been sampled in that area, and to date all samples are nondetect for explosives and perchlorate.

    Mr. Murphy stated that the future agenda items are all on tonight’s agenda with the exception of the update on Chemical Spill-18 (CS-18), which is tentatively on the agenda for the August IART meeting, and the update on CS-19, which will be on either the September or the October IART meeting agenda.

Agenda Item #3. Introductions of Potential New IART Members

Mr. Murphy noted that of the four people who had requested membership to the IART, two are present at the meeting tonight to introduce themselves.

Ms. Hayes introduced herself as a resident of Yarmouthport. She noted that she has an undergraduate degree from Boston College and a Masters Degree in Nursing, also from Boston College. She said that she worked for the United States Public Health Service in Panama and Alaska, and then attended the Heller School for the Advancement of Social Policy at Brandeis University where she majored in community organization and the development of social policy. She then taught at the University of Miami for ten years, moved to Cape Cod several years ago and currently is writing a textbook. Ms. Hayes also mentioned that her brother is a long-time resident of Bourne. She said that she has reviewed the minutes from IART meetings, and she welcomed any questions from the team.

Dr. Feigenbaum asked what kind of community organizing Ms. Hayes has done. Ms. Hayes replied that while she was at Brandeis she did a lot of work with the neighborhood health centers, and also was involved with the "A" and "B" organizations under the Dukakis administration. She further noted that her thesis at Brandeis was deinstitutionalization, and that she taught about about health when she lived in Panama and in Anchorage, Alaska.

Ms. Pepin, a Falmouth resident, introduced herself and read a letter that she’d written to Mr. Borci, in which she’d noted that she has been following Massachusetts Military Reservation (MMR) issues and attending IART meetings for the past two years. She said that her credentials include recently receiving a Dean’s award from Suffolk University Law School for advancing the civic and professional responsibility of the legal profession by progressive academic research of issues related to MMR. Ms. Pepin informed the team that she studied at Suffolk University Law School, Suffolk University School of Management, Harvard University, and Bristol Community College. She said that she has worked as a legislative aide for the Commonwealth of Massachusetts, and currently is a registered nurse. She also noted that she has lived in Barnstable County for eleven years, and has owned a home in Falmouth for seven years.

Mr. Hugus inquired about Ms. Pepin’s research of MMR issues. Ms. Pepin replied that she wrote a paper on the Sandwich pipeline, as well as a paper entitled "Difficulties on Obtaining Information through State and Federal Agencies about the Massachusetts Military Reservation: Freedom of Information Act Implications," which she wrote a for a public policy course taught by Speaker of the House Thomas Finneran.

Mr. Murphy stated that Mr. Dick Judge, a Sandwich Selectman and member of the Senior Management Board, also is interested in becoming a citizen member of the IART, but is not present at the meeting to speak this evening. Mr. Murphy thanked Ms. Hayes and Ms. Pepin, and asked the current IART members to send any recommendations to him by Friday so that he could inform the EPA regional administrator, who ultimately would appoint the new members.

Agenda Item #4. Demo Area 1 Soil Screening Report

Mr. Gregson stated that comments on the Demo Area 1 Screening of Alternatives report would be taken at the meeting this evening or via e-mail by July 31, 2001. He noted that 15 contaminants of concern (COCs) have been identified at Demo Area 1, including Royal Demolition Explosive (RDX), High Melting Explosive (HMX), trinitrotoluene (TNT), 2-amino dinitrotoluene (2A-DNT), 2,4-dinitrotoluene (2,4-DNT), 2,6-dinitrotoluene (2,6-DNT), nitroglycerine, and hexachlorobenzene.

Mr. Gregson reported that approximately 4375 cubic yards of soil at Demo Area 1 have been identified for removal and subsequent treatment. He stated that the bulk of excavation would occur at the bottom of Demo Area 1, and other areas outside of Demo Area 1 would be treated individually.

Mr. Gregson noted that part of the screening report is an assessment of soil associated with burn pits identified at Demo Area 1. Since the report was delivered, additional burn pits have been discovered during excavation of magnetic anomalies at Demo Area 1.

Mr. Hugus asked Mr. Gregson to describe a burn pit and the kind of activities that happened there. Mr. Gregson replied that these pits, which appear to have been used as open burn areas for munitions, are identified by black ash and fragments of munitions in the soil. Mr. Borci added that munitions would be placed along with scrap, wood, and paper, and burned with fuel so that the explosives would melt rather than explode. Mr. Gregson stated that the COCs identified in burn pits, which include antimony, lead, arsenic, dioxins, hexachlorobenzene, 4-methylphenol, and benzene, and are typically found at much higher concentrations than surrounding soil and may require a different type of treatment.

Mr. Gregson noted that there is a table in the handout that lists all the technologies assessed for Demo Area 1. He reported that 12 remedial alternatives were developed from the retained technologies. Each remedial alternative was screened in accordance with Administrative Order # 3 (AO#3), based on their effectiveness, implementability, and cost. As a result of this process, seven remedial alternatives were retained and five were eliminated.

Mr. Gregson reported that the remedial alternatives that were eliminated were the minimal action, the excavation and incineration, and the in-situ alternatives, which included capping, land farming, and thermal blanket. Remedial alternatives that were retained were the excavation alternatives of off-site land disposal, on-site composting, bioslurry treatment, chemical reduction, solidification stabilization, and thermal desorption.

Discussion

Dr. Feigenbaum asked if the retained alternatives address the top layer of soil only. Mr. Gregson replied that the majority of the soil would be treated; however, there would still be residual RDX at depth, which would be migrating into the water table. An alternative to remediate the RDX at depth would be to construct an infiltration gallery, combined with a groundwater treatment remedy. Mr. Gregson added that currently the Guard is trying to establish the historic bottom of Demo Area 1, and ultimately will excavate everything above the historic bottom. He noted that native soil below the historic bottom would likely contain dissolved RDX. Dr. Feigenbaum then asked Mr. Gregson to describe thermal desorption. Mr. Gregson replied that with thermal desorption the soil would be heated and any volatiles would be captured in a vapor-phase carbon filtration unit.

Mr. Hugus asked which alternatives, other than off-site disposal, would be good for burn pit soil. Mr. Borci replied that the level of dioxin contained in burn pits eliminates most treatment technologies except for off-site disposal. He added that dioxins could have been created by incomplete combustion of chlorinated compounds like hexachlorobenzene; he noted that very high dioxin levels were found next to burnt flares.

Mr. Hugus asked Mr. Gregson to explain the Innovative Technology Evaluation (ITE) program, which was mentioned in the report. Mr. Gregson replied that about a year ago the Guard started the ITE program to try to evaluate and identify what could be considered an innovative technology. He stated that the ITE is a group, which consists of representatives from the Guard, AMEC, the Army Environmental Center (AEC), and the United States Army Corps of Engineers (USACE), evaluates technologies that may be applicable at MMR.

Mr. Hugus then asked why EPA disapproved of the Demo Area 1 screening report. Mr. Borci explained that EPA has several options when reviewing a document. EPA can approve a document, approve a document with modifications, or disapprove a document. Based on the number of modifications that needed to be made to the Demo Area 1 Screening of Alternatives report, EPA disapproved the report and asked the Guard to resubmit it within two weeks. He added that one of EPA’s concerns was that a number of burn pits were discovered in the field after the document was written. Another concern was that more attention and detail should have been given to the native soil located at and below the historical bottom of Demo Area 1.

Mr. Dow stated that he is concerned about the effectiveness of the soil washing process. He suggested that a pilot test be conducted and that a sequential treatment process be developed for different contaminants attached to or in the matrix of the soil. He also said that most of the community thought that desorption and thermal treatment was an inappropriate technology clean up soils at the fire training areas, and he doesn’t see any changes that would make this appropriate for cleanup in the Impact Area today. Mr. Gregson asked Mr. Dow to explain what some of the concerns of the community were. Mr. Dow replied that it was thought thermal desorption would not capture all of the contaminants and could create more problems than excavating and removing the soil.

Mr. Borci clarified that any of the treatment technologies could be used in combination with any other. The technologies that are carried forward into the feasibility study would determine which combination of technologies would be appropriate.

Agenda Item #5. Depleted Uranium Report.

CPT Myer stated that the historical review of the response from Textron to the section 104E information request showed that from 1982 through 1984 11 depleted uranium (DU) warheads were loaded at the J-3 Range and 11 DU warheads were shipped to a weapons testing facility in New Mexico. In 1998 the Guard conducted a DU survey and citizens became concerned that DU may have been used at some defense contractor ranges. CPT Myer noted that the regulatory agencies were not involved in this DU survey.

CPT Myer reported that in July 2000 the regulators, the Guard, and contractors discussed the need to conduct additional DU survey work at defense contractor ranges. The final work plan for the DU investigation report was finalized and approved by the regulatory agencies in January 2001, and a scope of work was developed with the agencies to address all data gaps from the previous DU survey. During the archive search interview process, one of the interviewees identified some areas where DU may have been used on some of the ranges. Fieldwork was conducted and the draft DU report was submitted in June. The Guard received comments back from EPA in July 2001.

CPT Myer explained that the investigation, which screened for radiation at selected sites, involved analyzing for total uranium, not the specific isotope of DU. He also stated that the investigation work complied with the Multi Agency Radiation Survey and Site Investigation Manual (MARSSIM). He explained that the MARSSIM document, which was put together by EPA, the Nuclear Regulatory Commission (NRC), the Department of Energy (DOE), and the Department of Defense (DoD), provides a uniform way to perform radiation survey investigations.

CPT Myer reported that at the J-1 Range a beta gamma and a gamma survey were conducted of soils beneath the steel plate at the 1000-meter berm. Four penetration points were selected, the plate was removed, soil samples were collected from 0–1 foot and 3-4 feet, and the samples were analyzed. Also, background soil samples were collected and analyzed for total uranium, gross alpha and gross beta.

CPT Myer noted that at the J-3 Range beta gamma and gamma surveys were conducted at areas 5, 7, and 9. Five soil samples were collected at the warhead test firing range, and a background sample also was collected. The background sample was nondetect for total uranium (TU), and showed 17 counts per minute (CPM) for gross alpha, and 21 CPM for gross beta.

CPT Myer explained that an alpha survey was conducted on the steel plates, but not on the soils, because alpha particles are low energy particles. If DU was fired and the DU isotope was in the soil, soil would shield any alpha readings or alpha particle emissions. Therefore gamma and beta gamma surveys were done on the soils. He also noted that the background sample for steel plate filings, at plate number 6, was nondetect for total uranium, gross alpha, and gross beta.

CPT Myer stated that at the U Range alpha and beta gamma surveys were done of a tank target and the

3-meter buffer area around the tank. Daily background surveys were conducted at three locations, and measurements for alpha, gamma, and beta gamma were taken in order to get a baseline measurement, because naturally-occurring radiation fluctuates. CPT Myer noted that all the instruments were calibrated with certified sources and all sampling and analytical protocols conformed to EPA requirements for quality control. He added that procedures outlined in the work plan were approved by the regulatory agencies.

CPT Myer reported that the commonly used screening criteria by EPA and NRC for radiological contamination is two times the background rate. The investigation results identified two areas that were equal to two times the background. At the J-3 Range, area 9/grid 4 measured 70 CPM, for beta gamma, and the background was 35 CPM. On steel plate number 1, there was a beta gamma measurement of 70 CPM, and the background was 35 CPM; alpha was nondetect. CPT Myer noted that the survey looked at different suspect areas on the plate that could have been perforation holes from potential DU shape charges; out of all the measurements, there was only one that was equal to twice the background.

CPT Myer noted that for the steel plate and the location at the J-3 Range, the beta gamma result did not exceed twice the background; rather it was equal to twice the background, and none of the alpha measurements exceeded background. He said that readings of an actual DU detection have measurements in the 200+ CPM range, and when there is a potential presence of total uranium both alpha and beta gamma measurements are typically present.

CPT Myer concluded his presentation by noting that data gaps from previous work have been filled. The results from the investigation identify two areas with measurable levels of radiation that meet two times the background. All remaining areas surveyed were less than two times the background reading for soil, metal filings, alpha, gamma, and beta gamma surveys. He also said that regulatory comments still need to be discussed and public comments incorporated into the DU report before it is finalized.

Discussion

Mr. Kinney questioned the margin of variability in the measurements, given that the background number fluctuates daily. Mr. Hill of Tetra Tech introduced himself as the person who actually performed the measurements. He noted that he took background measurements from locations outside the J-1 gate and the J-3 gate, and down the road from the J-3 Range in order to establish a baseline of soils that was similar in makeup, but not in close proximity to where contamination might be present. He explained that the background readings were averages; actual readings varied from 30 CPM to 40 CPM per day or by a factor of about 10 CPM. Mr. Hill added that he has investigated sites where DU was used and those readings ranged from 200 CPM to 500 CPM, so the measurements at Camp Edwards are very low.

Mr. Kinney asked how reliable the measurements are, given the amount of variability. Mr. Hill explained that lower CPMs are vulnerable to more statistical error. He also noted that the highest readings are the ones listed in the tables, even though he collected many more readings that were much lower; the highest readings were kept to be conservative. Mr. Hill stated that where measurements were twice the background, he checked more carefully for an increase in CPM, and didn’t see any increase in the measurements.

Mr. Hugus asked if there is a signature for a DU hit, and whether DU corrodes or weathers over time. Mr. Hill replied that DU fuses with metal, producing a gray fusion or "melting" look. He noted that the half-life of uranium is 106 years, which is millions of years, and corrosion or rust might act as a shield, which is why metal filings were analyzed.

Mr. Kinney noted that the executive summary of the DU report includes the statement that a commonly used criterion accepted by EPA a NRC is two times the background rate to consider an area potentially contaminated. The executive summary also includes the statement that the survey showed that none of the suspect areas exceeded that accepted criterion. Mr. Kinney stated that the criterion was met, not exceeded, and the wording in the report puts a red flag up for him. He then asked why the report doesn’t recommend additional data collection or sampling and analysis activities. CPT Myer replied that the Guard is going to discuss these issues with the regulators and other experts, and then decide whether or not further action should be taken.

Per the IART’s request at the August 28, 2001 meeting for further clarification, a portion of the verbatim transcript has been included below:

Mr. Hugus: My final comment is that since there were two hits that reached an action level, that further testing be done. And that I see that there’s real sensitivity to location when this testing takes place and that it would be, well for one thing easy to miss DU. You could even miss it on a steel plate looking at the variety of measurements there just on the same plate. So maybe a refinement of the testing and certainly as Joel and Jamie were alluding to, retesting the two hits to see about fluctuation.

CPT Myer: Well we’ll take that into consideration. We’re going to talk with the EPA and the DEP about the comments on the reports and where we go next. I mean, that’s the next step of the process. Tonight I was here to present you the information and overview of what we did to give you an understanding of that, what the results, what our interpretation of it is. And the next steps, as I said on the slide with future steps, is to negotiate, discuss the comments with EPA and DEP and make that evaluation. We’ve got, you know, we’re using our experts. The information says what it says, we’re using the standards that were developed by EPA, NRC, DOE, DOD. I mean everyone bought into this process, even the regulatory folks bought into it. So, there’s a defined process and we’re moving down the road to see what we do next.

Mr. Murphy thanked CPT Myer and announced that additional comments can be e-mailed or faxed to Mr. Gregson at the Impact Area Groundwater Study Program office, at 508-968-5286.

Agenda Item #6. Investigations Update.

New Detections

Mr. Gregson reported that new detections include perchlorate detected in two wells at Demo Area 1. Well 35M1 had a perchlorate detection at 4 parts per billion (ppb), and well 75M2 had a perchlorate detection at 9 ppb. Unvalidated detections include 2ppb for perchlorate in well 90MW0022, located west of the J-3 Wetland, and 2 ppb for perchlorate at well 158S, located at the entrance to the J-2 Range.

Dr. Feigenbaum inquired about the health advisory level for perchlorate. Mr. Borci informed that a level has not yet been established, but is being developed. He said that he expects that the level will be in the 4 to 18 ppb range.

Mr. Gregson stated that as part of an investigation of apparent wastewater disposal by Textron or AVCO at the location of the 1000-meter berm, well 136 was installed in the vicinity of the popper kettle, which is a steel box used to burn munitions. At that well, RDX was detected at 1.6 ppb and HMX was detected at 1.9 ppb. Downgradient of this area three wells were installed: well 166, which had RDX detections ranging from 0.5 to 4.7 ppb, and HMX detections ranging from 0.7 to 0.49 ppb; well 58, which had a RDX detection at 7.4 ppb, and an HMX detection at 1.2 ppb; and well 168, which showed no detections of explosives. Well 58S had a RDX detection of 5.3ppb and HMX at 1.4 ppb and well 164 had a detection of RDX at 12 ppb and HMX at 0.93 ppb.

J Range Investigation and the Petroleum-like Material (PLM)

Mr. Gregson reported that the PLM was identified in well 164, well 168, and in monitoring well 170, which is located to the north of the former K Range. He noted that testing of the drill rig fluid ruled out the rig itself as a source of this material, and a fingerprint fuels analysis indicated that the PLM is a hydrocarbon, similar to Jet Petroleum 8 (JP-8), or a kerosene or diesel-type material. He noted that a number of semi-volatile organic compounds (SVOCs) were detected, including n-nitrosodiphenylamine; 2,4-dimethylphenol; 2- methylnaphthalene, which would be a fuel component; bis-2-ethylhexylphthalate; and di-n-butyl phthalate, fluorene, and naphthalene, which were all typical fuel semivolatiles; and phenol. Herbicide/pesticide analyses were nondetect. Extractable petroleum hydrocarbon (EPH) analysis is ongoing. This method, which is used under the MADEP Massachusetts Contingency Plan (MCP) provides a measurement of concentrations of different types of petroleum compounds as well as a more detailed forensic fingerprint that could provide more information on the type and potential source of the PLM.

Mr. Gregson continued his update on the J Range investigation by noting that future actions include the installation of five additional wells proposed for the vicinity of the 1000-meter berm. Well J1P4 would be installed to provide additional information on the particle backtracks from wells 164 and 168; well J1P11 would be a cross-gradient well; well J1P12 would be located downgradient of well 166; and well J1P13 would be a cross-gradient well to help bound, or perhaps detect again, the PLM found in well 164. The purpose of well J1P14 would be to help bound contamination on the east side and evaluate potential sources for the PLM.

J Ranges Response Plan

Mr. Gregson also stated that the J Range Response Plan, which pertains to the Snake Pond area, includes conducting biweekly sampling of drive-points and surface water near the Snake Pond beaches. He noted that three surface water samples were collected in the north cove area of Snake Pond and drive-point and surface water samples were all nondetect. He also reported that the Guard is working with the USGS to find a diffusion sampling membrane that will allow an RDX molecule to pass through. A membrane is currently being tested using water samples carrying a range of concentrations to see if RDX will pass through the membrane. In addition, two existing sentry wells will be sampled from Weeks Pond to get more information on the western edge of Snake Pond.

Agenda Item #7. Other Issues

Small Arms Ranges Investigation Update

Mr. Gregson stated that currently the Guard is in the middle of Phase 2b of the investigation, and has provided information on S, E, G, and I Range, which are the current Small Arms Ranges locations. He noted that data from four historical ranges will be arriving soon and will be presented as part of the Phase 2b report on August 20, 2001. Based on information in the Phase 2b report, the Guard will assess what additional former or current small arms ranges require further investigation. He also noted that the AEC currently is testing emissions from traditional M-16 rounds and green M-16 rounds.

Agenda Item #8. Agenda Planning and Review Action Items

Mr. Murphy stated that the CS-18 update and the Phase 2b report will be on the agenda for the August IART meeting. Mr. Murphy then reviewed the action items as they appear at the end of these minutes.

Agenda Item #9. Adjourn

Mr. Murphy announced that the next IART meeting is scheduled for August 28, 2001 and then adjourned the meeting at 9:20 p.m.

Action items:

  1. Dr. Feigenbaum requested that the Guard provide a technical response that explains the amount of anomalies shown on the Central Impact Area aerial magnetometry survey map border.

  2. MADEP and EPA will discuss updating the Snake Pond posting with the Air force Center For Environmental Excellence (AFCEE), the Sandwich Board of Health, the Massachusetts Department of Public Health (MDPH), the Joint Program Office (JPO), and the Impact Area Groundwater Study Program office (IAGWSP).

Status of Action Items

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