Impact Area Review Team
The Forestdale School
Sandwich, Massachusetts
May 22, 2001
6:00 p.m.

Meeting Summary

Handouts Distributed at Meeting:

1. May 22, 2001 Draft Meeting Agenda

2. April 24, 2001 Draft Meeting Minutes

3. Status of April 24, 2001 Action Items

4. UXO Discoveries/Dispositions Since 04-24 IART

5. Presentation handout: IAGWSP Investigations Update

6. Presentation handout: Archive Search Report (ASR) Integration & Enhancement

7. Presentation handout: Airborne Magnetometer Surveys

8. Presentation handout: Rapid Response Action (RRA) Update

9. MMR Integrated Activity Calendar – Joint Program Office

Agenda Item #1. Welcome, Approval of April 24, 2001 Meeting Minutes, Review Handouts, and Draft Agenda

Mr. Murphy convened the meeting at 6:00 p.m., welcomed the team members, and asked them to introduce themselves. He then asked if there were any changes to be made to the April 24, 2001 Impact Area Review Team (IART) meeting minutes. There were no changes and the minutes were approved as written.

Mr. Murphy asked if there were any recommended changes or additions to the agenda. Mr. Hugus requested that an Air Force Center for Environmental Excellence (AFCEE) presentation on Chemical Spill 18 (CS-18) and Chemical Spill 19 (CS-19) be added under "Future Agenda Items." Mr. Aker stated he will discuss Mr. Hugus’s request with Mr. Robert Gill and Mr. Mike Minior of ACFEE. Mr. Schlesinger requested that the IART invitations and groundrules be discussed under "Other Issues."

Agenda Item #2. Review of Action Items

Mr. Murphy reviewed the Action items from the April 24 meeting.

1. Mr. Hugus requested that the National Guard Bureau (NGB) provide information on any ongoing Textron litigation.

Mr. Murphy noted that the status on this item is that as previously stated, this case is still pending and comment is neither advisable nor allowed. Mr. Hugus noted that he had read in a previous progress report that the United States Environmental Protection Agency (EPA) went to Hale & Dorr in Boston to review Textron records. Ms. Dolan stated that Hale & Dorr represent Textron in some capacity. Mr. Hugus requested that EPA share the information with the IART. Ms. Dolan replied that she would put together a summary report for the IART.

2. Mr. Schlesinger requested that the Guard assess ecological receptors of air and soil from firing events at Camp Edwards.

Mr. Murphy noted that as stated in the response to this action item, the groundwater programs are conducted under the closely defined directives under the of the Administrative Orders pursuant to the Safe Drinking Water Act. As such, the National Guard’s exclusive role and responsibility is to protect the sole source aquifer of Cape Cod through its ongoing work plans agreed to with EPA.

Mr. Pinaud stated that the Massachusetts Contingency Plan (MCP) requires characterization of the risk of harm to human health, safety, public welfare, and the environment, and an ecological risk assessment is required at the end of the remedial investigation process. He added that the Massachusetts Department of Environmental Protection (MADEP) intends to request that the Guard make a presentation to the IART on ecological assessment when the investigation phase is complete.

Mr. Schlesinger asked EPA to identify the Guard’s obligation under the Safe Drinking Water Act (SDWA) with respect to delineation of ecological receptors. Ms. Adams stated that the section of the SDWA, under which the orders were issued, speaks to human health, not environmental risk. However, EPA is supportive of an ecological risk assessment and believes that should be a thorough evaluation of environmental risk at the site. Mr. Pinaud reiterated that under the MCP, the Guard is required by law to do an ecological risk evaluation.

Mr. Dow inquired about the requirements for an ecological risk assessment. Mr. Pinaud stated that under the MCP, the ecological risk assessment would be done in two stages. The first stage would be a comparison of concentrations to screening thresholds. The second stage would be actual sampling of wildlife and plants. Mr. Hugus asked if the assessment would be for the entire Camp Edwards. Mr. Pinaud stated that the obligation is to perform the risk assessment wherever the contamination exists.

Mr. Gregson asked if an ecological study was done at CS-19 under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Mr. Aker replied that a study was done and he will provide the findings to the team.

3. Mr. Schlesinger requested that the Environmental Protection Agency (EPA) risk assessors review the revised calculations of the Army Corps of Engineers small arms report.

Mr. Murphy noted that an EPA risk assessor has reviewed the revised calculation presented at the last IART meeting, and has determined that the revised calculation is correct.

Agenda Item #3. Munitions Survey Update

Brief Archive Search Report Update

CPT Myer introduced himself and stated that he is going to present an update of the Archive Search Report (ASR) integration and enhancement. He noted that his presentation is an overview of some of the documents recently submitted and some of the work that has been done regarding the ASR process.

CPT Myer stated that the two objectives for the ASR are to collect additional information to support the ongoing groundwater investigation, and to present the findings in a Geographical Information System (GIS) - based platform to assist the Guard and inform the public.

CPT Myer reported that the Guard visited Picatinny Arsenal to review available contract records, and noted that additional information was identified and submitted to the archive search team for review. Six agencies that had done work at the defense contractor ranges were contacted; however, most of the responses indicated that there was no available information. He noted that Picatinny Arsenal had the most information and the contracts record report is expected to be completed by the end of May.

CPT Myer noted that a draft military history report was delivered to the archive search team. The report, which identifies units that historically trained at the Massachusetts Military Reservation (MMR) contains information about the type of training that was conducted and the types of ordnance or explosive-related material that might have been used to support the training. Ten sources were contacted to provide the information. CPT Myer noted that beyond the fact that units trained here, currently there is no knowledge of how much ordnance or ordnance-related material was used. However, the Ammunition Supply Point (ASP) contains ammunition draw records that identify quantities of munitions drawn to support training, and these draw records also will be reviewed.

CPT Myer stated that the draft ASR is scheduled to be available for public review and comment on July 13, 2001. That the draft GIS-integrated ASR product is scheduled to be available for public review and comment on November 30, 2001.

Ms. Adams inquired about the dates of the earliest records available at the ASP, and whether any are located off base. CPT Myer replied that he would check into that.

Mr. Schlesinger asked if there will be any effort to gather additional information by contacting individuals who trained at the base in the past. Ms. Dolan replied that the group of interviewees included individuals who trained at the base; however, fairly limited information was shared. She also noted that the Guard recommended placing advertisements in certain military magazines as well.

Mr. Schlesinger inquired about the relationship of ASR to the Administrative Record for the IAGWSP. CPT Myer explained that all the documents that the Guard is required to keep will be stored at the administrative record. The ASR, however, is an historical review containing ordnance-related and contracts information. He also noted that both will be available electronically to the public.

Mr. Hugus inquired about Range Control records with respect to individuals who had trained at MMR. He asked how far back those records go. LTC Bailey replied that he believes that the records date back to about mid 1974.

Mr. Hugus inquired whether the private investigator working for the ASR is still actively working. CPT Myer replied that the investigation work for the interviews has been halted. Ms. Adams explained that the Department of Justice (DOJ) requested that the private investigator stop work temporarily. Mr. Hugus asked that the message be sent to the DOJ that the private investigator is a valuable asset to the team and the IART would like to see him continue his work.

Aerial Magnetometry I & II Update

Mr. Raye Lahti, from Tetra Tech, stated that the helicopter used for aerial magnetometry (air mag) has three magnetometer sensors on the booms placed six meters apart for data coverage. In the Impact Area, data were collected from roughly 2200 acres in only 10 days. He noted that an advantage of using air mag is that trees do not have to be cut down. Also, it is a good screening tool to help focus investigations, and is more efficient in terms of cost and time than a traditional geological survey on the ground. Mr. Lahti noted the air mag survey was successful in evaluating high-density target areas within the Impact Area.

Mr. Lahti explained that the first processing step involves the use of a bay station magnetometer that monitors the earth’s magnetic field, which varies throughout the day. The next step is to process the collected data into grid coordinates using a differential Global Positional System (GPS). Next, helicopter corrections and regional magnetic gradients are taken out of the data. The result is a map that shows where anomalies were detected from the original magnetic gradient.

Mr. Lahti explained that a laser altimeter is mounted on the helicopter to off-set the scale of topography data, i.e. trees and terrain. The laser altimeter measures the elevation along the grids. Then, the elevation is adjusted and calculated to produce a smooth map of anomalies. Mr. Lahti then displayed examples of data anomalies shown on the map compared to pictures of what was actually found out in the field.

Mr. Lahti stated that earlier data sets, called analytic signal maps, are evaluated. He noted that targets are identified using line profile data, also known as ground information, and laser altimeter data, which indicate how well a sensor is working. In the verification process, global positioning units are used to identify precise targets and locations. Then, in the field, photographs are taken of the anomalies that have been verified. Mr. Lahti noted that all of these data are entered into a geographical information system in order to keep track of what was looked at and what was not looked at. The database keeps track of everything that was mapped out through the air mag process and physically looked at on the ground.

Mr. Lahti stated that out of the 2200 acres of Camp Edwards where the air mag survey was conducted, 6800 targets were selected from the geophysical survey and 73 targets were selected for initial evaluation. He noted that the U-Range on the north side of the Impact Area is called Area 1. This area consists of 130 acres, where 253 targets were identified by air mag and 10 targets were selected for initial evaluation.

Mr. Hugus asked how the targets are selected. Mr. Lahti stated that the primary selection tool is to look at areas that may have been or are accessible to troops, and the primary goal is to detect any caches.

Mr. Zanis asked if any of the anomalies were used to track contamination back to its source. Mr. Borci replied that preliminary data were used to place wells in the field where there were anomalies and high detections in the same area. The data were used to make the well placements as efficient as possible. Mr. Gregson added that he thinks that the degree of accuracy to tie the contamination to a specific anomaly probably is less than the scale being used presently.

Mr. Lahti continued by reporting that the B-9 training area, designated as Area 2, consists of 255 acres, where 2574 targets were identified by air mag and 21 primary targets were selected for initial evaluation. Area 3 includes the J-Ranges, where 3576 targets were identified by air mag and 35 targets were selected for initial evaluation. Area 4 includes the southern training ranges near the ammo supply point, which make up a majority of the gun and mortar firing positions. In that area, 6000 anomalies were identified by air mag and 68 primary targets were selected for initial evaluation. Mr. Lahti noted that many utilities, fences, and other surface features will need to be eliminated by investigation on the ground.

Mr. Hugus asked how it is decided which targets to investigate. Mr. Borci replied that a number of areas in Camp Edwards are known; therefore, one way of sorting out the data is to examine anomalies that do not correlate with known existing objects. He also noted that this is the first screening cut. Additional targets will be examined.

Mr. Hugus stated that he believes that good work is being done, but he would like to see results. Mr. Lahti replied that data were collected from over 5,000 acres, and it is hoped that some results will be available after the field work this summer.

Mr. Dow inquired about the timeframe for determining whether the anomalies are surface anomalies or sub-surface anomalies, once the high-priority targets have been identified. Mr. Borci replied that work on the highest-priority sites will begin this summer. Most of the work that was shown tonight will be investigated this summer and into the fall. He also noted that the Guard will begin excavation work with the Gravity Anti-tank Range and the current ammo supply point. He added that active work will be ongoing on from this point forward, through the rest of the year.

Agenda Item #4. Groundwater Study Update

Recent Detections

Mr. Gregson reported that under Phase IIb, well 167 was installed downgradient of training area BA-1. Another well installation is being planned for the western part of the historic Small Arms Ranges. He also noted that at the J-Ranges, wells 166 and 168 were installed downgradient of the 1000-meter berm. Detections in profile samples taken from these wells showed mainly Royal Demolition Explosive (RDX) up to 8 parts per billion (ppb). Mr. Gregson added that well 169 was installed at the edge of Snake Pond on the beach near Camp Good News, and well SP-2 was installed on the spit that juts out into the northern edge of Snake Pond.

Mr. Schlesinger asked if well 169 will be tested while camp is in session. Mr. Gregson replied that sampling will be completed before camp opens, and the next sampling round will take place in September, when camp is over.

Mr. Gregson continued by reporting wells J1P1 and J3P10 were installed as part of the J-Ranges response plan. He noted that three wells have been approved to be drilled in the central Impact Area, and two wells are proposed at Demo Area 1. He also reported that while drilling, a non-aqueous liquid was discovered at a depth of 170 to 200 feet below water table. The composition of the liquid currently is unknown and analytical test results are anticipated.

Mr. Hugus requested a separate update on the 1000-meter berm for the next IART meeting. He noted that the detections being discovered there are significant. Mr. Gregson replied that a work plan for additional investigations will be presented at the next meeting, at which time plans for additional well drilling near the berm can be discussed.

Mr. Zanis asked if the non-aqueous liquid is being sampled. Mr. Gregson answered that it was. Mr. Dow asked if the non-aqueous liquid is being tested for RDX. Mr. Gregson replied that he will have to check.

Mr. Gregson then reported that two shallow well profile samples from well 167, at training area BA-1, showed RDX at 0.7 ppb and nitrobenzene at 0.5 ppb. He noted that dinitrotoluene (DNT) and trinitrotoluene (TNT) breakdown products previously were detected in the Land Fill 1 (LF-1) in this area, which is why well 167 was installed upgradient of LF-1. He added that the wells installed at this location are scheduled to be sampled shortly.

Mr. Gregson stated that three wells are being installed as part of the additional investigation at the central Impact Area, where as many as 25 wells will be installed. He noted that well CIA-P5 is located downgradient of monitoring well 23 (MW-23); CIA-P1 is located off of Turpentine Road; and well CIA-P2 is proposed to be drilled north of well MW-96. He said that EPA has approved drilling for those wells. Also AFCEE plans to install up to three additional wells downgradient of CS-19 as part of its investigation.

Demo Area 1 Plume Update

Mr. Gregson reported that well 165 had profile detections of up to 70 ppb in a location that is consistent with what is being seen in the Demo Area 1 plume. He noted that currently there are two proposed well locations to help define the downgradient extent of the Demo Area 1 plume; they are D1P5 on Frank Perkins Road, and D1P6 on Pugh Road. These wells will help define the southern extent and the toe of the Demo Area 1 plume.

Mr. Gregson stated that soil sampling has been completed for all of the Phase IIb areas. He also reported that monitoring wells have been installed at the Gravity Range, Demo Area 2, the former K-Range, the training range BA-1, the former ASP, and the inactive demo sites. He added that one well is to be installed at the former Small Arms Ranges, either B, C, or D.

Mr. Gregson stated that two of six areas on the K-Range had detections of RDX and/or Her Majesty’s Explosive (HMX). RDX was detected in soil at 280 ppb, HMX was detected at 270 ppb in grid 138-H, and HMX was detected at 1600 ppb in grid 130-Q. He noted that all the other soil samples were non detect for explosives. Mr. Gregson stated that well K-1 is in the process of being installed, and results should be available shortly. He said that K-1 is being installed on Wood Road, downgradient of the two detections.

Mr. Gregson further reported that at the Gravity Range there were detections of TNT in soil in the range of 1600 to 9000 ppb for breakdown products in grids 132-E, 132-G, Q, R and U. He added that HMX was detected in grid 132-N soil samples.

Mr. Hugus asked what level of TNT triggers the state reporting procedure. Mr. Grant replied that it is 100 parts per million (ppm) for the Massachusetts Contingency Plan. Mr. Borci clarified that those numbers are reportable concentrations and are not necessarily what would be chosen as a cleanup level. He also said that TNT adheres to soil a little bit more than RDX does, and it appears to break down into breakdown products, which may not adhere as much. All of that would be part of the feasibility study process for the soil at Demo Area 1. He noted that EPA would come up with a cleanup number that is much lower, somewhere around EPA detection limits for those compounds.

Mr. Gregson continued by reporting that at Demo Area 2, there were detections of RDX between 150 and 560 ppb in soil sample grid 133-T. He noted two wells were installed downgradient of Demo Area 2, well MW-160 and MW-161; results are not yet back from those two wells.

Mr. Gregson stated that some grab samples were collected at the former ASP to the northeast; those samples were non detect for explosives. Also, well 156, which was installed downgradient of the former ASP, was non detect for explosives in profile sampling. Mr. Gregson noted that AFCEE installed a well as part of its investigation work on the Southwest Operable Unit (SWOU), and split samples for explosives. Those samples were also non detect.

Mr. Gregson reported that the J-1/J-3/L Range additional delineation work plan is coming up at the end of the month. The draft Demo Area 1 soil report, which will summarize all existing data to date for this area, is coming out the second week in June. The Central Impact Area groundwater Feasibility Study (FS) screening report is due to come out on June 14, 2001, and will take an initial look at some of the technologies that may be applicable for cleaning up groundwater in the Central Impact Area. Also, the draft Demo Area 1 soil FS screening report is expected to come out at the end of June.

Mr. Dow inquired about the depth of the soil sampling. Mr. Gregson replied that sampling is done at 0 to 3 inches, and then at 6 inches to 1 foot. He added that typically soil contamination is seen in the surface, not at depth. Mr. Borci added that soil contamination would not be expected to be seen any deeper than the first one or two feet.

Mr. Hugus stated that at a previous IART meeting, the citizens asked the Guard to provide an inventory for the ASP. The citizens were denied this request but were told that EPA would be allowed to make a visual inspection of the ASP. Mr. Hugus asked if this inspection has been conducted.

Mr. Borci replied that the inspection was conducted in mid April, and EPA is reviewing what was observed in order to initiate a discussion with the Guard. He noted that some items appeared to be precluded from use by the EPA order; however, the Guard had shipped out a lot of the items that were there originally, and many items that remained in the ASP are expected to be shipped when funding becomes available. Mr. Hugus asked the Guard to confirm what was shipped out as an action item for the next meeting.

Mr. Schlesinger asked if cuts in the federal budget are expected to preclude the Guard from being able to carry out some actions associated with the groundwater study. Mr. Gregson replied that he will discuss the budget with the Guard and get back to Mr. Schlesinger.

Agenda Item #5. RRA Update

Group 1 and Group 2 Status

Mr. Gregson stated that Rapid Response Actions (RRA) were set up under Administrative Order # 3 (AO#3) as one of a type of site where actions could be taken immediately, or rapidly, to deal with levels of contaminants in soil that may pose a threat to groundwater. He noted that the first group of RRA, which were completed last year, included the KD-Range, the armored personnel carrier in the Impact Area, Gun Position 7, and some contaminated sediments in the J-3 Wetland. He noted that approximately 810 cubic yards of soil was removed by October 1, 2000. The soil was sent through a soil washing system, and 300 cubic yards of gravel and stones were treated and returned to the Impact Area. Site restoration was completed by December 1, 2000.

Mr. Gregson reported that remaining work from the first group of RRA includes soil that needs to be re-washed in order to optimize the separating of clean rocks from contaminated fine material. He noted that approximately 500 cubic yards of fine material is scheduled to be processed along with RRA Group II soils. He also mentioned that details of the RRA Group I are provided in the draft Completion of Work Report, which is dated April 30, 2001.

Mr. Gregson then stated that in November 2000, EPA amended AO#3 to add two RRA sites - Mortar Target 9 and the former H-Range, which is located off post. The Guard prepared an RRA work plan addendum, a Release Abatement Measure (RAM) plan modification, and a delineation field sampling plan, which were approved by EPA and MADEP. The first round of the delineation was completed and documented in a draft soil contamination summary report that was issues last month.

The main finding of that report was that additional delineation is required at both locations. Mr. Gregson noted that delineation samples detected RDX at the D-3 sampling point, and TNT at D-7. Also, the composite for the outer wring, that is 35 feet from the center of Mortar Target 9, showed levels of TNT above the RRA cleanup goals.

Mr. Gregson reported that the work on Mortar Target 9 includes finalizing of contracting for additional delineation of soil removal. The environmental documentation was prepared, and the Record of Environmental Consideration has been approved through the Natural Resources office on post. Mr. Gregson noted that the Guard put in an extension request to EPA to allow time for the additional delineation sampling prior to soil removal.

Mr. Borci stated that seven of the eleven mortar targets that were sampled had explosive residues around them; Mortar Target 9 was the highest.

Mr. Gregson continued by noting the former H-Range is part of a Formerly Used Defense Site (FUDS). He stated that the United States Army Corps of Engineers (USACE) is managing upcoming response actions under the FUDS program with a deadline to accomplish removal by September 1, 2001.

Mr. Gregson also stated that upcoming activities at Mortar Target 9 include soil sample delineation, removal of soil, and site restoration, and the same types of activities will be conducted at the H-Range. He noted that coordination with the Conservation Commission will be added because the Guard is getting into the 100-foot buffer zone of the wetland, where unexploded ordnance (UXO) clearance and additional delineation and soil removal need to be conducted.

Agenda Item #6

Other Issues

Mr. Hugus asked when the Impact Area Groundwater Study Program (IAGWSP) office is going to put out a news release regarding the depleted uranium survey. Mr. Gregson replied that a news release will not be released until the data have been reviewed. He noted that the Guard, MADEP, and EPA have not seen those data yet.

Mr. Schlesinger inquired about the status of invitations to new team members. Mr. Murphy replied that the plan is to provide IART team members with draft groundrules. Then, IART members can think about how many citizen members are needed on the team. He noted that it was never really established how many was a workable amount, and he would like some feedback on this from the team. Mr. Murphy stated that he also would like team members to consider a process for declaring someone an inactive member, including the number of meetings that would have to be missed, notification, and so forth. He said that this process should be established before any new members join the IART.

Mr. Murphy asked the citizen team members to contact him within the next couple of days regarding these issues, which will be discussed at the next IART meeting on June 26, 2001. He also suggested that the review on comments on the groundrules be handled via email. He said that he would incorporate comments and then re-distribute the groundrules document, which he hopes could be adopted at the June meeting.

Mr. Murphy added that between now and the next IART meeting he will ask for a formal response from the agencies that were invited to join the team.

Agenda Item #7. Review Action Items and Future Meeting Dates

Mr. Murphy reviewed the action items, which appear at the end of these minutes. He also noted that IART meetings are scheduled for June 26, 2001, July 24, 2001 and August 28, 2001. In addition, the team discussed future agenda items, which also appear at the end of these minutes.

Agenda Item #8. Adjourn.

Mr. Murphy adjourned the meeting at 9:15 p.m.

Action items:

1. The Air Force Center for Environmental Excellence (AFCEE) will be asked to provide the findings of the Ecological Risk Assessment that was performed at Chemical Spill–19.

2. Ms. Adams requested that the Guard report back to the IART on how far back in time the Ammunition Supply Point (ASP) records go and whether records are located off-base in addition to on-base.

3. Mr. Schlesinger asked the Guard to provide the 10 Sources of Information for the Administrative Record.

4. Mr. Hugus requested that the Environmental Protection Agency (EPA) bring the IART’s request for the continued use of the private investigator to the Department of Justice.

5. The Guard will report back to the IART the status of the non-aqueous liquid that was detected at monitoring well 164 (MW-164).

6. Mr. Schlesinger requested that the Guard overlay Aerial Magnetometry (Air Mag) data over the existing Central Impact Area map to see if the Air Mag anomalies correspond with increased detections of Royal Demolition Explosive (RDX).

7. Mr. Hugus requested that the Guard report back to the IART regarding whether the items that were due to be shipped out of the Ammunition Supply Point per EPA were actually shipped out.

8. Mr. Schlesinger asked that the Army Corps of Engineers (USACE) report on options to support the Technical Outreach Services for Communities (TOSC) program.

9. Mr. Hugus requested that the Guard distribute to the IART the report regarding heavy metal contamination on training ranges provided by Mr. Zanis.

10. Mr. Hugus requested that a copy of the editorial from the May 6, 2001 Cape Cod Times about the issue of ecological receptors be distributed in the next IART mailing.

11. Mr. Schlesinger requested that the maps in the presentations be clear and readable.

12. EPA will provide a summary of the information reviewed at Textron’s attorney’s office.

13. The Guard will provide information on the vulnerability of Impact Area Groundwater Study Program (IAGWSP) funding to Federal budget cuts.

14. Dr. Stahl requested that an update be provided on the status of bioslurry.

15. Future Agenda Items:

    1. Comprehensive Chemical Spill-18 (CS-18) and Chemical Spill-19 (CS-19) update by AFCEE.

    2. A review of the investigation of 1000 meter berm at the J-1 Range

    3. Water supply update.

    4. IART groundrules and process

    5. Ecological Risk Assessment process

    Status of Action Items