Area Review Team
The American Legion
October 23, 2001
6:00 p.m. – 9:30 p.m.
Distributed at Meeting:
- October 23,
2001 Draft Meeting Agenda
25, 2001 Draft Action Items
25, 2001 Draft Meeting Summary
to Action Items from September 25, 2001 IART meeting
- Small Arms
Propellant Composition from MIDAS Database – IAGWSP
Values and Standards for Detected Compounds in Soil
- Map: Impact
Area RDX Source and Detection Areas with AirMag Signal and Targets
- MMR Buried
Combustion Product Analyses on an M16 Rifle and a 105mm Caliber
handout: Demo 1 Groundwater FS Report
handout: Small Arms Ranges
handout: CS-19 Supplemental Remedial Investigation Update
- Impact Area
Groundwater Study Update – October 2001
Item #1. Welcome, Brief Overview of the Impact Area Review Team,
Approval of September
25, 2001 Meeting Minutes, Review Draft Agenda
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
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.
team members introduced themselves.
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."
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.
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.
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.
Cambareri agreed that it would be beneficial to have an overall
update, as the material is sometimes difficult to fully comprehend.
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.
Item #2. Review Action Items
Murphy reviewed the action items from the September 25, 2001 IART
Guard will respond to Mr. Cambareri’s question about quartz filter
analysis regarding the AEC report.
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: www.epa.gov/ttn/amtic.
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.
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.
in the AEC report, Mr. Gregson will distribute data from 50-caliber
machineguns using plastic ammunition.
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.
Guard will provide the "Fate and Transport" laboratory
study report to the Massachusetts Institute of Technology (MIT)
representatives involved with the IART.
Murphy stated that this report will be mailed to the MIT representatives
when it becomes available in November 2001.
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.
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
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
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.
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.
Item # 3. Chemical Spill 19 Update
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.
Aker displayed a map depicting the MMR. He pointed out CS-19, which
is a Royal Demolition Explosive (RDX) plume.
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.
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.
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.
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.
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.
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.
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
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
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.
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.
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
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.
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.
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.
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.
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.
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.
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.
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
Item #4. Demo Area 1 Groundwater Draft Feasibility Study
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.
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.
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.
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.
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.
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
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.
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.
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.
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.
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.
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
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
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.
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.
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
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.
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.
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.
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.
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.
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.
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.
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.
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.
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
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.
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.
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.
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.
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.
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.
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.
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.
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.
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
Item #5. Small Arms Ranges Update
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.
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
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
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.
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.
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.
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.
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.
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.
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.
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.
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
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
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.
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.
Item # 6. Other Issues
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
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.
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.
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.
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
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.
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.
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.
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.
Item #7. Agenda Planning and Review Action Items
action items and future agenda items were reviewed as follows:
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
will send Mr. Cambareri a copy of the pump and test proposal and
plan as well as the memorandum of resolution.
requested a cross-sectional map of Chemical Spill 19 (CS-19).
will provide Mr. Dow with a list of contaminants of concern listed
in the November 2000 CS-19 Remedial Investigation (RI).
requested the identification of the bacterium that would be utilized
in several of the alternatives proposed for Demolition Area 1.
will provide the team with information regarding nitrocellulose
and its effect on the environment.
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).
requested transcripts from the interviews conducted for the archive
search report since interviewing has resumed. He expressed particular
interest in interviewee #19.
of Action Items
Item #8. Adjourn
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.