Area Review Team
Distributed at Meeting:
May 22, 2001
Draft Meeting Agenda
2001 Draft Meeting Minutes
April 24, 2001 Action Items
Since 04-24 IART
handout: IAGWSP Investigations Update
handout: Archive Search Report (ASR) Integration & Enhancement
handout: Airborne Magnetometer Surveys
handout: Rapid Response Action (RRA) Update
Activity Calendar – Joint Program Office
#1. Welcome, Approval of April 24, 2001 Meeting Minutes, Review
Handouts, and Draft Agenda
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.
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."
Item #2. Review of Action Items
Murphy reviewed the Action items from the April 24 meeting.
Mr. Hugus requested that the National Guard Bureau (NGB) provide
information on any ongoing Textron litigation.
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
Mr. Schlesinger requested that the Guard assess ecological receptors
of air and soil from firing events at Camp Edwards.
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.
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
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.
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
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.
Mr. Schlesinger requested that the Environmental Protection Agency
(EPA) risk assessors review the revised calculations of the Army
Corps of Engineers small arms report.
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.
Item #3. Munitions Survey Update
Archive Search Report Update
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
Magnetometry I & II Update
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.
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
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.
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.
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
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
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.
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.
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
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.
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.
Item #4. Groundwater Study Update
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.
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.
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.
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
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.
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.
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.
1 Plume Update
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.
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.
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.
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.
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.
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.
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.
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.
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
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.
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.
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.
Item #5. RRA Update
1 and Group 2 Status
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,
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.
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.
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.
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.
Borci stated that seven of the eleven mortar targets that were sampled
had explosive residues around them; Mortar Target 9 was the highest.
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.
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.
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.
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
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
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.
Item #7. Review Action Items and Future Meeting Dates
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
Item #8. Adjourn.
Murphy adjourned the meeting at 9:15 p.m.
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.
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.
asked the Guard to provide the 10 Sources of Information for the
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.
will report back to the IART the status of the non-aqueous liquid
that was detected at monitoring well 164 (MW-164).
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
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.
asked that the Army Corps of Engineers (USACE) report on options
to support the Technical Outreach Services for Communities (TOSC)
requested that the Guard distribute to the IART the report regarding
heavy metal contamination on training ranges provided by Mr.
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.
requested that the maps in the presentations be clear and readable.
provide a summary of the information reviewed at Textron’s attorney’s
will provide information on the vulnerability of Impact Area Groundwater
Study Program (IAGWSP) funding to Federal budget cuts.
requested that an update be provided on the status of bioslurry.
Chemical Spill-18 (CS-18) and Chemical Spill-19 (CS-19) update
of the investigation of 1000 meter berm at the J-1 Range
groundrules and process
Risk Assessment process
of Action Items