Impact Area Review Team

River River Drops of rain on a leaf

Impact Area Review Team
The American Legion
Sandwich, MA
October 23, 2001
6:00 p.m. – 9:30 p.m.

Meeting Summary





Ben Gregson



LTC David Cunha

HQ Camp Edwards


Jane Dolan



Todd Borci



Margery Adams



Ellie Grillo



Len Pinaud



Marty Aker



Tom Cambareri

Cape Cod Commission


Jim Stahl



Janet Pepin

Teaticket resident


Evelyn P. Hayes

Yarmouthport resident


James Kinney



Joel Feigenbaum



Richard Hugus

Falmouth resident







Jim Murphy








Pamela Bonin



Tina Dolen



Mike Minior




Robert Gill




Mark Applebee



Rob Clemens



Kim Harriz



Marc Grant



Michael Jasinski



Desiree Moyer



Justin Mierz



Henry Byers



Jan Larkin




COL Albert Bleakley




LTC Will Tyminski




Bill Downs

Jacobs Engineering



Ken Gaynor

Jacobs Engineering


Pat deGroot



Mark Hutson

Ellis Environmental


Mark Franson

Charter Oak Envr.


Pete Delano

Nobis Engineering Inc


Rick Newill

Foothill Engineering


Richard Skryness


Tom Fogg

IT Corp



Dave Egan

IT Corp


David Cobb



Doug Shattuck

Directional Technologies


David Dow

Sierra Club


Karen Foster




Les Perry

Sandwich citizen



Lori Boghdan



Mary Meli



Deirdre DeBaggis



Handouts Distributed at Meeting:

  1. October 23, 2001 Draft Meeting Agenda
  2. September 25, 2001 Draft Action Items
  3. September 25, 2001 Draft Meeting Summary
  4. Responses to Action Items from September 25, 2001 IART meeting
  5. Small Arms Propellant Composition from MIDAS Database – IAGWSP
  6. Screening Values and Standards for Detected Compounds in Soil
  7. Map: Impact Area RDX Source and Detection Areas with AirMag Signal and Targets – AMEC
  8. MMR Buried Ordnance Discoveries
  9. Propellant Combustion Product Analyses on an M16 Rifle and a 105mm Caliber Gun
  10. Presentation handout: Demo 1 Groundwater FS Report
  11. Presentation handout: Small Arms Ranges
  12. Presentation handout: CS-19 Supplemental Remedial Investigation Update
  13. Impact Area Groundwater Study Update – October 2001

Agenda Item #1. Welcome, Brief Overview of the Impact Area Review Team, Approval of September 25, 2001 Meeting Minutes, Review Draft Agenda

Mr. Murphy convened the meeting at 6:08 p.m. and welcomed the attendees. He said that he wanted to take a minute to provide a brief overview on the history of the IART. He mentioned that there were several items available on the back table that pertain to the Groundwater Study Program. He stated that the team was established in 1997 when the United States Environmental Protection Agency (EPA) instructed the National Guard Bureau (NGB) to begin investigating the groundwater under the training ranges and Impact Area at Camp Edward. He explained that EPA has issued administrative orders outlining what should be done. He noted that the Massachusetts Department of Environmental Protection (MADEP) is also involved under the Massachusetts Contingency Plan (MCP), which is a set of environmental rules and regulations. He explained that there are several areas of Camp Edwards that are under investigation. He noted that IART members are comprised of citizens from various towns around the Cape, representatives from EPA, DEP, the Massachusetts Army National Guard (MANG), the NGB, the Cape Cod Commission (CCC), and the Air Force Center for Environmental Excellence (AFCEE).

Mr. Hugus said that he would like to recognize that citizens on the Upper Cape were responsible for calling the attention of the regulatory agencies to the problem that future water supplies were at risk due to the contamination of groundwater caused by plumes emanating from the southern part of MMR. He noted that, ironically, Camp Edwards is situated on top of the most likely future water supplies for the Upper Cape. He also stated that there is a ten-year history of citizen effort brought this situation to the attention of the public officials, and this is partly why the team was established in the first place.

The team members introduced themselves.

Mr. Murphy stated that COL Bleakley provided him with the following change to the September 25, 2001 meeting minutes, which is a correction to paragraph three on page 12. The paragraph reads "a 50-caliber machinegun is fired on MMR, but it uses green ammo", but it should read "a 50-caliber machinegun is fired on MMR, but it uses plastic ammo." He asked if there were any other changes to the September 25, 2001 IART meeting minutes. Mr. Cambareri referred to the top of page 8 and suggested the following statement be added for clarification regarding the AEC report: "The lack of detections of explosive compounds compared to detections of pyrotechnic compounds in the soil of the MMR small arms range testing."

Dr. Feigenbaum inquired about the comment COL Bleakley added about green versus plastic ammunition. He said that he thought that it’s the bullet that’s plastic, not the projectile. COL Bleakley explained that the bullet is plastic and it is referred to as plastic ammunition.

Mr. Murphy asked if there were any more changes to the September 25, 2001 meeting minutes. Hearing none, the minutes were approved with the noted changes.

Mr. Murphy briefly reviewed the agenda. He noted that Mr. Gregson requested some time under "Other Issues" to discuss the N Range findings. Mr. Hugus said that he also has a number of topics he would like to discuss under "Other Issues." He said that he noticed that the agenda did not include a general Groundwater Study update. Mr. Gregson explained that certain sites will be discussed and that time did not allow for a general update. However, the usual information is provided in the handout. Mr. Hugus said that he thinks that a general update would be beneficial for the audience. He also suggested that the team consider adding a "Late-Breaking News" item to its agenda, which would follow the review of the action items. Mr. Murphy said that typically such items are addressed under "Other Issues." However, it is up to the team members to decide. He said that the agenda planners will discuss this issue.

Mr. Cambareri agreed that it would be beneficial to have an overall update, as the material is sometimes difficult to fully comprehend.

Ms. Hayes said that she believes that the material is extremely comprehensive and that meeting time should be utilized for pressing news. Mr. Hugus reiterated that the public would benefit from a general overview. He added that he thinks an overview also would be helpful for team members. He added that past meetings have featured a section regarding a general update.

Agenda Item #2. Review Action Items

Mr. Murphy reviewed the action items from the September 25, 2001 IART meeting.

  1. The Guard will respond to Mr. Cambareri’s question about quartz filter analysis regarding the AEC report.

    Mr. Murphy stated that the quartz filter was used along with the resin packed cartridge for the analysis of energetic materials in accordance with the EPA compendium method TO13A protocols. He noted that Mr. Mike Jasinski has the document "The Compendium of Methods for the Determination of Toxic Organic Compounds and Ambient Air" available for Mr. Cambareri and Dr. Stahl. He added that additional information can be found at the following web site:

  2. Mr. Borci and Mr. Gregson will contact members of EPA and the Army who were involved with the AEC report in an effort to determine whether there is additional information available from the emissions test report, beyond what was sent to the IART.

  3. Mr. Murphy stated that the only additional information available pertains to rounds not currently fired at MMR. The final AEC report, which will be jointly issued by the AEC and the EPA, will be provided to IART members when it becomes available.

  4. If available in the AEC report, Mr. Gregson will distribute data from 50-caliber machineguns using plastic ammunition.

  5. Mr. Murphy stated that to date, 50-caliber plastic rounds have not been tested for emissions. The NGB is working with the AEC to determine if other 50-caliber rounds would yield comparable results.

  6. The Guard will provide the "Fate and Transport" laboratory study report to the Massachusetts Institute of Technology (MIT) representatives involved with the IART.

Mr. Murphy stated that this report will be mailed to the MIT representatives when it becomes available in November 2001.

Mr. Hugus referred to Action Item #4 and stated that he thought the AEC report included tests on 50-caliber machineguns, although probably not with plastic ammo. However, the report should provide some information. Mr. Gregson said that he will provide the team members with data regarding emissions results for the 50-caliber lead bullet rounds. He noted that the emissions results will be different for different types of projectiles because of different the rates of combustion due to the density of the rounds. Mr. Hugus added that he is also interested in data concerning rounds that may have been fired in the past on MMR.

Dr. Feigenbaum asked whether the propellant is the same in both the tungsten tin and lead bullets. Mr. Gregson replied that the propellants are the same. Dr. Feigenbaum asked if the emissions characteristics are different because of the different densities of the projectiles. Mr. Gregson replied that they are. He then explained that it takes different amounts of energy to push the projectile forward, and different burn characteristics in the propellant result in different emissions. Dr. Feigenbaum asked how different the tungsten tin is from the lead. He also asked whether the firing characteristics are the same in terms of usefulness for training purposes.

LTC Cunha explained that the weapons system has been designed so that there is no difference between the actual firing of the tungsten tin bullet versus lead ball ammo; there is no difference experienced by the individual on the ground pulling the trigger. Dr. Feigenbaum said that it would stand to reason that the emissions are similar as well.

Mr. Borci explained that Dr. Feigenbaum and Mr. Gregson originally were talking about 50-caliber plastic versus 50-caliber lead, and there is a difference in the emission between those two. However, the conversation has changed to tungsten tin versus lead. Mr. Gregson said that he will show Dr. Feigenbaum the results he has for emissions of the 5.56 tungsten tin versus the 5.56 lead ammo, which he believes use the same propellant, yet have different emissions results.

Mr. Cambareri noted that at the September IART meeting he requested information regarding the pump tests in the Central Impact Area. Mr. Gregson said that he will provide Mr. Cambareri with the pump and test plan and proposal, as well as the memorandum of resolution.

Action Item # 3. Chemical Spill 19 Update

Mr. Aker explained that the first CS-19 RI was delivered in November 2000. However, it was determined that further investigation was warranted, and a supplemental RI was conducted.

Mr. Aker displayed a map depicting the MMR. He pointed out CS-19, which is a Royal Demolition Explosive (RDX) plume.

Mr. Aker explained that the scope of the supplemental investigation includes the excavation of on-site trenches in an attempt to evaluate magnetic anomalies that may be contributing to the plume. He said that a magnetic survey was conducted and an extensive amount of anomalies were detected. He noted that three trenches were dug where the larger anomalies were located.

Mr. Aker stated that two sample borings were drilled to profile the vadose zone of the surface soils down to the water table in an attempt to determine the contamination profile and to identify what is contributing to the plume. This information will be entered into the model, which will run shortly. A groundwater screening boring also will be installed at the leading edge of the plume. He noted that there was a data gap in the first RI because it did not reach nondetect, or below the health advisory level; therefore the leading edge of the plume was not well defined. Again, the data gap had to be identified because the purpose of an RI is to define the nature and extent of contamination in both soil and groundwater.

Mr. Aker stated that the scope for the supplemental RI also included the development of models to evaluate contaminant transport to groundwater. Also, the risk assessment has been revised. He explained that the original RI contained a risk assessment on the contaminants that were identified at the time; however the supplemental RI addresses new contaminants of concern (COC.) He reported that the final CS-19 RI will be delivered on January 19, 2002.

Mr. Aker displayed a map depicting the CS-19 plume, and commented that it is a rather small site approximately 200 feet by 200 feet. He pointed out the locations of the three trenches. He displayed a graph depicting the soil sample profile at trench #1. He explained that the first two feet of soil were removed and composite samples were taken every 20 feet along the trench. He noted that samples were taken at depths up to ten feet. He added that the graph depicts the major detections of RDX, which includes one detection of 1200 parts per million (ppm). Most of the detections were located within the top three feet of soil at all of the three trenches.

Mr. Aker then referred to trench #2 and noted that a cluster of artillery shells was identified in this trench. He also mentioned that this area was reported to be a disposal site. He then reported that a 57-millimeter (mm) cracked shell was identified in trench #3. He noted that 17 ppm was the highest detection in trench #3.

Mr. Aker stated that the soil investigation identified a number of magnetic anomalies that consisted of spent cracked shell casings, 2.75-inch rocket casings, and motors. Shrapnel, metal debris, pipes, and cable also were identified. He noted that he is convinced that CS-19 was a disposal site, as opposed to other sites that the Impact Area Groundwater Study is examining.

Mr. Aker reiterated that the RDX detections mostly were identified within the top three feet of the soil, and were found directly below cracked shell casings, which were segregated and stockpiled separately. He stated that other contamination that exceeds MMR cleanup levels include lead, iron, and hexachlorobenzene, which was identified in a burn pit in trench #1. He added that dioxin was also detected at levels that potentially could be above cleanup levels. Mr. Aker said that the RI is still under way and cleanup levels are still being determined.

Mr. Aker displayed a map depicting the groundwater investigation regarding the CS-19 plume. He stated that most of the wells in the area are Installation Restoration Program (IRP) wells; however several wells belong to the Impact Area Groundwater Study Program (IAGWSP). He pointed out a recently installed well, which he said was instrumental in defining the leading edge of the plume. He reported that RDX was detected at 0.27 parts per billion (ppb) in this well, which is below the health advisory of 2 ppb. He reported that chlorinated solvents were detected below the RDX, which was not a surprise since the site was used as a chemical disposal site in the 1967/68 timeframe. Trichloroethylene (TCE) was detected at 9.1 ppb and tetrachloroethylene (PCE) was detected at 5 ppb. He added that 3-nitrotoluene also was detected.

Mr. Aker reported that deeper wells are being drilled in order to reach the contamination. He also noted that the IAGWSP well, which is downgradient from CS-19, was nondetect for chlorinated solvents. He added that additional sampling was conducted on several wells to test for chlorinated solvents, since the IAGWSP tests mostly for RDX and other explosives.

Mr. Aker stated that next steps include the following: completion of screening boring for volatile organic compounds (VOC) analysis, completion of particle track analysis to identify likely origin and flow path of chlorinated solvents, completion of unsaturated soils and groundwater modeling, revision of plume shell using current analytical data, completion of the risk assessment, and submittal of the revised Draft Final CS-19 report on January 19, 2002. He reported that the CS-19 Feasibility Study (FS) is scheduled to be submitted on March 22, 2002; the CS-19 proposed plan is due on July 24, 2002, which will be followed by a public comment period; and the Draft CS-19 Record of Decision (ROD) is scheduled to be submitted on December 20, 2002.

Mr. Kinney asked Mr. Aker how confident he is that the plume is not wider than it appears, considering the location of some of the detections. Mr. Aker replied that some of the detections are at different levels, which would indicate that they are not originating from the CS-19 source. He stated that he thinks that the plume is pretty well defined by the wells that are in place. He also pointed out three particular wells where screening profiles were taken approximately every ten feet.

Mr. Kinney asked how well the IRP is coordinating with the IAGWSP regarding well location. Mr. Aker replied that the IRP and IAGWSP work closely together, and regularly share information. Mr. Kinney asked if the IAGWSP has plans to install additional wells to identify the source of the detections. Mr. Gregson replied that an extensive investigation program is under way in that part of the Central Impact Area. A total of 25 monitoring wells will be installed to further define the extent of the finding surrounding the CS-19 plume area.

Mr. Schlesinger asked if the timelines will be affected if contamination is detected in the new well. Mr. Aker replied that he anticipates that the RDX plume schedule will proceed according to schedule. However, it would be a different story if a VOC plume is detected.

Mr. Hugus explained, for the benefit of the audience members, that the Air Force insisted on having CS-19 under its auspices, which, he thinks diminishes a comprehensive overview. He then asked Mr. Aker if he has a cross-sectional view of CS-19 in relation to the Central Impact Area. Mr. Aker replied that he did not have a cross-sectional view available tonight. He reiterated that the supplemental RI is a work in progress and that he is providing an interim update on the project. Mr. Hugus requested that a cross-sectional map be provided at future presentations.

Mr. Hugus stated that there are high concentrations of RDX in the soil at CS-19, in particular the detection of 1200 ppm, and yet cleanup activities will not be taking place until 2003. He added that CS-19 was identified under the Superfund program in 1989, which means it will be 14 years before any meaningful cleanup will have occurred. He stated that he thinks it is his duty to insist that EPA take action on soil cleanup as soon as possible before further contamination occurs. Mr. Aker reiterated that CS-19 is a small site, and he noted that the excavation of the three trenches removed a great deal of the contamination. He explained that the IRP and the regulators are discussing how to best address the soil that has been removed, segregated, and stored in polyethylene to prevent further leaching of contaminants into the soil. Mr. Hugus said that he is pleased to hear that the contamination has been segregated. He also suggested that protocol should dictate that contaminated soils, especially those at such high concentrations, be removed without having to go through cumbersome bureaucratic procedures. Mr. Borci concurred, and said that EPA is trying to move the soil and groundwater remedy along as quickly as possible.

Mr. Hugus said that he thinks that the 9.1-ppb TCE detection in groundwater is an important new finding. Mr. Aker stated that the detection of TCE was not completely unexpected because the area was used as a chemical disposal site in the 1960s. Mr. Hugus asked why TCE is suddenly being detected when AFCEE has been testing for VOCs since 1989. Mr. Aker explained that there are many detached plumes on MMR. Mr. Gill added that the IRP is pursuing the TCE detections. He said that he hopes that the recently installed well will yield data that will help to provide a better understanding of why TCE is now being detected. He said that information regarding this matter will be included in the RI report and will be provided to the Plume Cleanup Team (PCT) and the IART.

Mr. Cambareri asked what is responsible for the curvature that is depicted in the CS-19 plume. Mr. Gaynor explained that the moraine on the site changes the direction of groundwater flow so there is a slight kink in the plume trajectory. Mr. Cambareri noted that there is a lot of fluctuation in the area and several different water table measurements; given that, he wonders if there is enough information available to look at slight variations in the projection of flow over time. Mr. Aker stated that there have not been many wells in that area, which is part of the problem. However, a couple of good synoptic water level surveys were conducted recently. Mr. Gaynor stated that the plume is being redrawn using the newly calibrated model. He added that there is a slight seasonal fluctuation, to which Mr. Cambareri may have been referring.

Mr. Dow asked what COCs were identified in the original RI. Mr. Aker replied that many COCs were identified and he will provide Mr. Dow with the list.

Mr. Dow asked what kind of process is used to determine which COCs are incorporated in the risk assessment. Mr. Aker replied that it is a complicated process, but one that follows EPA standards and guidelines. Mr. Dow stated that he is concerned that contaminants that are just below the health advisory are not taken into account when determining the COCs. He said that he believes that risk assessments should consider the cumulative impact of the various chemicals that occur above background.

Agenda Item #4. Demo Area 1 Groundwater Draft Feasibility Study

Mr. Gregson stated that Demolition Area 1 is located south of the Central Impact Area. He explained that many activities, which include open burning, open detonation of munitions, and training activities with explosives, were conducted at Demo Area 1. Due to the intense activity in this small area, an RDX groundwater plume has been identified. The plume originates at Demo Area 1 and extends about a mile downgradient toward the west. He reported that an extensive investigation has occurred at Demo Area 1, and cleanup alternatives now are being identified and considered. Mr. Gregson stated that the FS for Demo Area 1 was distributed to IART members following the September meeting, and that he is hoping to get comments on the FS tonight. He then deferred to Mr. Applebee, one of the primary contractors working on the site.

Mr. Applebee reported that the COCs were identified in the final Demo 1 Groundwater Report, which was submitted in April 2001. The explosive COCs include RDX, Her Majesty’s Explosive (HMX), trinitrotoluene (TNT), 2A dinitrotoluene (2A-DNT), and 4A-DNT. Propellant-related COCs include 2,4-DNT and perchlorate. He said that the explosive compounds have been detected in the soil and the propellant-related compounds have been detected in the groundwater. Mr. Applebee explained that the next step, after obtaining approval on the COCs, is to identify technologies that could best be used to remediate the contamination at Demo Area 1. He noted that the FS contains a detailed evaluation of five remedial alternatives.

Mr. Applebee stated that Alternative 1 calls for "no action," which is a required alternative according to Administrative Order 1 (AO #1), and will serve as a comparison to the remaining four alternatives. He stated that Alternative 2 is referred to as "gradient control" and consists of a single extraction well located at the leading edge of the plume.

Mr. Hugus asked what is meant by gradient control. Mr. Applebee explained that gradient control refers to a single extraction well located at the leading edge of the plume, which is designed to capture the entire plume. It is called gradient control because the extraction well induces a slight gradient toward itself.

Mr. Schlesinger asked how a remediation method can be selected if the toe of the plume is unidentified. He also inquired about the cleanup goal for the investigation. Mr. Applebee stated that additional monitoring wells will be installed to assist in defining the toe of the plume. He noted that AO #3 requires that a range of cleanup goals be evaluated for each of the COCs, but basically requires that cleanup is evaluated to background or nondetectable concentrations. He added that the current design of these alternatives is to capture the entire plume and ultimately remediate to background, if possible.

Mr. Applebee referred to Alternative 2 again and further explained that after the water is extracted at the toe of the plume, it would be pumped back to a treatment building, where it would be treated by a two-step process. The first part of the treatment would involve biological reactors to treat perchlorate and the second part would involve granular activated carbon (GAC) to treat explosive compounds. He noted that each of the alternatives involve the same treatment process to remediate the groundwater once it is extracted from the ground.

Mr. Applebee explained that the treated water would then be pumped back to the Demo Area 1 depression and discharged via infiltration galleries there. He explained that Alternative 2 would flush any residual contamination that may remain in the deeper soils, which is not addressed as part of the soil operable unit.

Mr. Applebee stated that Alternatives 3 and 4 are similar to Alternative 2 in that they use a single extraction well at the toe of the plume; however Alternatives 3 and 4 also include in situ components to address areas of higher contaminant concentrations. Alternative 3 would oxidize the contaminants in place in the aquifer to help reduce contaminant concentrations in an attempt to reduce remediation timeframes. Alternative 4 would use in situ biological reduction to reduce the contaminants in the environment in place, similar to Alternative 3 except that it involves four injection points along the most concentrated areas of the plume.

Mr. Applebee stated that while Alternative 5 does not include any in situ components, it employs a more aggressive approach to capturing the contaminated groundwater at Demo 1 by the use of five extraction wells located down the center line of the plume and screened throughout the highest areas of contamination in the plume.

Mr. Schlesinger said that he is concerned about pumping water back into the Demo Area 1 depression, and asked if there are other options being considered. Mr. Applebee replied that the best reinjection approach is still under consideration. Options include injection wells along the edges of the plume, and infiltration galleries downgradient of the plume.

Mr. Applebee stated that the alternatives are all similar in the way they address extraction, treatment, and discharge of groundwater. The differences in the alternatives are generally found in remediation timeframes and the associated costs. He stated that Alternative 5 would meet the cleanup goals in approximately 10 to 20 years, whereas Alternatives 2, 3, and 4 would take 35 to 50 years.

Mr. Applebee stated that Alternative 1, the "no action" alternative, involves long-term monitoring and is estimated to cost around $3 million. He said that the costs for Alternative 2, which is a single well at the toe of the plume, and Alternative 5, which is five wells down the center line of the plume, are similar. He explained that the difference is that Alternative 5 includes operation and maintenance (O&M) for 35 to 50 years versus Alternative 2, which has higher capital costs. He noted that Alternatives 3 and 4, with the in situ treatment components, cost slightly more than Alternatives 2 and 5.

Mr. Gregson noted that at a previous meeting Ms. Dolen discussed the draft Decision Criteria Matrix (DCM). He reported that the Guard is working with EPA and DEP to finalize the document and will provide a presentation to the IART at its December meeting. He also noted that the draft Remedy Selection Plan will be distributed to the team in January 2002, and is scheduled to be finalized in April. The draft Decision Document and Responsiveness Summary (DD/RS) will be presented in July, and the final is scheduled to be available in October 2002, after which design and construction activities will commence.

Dr. Feigenbaum said that he thinks it would be useful if graphs of mass capture versus time for the different alternatives were available. Mr. Applebee noted that graphs are included in the FS. Dr. Feigenbaum stated that he thinks that common sense points to Alternative 5, which will get the job done in 10 to 20 years. He added that he believes that for years citizens have been trying to be consistent with the goal of maximum capture/minimum time.

Dr. Feigenbaum inquired about the treatment of the perchlorate. Mr. Applebee explained that the current proposal for treating the perchlorate is the use of a fluidized bed and bio-reactor, which is a technology that has been utilized at several other sites across the country to treat much higher concentrations and much higher flow volumes than are anticipated at Demo Area 1. He explained that this approach uses a media to support the biomass – typically a carbon or sand media, which is located within the reactor itself. The media is colonized with bacteria, which remediate the perchlorate.

Dr. Feigenbaum asked Mr. Gregson to name the daughter products of perchlorate. Mr. Gregson replied that perchlorate is made up of chlorine and oxygen. Dr. Feigenbaum expressed concern about the perchlorate degrading to bleach, which would kill any bio-media. Dr. Stahl explained that the perchlorate level is going to be low enough that there will be some toxicity to the microbe; however, it would not kill the whole reactor.

Mr. Hugus stated that he also is in favor of Alternative 5. He then referred to biological in situ treatment and asked if it means that bacteria are injected into the groundwater, rather than contained in an above-ground reactor. Mr. Applebee replied that Alternative 4 involves the injection of a material that induces conditions that allow the degradation of the RDX; however the effectiveness of the in situ treatment on perchlorate is limited. Although some treatability studies have shown some degradation or removal of perchlorate, he is not sure how effective it would be from a science standpoint.

Mr. Hugus asked if Mr. Applebee is saying that extracting and treating in a reactor is better than trying to treat in-place. Mr. Applebee concurred, and clarified that the in situ technologies are more inclined to address explosive contaminants and not perchlorate. He also mentioned that there is a project under way in Pueblo, Colorado that is effectively using in situ treatment on explosive compounds. Mr. Hugus requested more information on that project.

Mr. Kinney asked if the treatment goal for each alternative is the reduction of contaminants to background level or below the health advisory or maximum containment level (MCL). Mr. Applebee replied that the goal is treatment to background. However, that goal may not be possible; time, actual treatment, and evaluation will provide a better sense of how realistic the goal is. Mr. Kinney stated that none of the IRP plume treatments have obtained 100% mass capture, and he thinks that the citizens understand that may not be obtainable. He also said that he thinks Alternative 5 makes the most sense, if it will really capture the entire plume. Alternative 5 seems to incorporate some of the "hot spot" treatment that citizens have supported for years; that is, it will quickly address the high contaminant levels in the center of the plume, rather than waiting for it to reach the toe.

Ms. Pepin asked what bacteria would be used in the bioreactor. Mr. Applebee said that he does not know now, but will find out. Ms. Pepin asked if any bioreactors currently are in place on MMR. Mr. Applebee replied that he is not aware of any bioreactors in use on the base. Ms. Pepin asked how the integrity of a bioreactor would be maintained, and explained that she is concerned about a release of a large amount of bacteria into the groundwater. Mr. Applebee explained that the bioreactor treatment is followed up with a sand filtration, which would capture any of the biomass that comes off from the biological reactor prior to treatment by carbon.

Mr. Borci stated that he believes that the bacteria are already in the soils on-site. They would be inoculated into the bioreactor to provide a growth substrate. The bacteria do not have that growth substrate in the plume, and therefore cannot break down the contaminants to the extent that is desired.

Mr. Schlesinger stated that he thinks that the description regarding Alternative 1 should include the fact that the plume, if left unattended, would affect the Bourne wells’ zones of contribution. Therefore, the associated cost would likely be higher than what is noted, given that at least one of the Bourne wells would have to be relocated. He also said that he thinks Alternative 5 is the best alternative, providing it fits in with the fate and transport study. He further noted that only one form of reinjection is mentioned in the alternatives, and he thinks other options should be considered. Mr. Applebee concurred and stated that other options currently are being considered.

Mr. Dow asked what chemical would be used in the in situ oxidation alternative. Mr. Applebee replied that the treatability study looked at permanganate. Mr. Dow asked what method would more quickly remove the high concentration areas. Mr. Applebee replied that he believes that the evaluation indicated that an extraction well, in lieu of some in situ treatment technology, might be more effective in actually remediating the contaminants in groundwater more quickly. Mr. Dow said that it seems then that it would be quicker to extract and treat water rather than treat the "hot spots" with either microbes or permanganate. Mr. Applebee agreed and noted that the plume is dispersed and diluted, which means that it does not warrant "hot spot" treatment.

Mr. Dow asked if the high levels of lead and manganese in the groundwater would interfere with the fluidized bed reactor that would treat the perchlorate. Mr. Applebee replied that current evaluation indicates that it would not be a problem.

Mr. Dow stated that he is concerned that biological reduction would reduce the iron and manganese oxides in the soil particles in the groundwater and release some of the heavy metals. Mr. Applebee concurred that this could be a problem.

Dr. Stahl asked if the additional monitoring wells that will be installed to help identify the toe of the plume will be located near extraction well 1 (EW-1.) Mr. Applebee replied that the additional wells will initially be located in that area. The first well will be installed near EW-1 and data from that well will dictate where future wells are installed

Dr. Stahl noted that Alternative 2 consists of one extraction well and Alternative 5 consists of five extraction wells. He asked if a medium position has been considered that might take a little bit longer, but would require fewer wells. Mr. Applebee replied that the full range of possible scenarios has yet to be analyzed.

Ms. Hayes inquired about Mr. Applebee’s level of confidence in the timeframes for the remediation goals. Mr. Applebee said that the cost estimates are based on the most conservative end of the range. He added that he is not very confident about the cleanup timeframes because they are based on a number of assumptions that are built upon one another.

Mr. Hugus asked Mr. Applebee to identify the earliest point when treatment could start. Mr. Applebee replied that schedules are being discussed with the regulatory agencies. Mr. Hugus said that according to the schedule that was presented tonight, treatment would not start until 2003. He asked whether it is possible that a plan could be implemented to expedite the whole process.

Mr. Pinaud stated that the FS is still under review by DEP, and a comment letter will soon be issued. He noted that some good points were made this evening, which DEP will also consider. He also noted that DEP has some concerns that are both cost and ecologically based. For example, each of the alternatives consists of a piping run from EW-1 up to the source area; piping is an expensive part of the alternatives and the FS does not mention the conditions of the areas in question. He said that DEP is also concerned with discharging the water at the source area.

Mr. Borci stated that EPA also will be submitting comments on the FS this week. He also said that in general EPA is pleased with the range of alternatives.

Mr. Cambareri inquired about the total flow rate for Alternative 5. Mr. Applebee said that it is currently projected to be in the range of 150 gallons per minute (gpm). Mr. Cambareri commented that the flow rate is appreciably lower than IRP systems.

Dr. Feigenbaum asked if it is correct that water would be reinjected at the source area because it is the most efficient way to clean the source area. Mr. Applebee replied that it is. Dr. Feigenbaum said that an extraction well would be located near the source area, which would be immediately re-cleaning that same water. Mr. Applebee stated that Alternative 5 proposes an extraction well approximately 600 to 1000 feet downgradient. Dr. Feigenbaum asked then if RDX contamination would be dissolved and then picked up again 1000 feet downgradient. Mr. Applebee explained that dissolved RDX would be flushed in the pore water of the soil to the water table where it could be more quickly captured by the first well.

Dr. Feigenbaum referred to Alternative 2 and noted that it includes one extraction well at the toe of the plume, which would result in an endless process that sends water from the toe up to the source area where more RDX would be introduced. Mr. Applebee said that the FS suggests that the particulate source material at Demo 1 would be removed. He explained that the only residual contamination would be in the form of dissolved explosive contaminants in pore water within the soil. He said that there would not be a chunk of RDX at the surface that water would be continuously moving through.

Dr. Feigenbaum asked where the treatment plant will be located. Mr. Applebee replied that the thought is that the plant will be located in the cleared area in the G Range.

Ms. Hayes suggested that the IART consider either meeting more frequently or restructuring the time allotments for agenda items. Mr. Murphy said that he will bring these suggestions up at the next agenda-planning meeting.

Agenda Item #5. Small Arms Ranges Update

Mr. Gregson stated that current small arms firing using the 5.56 tungsten tin, plastic, and 50-caliber plastic is not contributing 2,4-DNT to the soil or groundwater at MMR. However, low levels of lead are being detected in some of those current propellants. He added that the Guard is proceeding with initial investigations, primarily focusing on lead and 2,4-DNT.

Mr. Gregson displayed a graph depicting the rounds that are currently used at MMR, which include the M-16, 5.56-mm plastic, M-16 tungsten tin, the squad assault weapon 5.56 tungsten tin, and the 50-caliber machinegun, which fires a plastic bullet. He added that some law enforcement training occurs at MMR, which utilizes a pistol round, which is a frangible round, and also a shotgun round that contains steel shot.

He explained that the columns on the left of the graph show information on the ranges that have been used over the past two years at MMR. He pointed out that the N, O, and P Ranges have not been used for the past two years, and these are the ranges that are located along Greenway Road.

Mr. Gregson stated that soil sampling and air monitoring was conducted at small arms ranges as part of the Phase IIb Investigation. The air monitoring occurred at the C and SE Ranges. He reported that neither explosives nor propellants were detected. However, antimony, copper, barium, zinc, and lead were detected in the downwind air monitoring samplers. Mr. Gregson stated that soil samples were collected in front of the firing lines immediately following a training firing event at G, I, and SE Ranges. Propellant-related compounds, such as 2,4-DNT and n-nitrosodiphenylamine, were detected in the samples at levels above screening criteria. He added that lead and antimony also were detected above screening criteria.

Mr. Gregson referred to the AEC report, which tested a wide range of rounds, and noted that it confirms the results that were detected in the air monitoring conducted on MMR. Specifically, the AEC did not detect explosives in propellants, but did find detections of metals, primarily lead.

Mr. Gregson then referred to the document titled "Propellant and Combustion Product Analyses on the M-16 Rifle and a 105-mm Caliber Gun," which pertains to a study conducted in 1985. He noted that this study focused only on air emissions, and the analysis did not detect 2,4-DNT in the emissions. However, the rounds used in the study do not match what is currently used on MMR. Specifically, the 1985 report did not test tungsten tin because it was not being used at that time. Mr. Gregson stated that the propellants are probably slightly different between the rounds that were used in 1985 and the rounds that are used now. He said that this study will serve as a historical framework for the compounds detected in the report and the history of the use of ranges at MMR.

Mr. Gregson stated that the propellants compound, 2,4-DNT, is not currently used in the rounds at MMR. This information can be found in the MIDAS database, a Department of Defense (DoD) publication that lists the components of munitions. Therefore the primary focus of the follow-up to the Phase IIb report will be determining the source of the 2,4-DNT, given that it is now known that it is not in the round before it is fired and it is not detected in the emissions. Mr. Gregson noted that the study will investigate previous rounds that were used on MMR, which were known to contain 2,4-DNT.

Mr. Gregson stated that next steps include the continued investigation under Phase IIb. He said that personnel from the IAGWSP and the regulators will be visiting the small arms ranges in order to develop the field sampling plan for additional sampling. He explained that the study will focus specifically on the propellants and metals, such as 2,4-DNT and lead. The study will include soil sampling at the firing points, in front of the firing points, and also at some of the backstop burns. He said that the idea is to conduct the study under a phased approach, which will allow the team to examine the results as the investigation continues to be refined.

Mr. Hugus stated that he thinks the historic perspective is important for two reasons – to understand how firing polluted in the past, and to provide a means of discovering how the new propellants pollute. He noted that the new propellant fact sheet indicates that the new propellants are comprised of 78% to 85% nitrocellulose. He said that he is pleased that DNT is no longer being used in the propellants, but he is concerned about the effects of nitrocellulose on the environment. Mr. Gregson stated that the compounds in the new propellants were not detected in the emissions testing in the soil in front of the firing ranges. Therefore, they are not at the same level of concern as the 2,4-DNT and the lead, which were detected at the small arms ranges at levels above remediation goals. He added that, based on the information he presented, it appears that the 2,4-DNT and lead may have came from past activities.

Mr. Hugus stated that he is concerned about the gases that were detected in the air monitoring conducted at the SE Range. He asked whether the new propellants will pose similar problems. Mr. Gregson replied that the levels of the compounds being emitted are very low, and a soil monitoring and maintenance program could be instituted. Mr. Hugus clarified that he is talking about the air monitoring results. He said that he is also concerned with compounds entering the lungs of the people how fire the weapons and the people who live in the nearby neighborhoods. Mr. Gregson stated that based on the MMR emissions results and the AEC testing, there is no risk to the community, given the distances of these ranges to the community. He added that the Guard currently is not using the Greenway Road ranges, which are closer to neighborhoods.

Mr. Schlesinger asked about the status of an ecological receptors study and whether such a study will take into account examining vegetative uptake of the heavy metals that are on the small arms ranges. Mr. Gregson replied that the ecological risk assessment uses the MCP as a framework and focuses on areas of contamination. He added that vegetation will be included in the assessment.

Mr. Kinney asked when more wells will be installed at the firing ranges to ensure that the findings are real. Mr. Gregson explained that additional groundwater investigations would be based on soil sampling results. He stated that the soil/groundwater connection will be carefully examined. Mr. Kinney noted that lead and DNT already have been detected at some of the small arms ranges and asked if there are plans in place to install wells in those areas. Mr. Gregson replied that there are no plans at this time, and noted that the limited number of wells that were allotted already have been installed. He stated that typically 2,4-DNT and lead migrate slowly to the groundwater.

Mr. Borci stated that an EPA comment on the Phase IIb Report pertains to a threshold regarding the limited number of wells in the small arms ranges; EPA requires that additional wells be installed if contamination is detected at the existing wells. He added that DEP and EPA are considering a proposal from the Guard, which is a revised Phase IIb Report that asks for wells to be installed at the five most-used ranges.

Mr. Borci stated that 2,4-DNT does not have to be detected in the groundwater in order to justify its removal from soil. He said that EPA has stated that it wants the Guard to start developing a delineation plan to determine the aerial extent of contamination at each of the gun positions; this would also apply to the small arms ranges.

Mr. Hugus stated that he noticed in the September 2001 monthly progress report that the groundwater sample from monitoring well 84D on Canal View Road had detections of 2,6-DNT, which were confirmed by photo-diode array (PDA) spectra. He noted that DNT also has been detected in the groundwater at Demo Area 1. Mr. Gregson confirmed that 2,4-DNT has been detected in Demo Area 1, which is one of the few, if not only, areas where it has been detected in groundwater. He said that he is continuing to monitor the status of the detections throughout the validation process and will keep the team updated.

Agenda Item # 6. Other Issues

N Range

Mr. Gregson reported that initially eight 81-mm mortars were discovered at the N Range, which is located in the southeast corner of the Impact Area. The mortars were located at a depth of about three-feet below grade and were marked as inert with dummy fuses. He said that the schonstedt survey identified the anomaly site as an area of about 20 feet by 25 feet in size. The area is located close to the Forestdale School. Subsequently, notification was conducted and engineering controls were constructed. He explained that the engineering controls consist of roll-off containers that are filled with sand, which would serve as a barrier if one of the mortars should happen to detonate.

Ms. Dolen stated that the Sandwich notification protocol was implemented. She explained that the IAGWSP and the Town of Sandwich agreed upon a protocol in October of 2000. She reported that the Town Administrator was notified, and that she presented the information at the Board of Selectmen’s meeting. The Forestdale School also was notified and 1100 notices were sent home with the school children. In addition, 140 notices were distributed door-to-door in the surrounding area. Ms. Dolen reported that if any mortars have to be blown in place, that would occur either on the weekend or after school hours.

Mr. Schlesinger remarked that he thinks that this discussion should have taken place at the beginning of the meeting because approximately 30% of the attendees have left already.

Mr. Gregson reported that removal actions were implemented following the notification protocol. As of today, 959 inert 81-mm mortars with inert fuses have been excavated, as has one inert 81-mm mortar with no fuse. He noted that many of the mortars had markings and lot numbers, which will help in determining the source of the rounds and who might have buried them.

Dr. Feigenbaum asked what is meant by an inert mortar. Mr. Gregson replied that the mortars did not contain any high explosive (HE). Dr. Feigenbaum remarked that he hopes that whoever buried the mortars will have to fund the disposal process. Mr. Gregson said that issue is being investigated.

Mr. Schlesinger said that he does not understand why the mortars were buried and why they didn’t contain any HE. COL Bleakley stated that it is possible that the mortars were used to test fuses, in which case HE would not have been used.


Mr. Hugus said that he is interested in obtaining the transcripts from the archive search report since the investigator resumed the process. He said that he is especially interested in interviewee #19 who has retained a lawyer and has refused to comment further.

Mr. Hugus also stated that he would like to see a copy of the J Range plume map that is being used internally at the IAGWSP. Mr. Gregson noted that a copy of that map will be forthcoming.

Mr. Hugus requested that the team be provided with information on the disposal area that was found near the BOMARC site. He also asked about the status of the Schooner Pass well. Mr. Gregson replied that that well is nondetect.

Agenda Item #7. Agenda Planning and Review Action Items

The action items and future agenda items were reviewed as follows:

Action Items:

  1. The Guard will provide the Impact Area Review Team (IART) with data from the Army Environmental Emissions Center (AEC) Report regarding 50-caliber lead bullet rounds, as well as other rounds, which may have been used in the past at the Massachusetts Military Reservation (MMR).

  2. The Guard will send Mr. Cambareri a copy of the pump and test proposal and plan as well as the memorandum of resolution.

  3. Mr. Hugus requested a cross-sectional map of Chemical Spill 19 (CS-19).

  4. Mr. Aker will provide Mr. Dow with a list of contaminants of concern listed in the November 2000 CS-19 Remedial Investigation (RI).

  5. Ms. Pepin requested the identification of the bacterium that would be utilized in several of the alternatives proposed for Demolition Area 1.

  6. The Guard will provide the team with information regarding nitrocellulose and its effect on the environment.

  7. The Guard will keep the team updated on the validation status of 2,4-dinitrotoluene (DNT) and 2,6-DNT detected in monitoring well 84 (MW-84).

  8. Mr. Hugus requested transcripts from the interviews conducted for the archive search report since interviewing has resumed. He expressed particular interest in interviewee #19.

Status of Action Items

Future Agenda Items:

  • Meeting frequency/agenda times

  • The addition of "Late Breaking News" item to the agenda

  • J Range plume map

Agenda Item #8. Adjourn

Mr. Murphy stated that the next IART meeting is scheduled for Tuesday, December 4, 2001 at 6:00 p.m. at the Quashnet Valley Country Club in Mashpee. He thanked everyone for attending and adjourned the meeting at 9:36 p.m.

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