Impact Area Review Team
Future Agenda Items:
Perchlorate Testing at BOMARC/CS-10
Agenda Item #1. Welcome, Approval of June 25, 2002 IART Meeting Minutes, Review Draft Agenda
Mr. Murphy convened the meeting at 6:03 p.m. and asked the IART members to introduce themselves. It was noted that Dr. Dahmani and Mr. Hood are new Technical Outreach Services for Communities (TOSC) advisors to the IART.
Mr. Murphy asked if there were any changes or
additions to the June 25, 2002 IART meeting minutes. No changes were
recommended and the minutes were approved as written. Mr. Murphy
then reviewed the meeting agenda and noted that prospective IART
member Bob Mullenix would be introducing himself to the team later
in the meeting.
Mr. Murphy asked if there were any comments on the responses to action items from the June 25, 2002 IART meeting.
Mr. Hugus referred to action item #3 and asked if itís been determined whether or not perchlorate was a component of fuel used at the Boeing Michigan Aeronautical Research Center (BOMARC) site on the base. Mr. Gregson replied that this question has been researched and the indication is that solid rocket propellant, which was used before the switch to liquid propellant, did contain perchlorate. Mr. Hugus asked whether Mr. Gregson knows anything about disposal practices associated with the solid propellant. Mr. Gregson replied that he does not, but noted that this type information is being sought through the archive search process. He also said that so far thereís been nothing that indicates disposal at the Massachusetts Military Reservation (MMR) of perchlorate or any fuel from the BOMARC site. Mr. Hugus recommended that the topic of perchlorate testing at CS-10 wells be added to the next meeting agenda. Mr. Gregson agreed with the recommendation. Mr. Hugus also mentioned that the CS-10 wells were installed under the IRP.
Dr. Feigenbaum stated that heís quite certain
that the Task 6 Report contains information that there was a regular
protocol for disposal of hydrazine at the site. He noted that
hydrazine was a component of the liquid propellant. He also asked if
it was definitively determined that a type of BOMARC missile that
used liquid propellant was followed by one that used solid
propellant. Mr. Gregson confirmed that this was determined.
Agenda Item #3. Introduction of Prospective IART Member
Mr. Mullenix, a resident of Bourne who had expressed interest in joining the IART, stated that he was born and raised in Cambridge, Massachusetts, received a Bachelor of Science degree in chemical engineering from the University of Florida, worked as an engineer for about 15 years, received a Masters degree in environmental engineering with a specialty in water resources engineering from the University of North Carolina in Chapel Hill, and about 10 years ago, at the age of 40, moved to Bourne, where he quickly became interested in activities at the base. He also noted that heís particularly interested in the recent perchlorate issue in Bourne as he works in the environmental field and has some experience with perchlorate issues in the western part of the country.
Mr. Mullenix stated that he wants to join the IART as a public service to the community. He said that he has studied the subject matter, he works in the environmental field, he lives in Bourne, and he would like to be part of the effort to bring the cleanup to a successful conclusion.
Ms. Pepin inquired about Mr. Mullenixís current employment. Mr. Mullenix replied that he works in the environmental affairs department of a large private corporation in Massachusetts. Mr. Hugus asked whether Mr. Mullenixís work is connected to the base, and if he would identify the name of his company. Mr. Mullenix replied that his company is not affiliated with the base at all. He also said that he would rather not say the name of his company because he doesnít think it would be appropriate to do so in this forum.
Dr. Feigenbaum asked whether Mr. Mullenixís company had ever been subject to regulatory process by EPA Region 1. Mr. Mullenix replied that he believes that it had, in the 1980s, prior to his joining the company. Mr. Walsh-Rogalski asked whether the company is a defense contractor. Mr. Mullenix replied that it is not.
Mr. Murphy asked that IART members submit their
comments or recommendations regarding Mr. Mullenixís prospective
membership to him by Friday, September 6, 2002. He said that he
would then forward those comments to EPAís regional administrator,
who would make a decision regarding Mr. Mullenixís appointment to
Agenda Item #4. Investigations Update
Update on Perchlorate Investigation at Monument Beach Wellfield
Mr. Gregson showed a map, pointed out Route 28 and water supply wells 1, 4, 3, and 6, and reported that thereís a continued pattern of perchlorate detections of less than 1 ppb in the Monument Beach wellfield area. He also pointed to a far-field well, located along the base boundary, and noted that thereís a continued perchlorate detection there at greater than 1 ppb. In addition, he reported that perchlorate detections occurred for the first time in wells 02-12 and 02-15, and in the middle screen of far-field well MW-81 Ė all at levels less than 1 ppb. Mr. Gregson noted that 1 ppb is the drinking water advice level that the Massachusetts Department of Environmental Protection (DEP) provided specifically for the Bourne Water District.
Mr. Gregson reported that MW-226, which is located 1000 feet upgradient of MW-80, was recently completed. Profile results showed perchlorate detections up to 3 ppb, while the first actual sample came back with a 1.3 ppb perchlorate detection in the middle screen. At MW-216, which is located about 4000 feet upgradient of MW-226, near Range Control, perchlorate was detected in the shallow water table screen at a concentration of about 0.7 ppb. This is significant because a detection at the water table is indicative of a nearby source.
Dr. Dahmani asked for the Groundwater Study Programís definition of "profile" samples. Mr. Gregson explained that profile sampling refers to the process of taking samples at 10-foot intervals during the drilling process in order to collect data thatís critical in selecting permanent well screen locations.
Mr. Gregson then stated that to date the Groundwater Study Program has installed 19 monitoring wells in and upgradient of the Monument Beach wellfield, collected soil samples, and done some detailed groundwater modeling, which is in the process of being completed. Based on information thatís available at this time, three new monitoring well locations are being proposed Ė two upgradient of wells MW-226, MW-80, and MW-213, and another upgradient of MW-216. Decisions on whether or not to install the contingency wells, which also are depicted on the map, will be made based on whatís found in the three new wells.
Mr. Gregson also mentioned that another new well is proposed to be located between Bourne production well #1, which currently is operating, and MW-213, where there have been sporadic perchlorate detections at less than 1 ppb. He further noted that 22 soil sampling locations have been identified, including gun position 2 (GP-2), GP-24, and some of the mortar positions on the southwestern edge of the Impact Area.
Mr. Gregson stated that the Groundwater Study Program also is in the middle of conducting a site-wide perchlorate characterization program. The wells were prioritized, and sampling of the first group, which consists of 80 well screens upgradient of Bourne, at the base perimeter, or within zones of contribution for drinking water wells, is very near completion. Sampling results from this group are expected to be available in two weeks, with validated results available in six weeks. The second group consists of about 100 well screens in the Central Impact Area and other potential source areas. Mr. Gregson stated that based on what is found, future actions will include particle tracking from known detections to identify potential source areas, and other response actions as necessary. He noted that data from the site-wide perchlorate characterization would be presented in a report due to be released at the end of October 2002.
Mr. Schlesinger asked whether MW-47 and MW-214, for which it was noted on a previous map that no data were available, have since been sampled for perchlorate. Mr. Gregson replied that he would have to check and report back to the team on this question. He also said that if they havenít been sampled, itís probably because the screen intervals are not appropriate to be of use.
Mr. Schlesinger also asked that the Groundwater Study Program revise the Impact Area perchlorate detection map to include the Monument Beach wellfield area and the perchlorate detections there. Mr. Gregson replied that it would make sense to do that.
Mr. Hugus asked if itís correct that the purpose of conducting soil sampling at the mortar range area is to look for a source of the perchlorate there. Mr. Gregson replied that that is correct and noted that the soil sampling thatís already been conducted has yielded a few perchlorate detections. Mr. Hugus asked if a source area has been pinned down yet. Mr. Gregson replied that right now it is too early to tell. Mr. Hugus also inquired about the estimated 30-year time period that it took for perchlorate to reach the area in Bourne. Mr. Gregson acknowledged that a 30- to 40-year period was estimated as the amount of time it takes "for the particle tracks to make their course from a potential source area." He also noted, however, that with respect to looking for sources, the location where the particle tracks end at the water table is more helpful, along with information on historic uses and so forth.
Mr. Hugus asked if there are enough data to draw a plume contour for the perchlorate contamination. Mr. Gregson replied that he expects this type of activity to occur soon, after all the validated results from the first round of sampling are available. He also noted that the current focus is on groundwater modeling and particle tracking in order to find the source and determine whether thereís an area of significantly higher perchlorate contamination upgradient of the wells at the base boundary. Mr. Hugus said that he would urge the Groundwater Study Program to draw a plume contour so the IART would have a graphic representation of the perchlorate contamination.
Mr. Hugus also inquired about perchlorate testing of water distributed to Bourne residents. Mr. Gregson replied that the six sampling points within the Bourne water distribution system were tested and came back nondetect for perchlorate. Mr. Hugus said that he thinks that 2,6-dinitrotoluene (2,6-DNT) was detected in one of those samples. Mr. Gregson clarified that that detection turned out to be a false positive.
Mr. Hugus then asked about the goal of the Monument Beach investigation and the status of Bourneís water supply. Mr. Gregson stated that supply well #1 is the only production well currently operating in the Monument Beach wellfield. However, with the pipeline in place to the Upper Cape Water Cooperative system and the connection to the Sagamore Water District, itís likely that the Bourne Water District will have enough capacity to meet its demand through the fall, winter, and spring. He also stated that the investigation is focused on the nature and extent of contamination upgradient of the wellfield. He further noted that the Groundwater Study Program continues to work with the Bourne Water District to identify any emergency situations that might arise with existing wells and to determine whether thereís an opportunity to turn on a well on that was previously shut off. Mr. Hugus inquired about sampling results from sentry wells upgradient of supply well #1. Mr. Gregson replied that perchlorate detections continue to be seen in wells immediately upgradient, such as wells 02-04, 97-3, and 00-7.
Ms. Pepin requested that the Groundwater Study Program office provide the team with copies of the map that show all wells that have been tested for perchlorate. Mr. Schlesinger confirmed that the map to which Ms. Pepin is referring includes the eastern side of the base. Mr. Gregson agreed to provide an updated copy of this map.
Dr. Dahmani asked whether the MODFLOW program was being used to do the modeling. Mr. Abate of AMEC confirmed that MODFLOW is being used for the flow modeling. Dr. Dahmani asked if pump tests were conducted for input data into the MODFLOW model. Mr. Gregson replied that the data that were used are from pump tests conducted by the Bourne Water District as part of its wellfield development. Dr. Dahmani asked whether the pump tests were conducted at different depths. Mr. Gregson replied that he doesnít know.
Dr. Dahmani also inquired about the dispersion coefficients used in the model. Mr. Abate replied that MODFLOW does not simulate contaminant mass transport, so there is no dispersion, just flow. Dr. Dahmani asked if monitoring wells would be installed to calibrate the model. Mr. Gregson said that data from the 19 wells that were installed as part of the investigation are used to calibrate and update the model. Dr. Dahmani questioned whether there are enough monitoring wells, appropriately located, to calibrate the model properly. Mr. Abate noted that thereís a far greater concentration of monitoring wells in the Monument Beach wellfield area than anywhere else on MMR and he believes that those data provide a good understanding of the water table configuration. He also said that while there are some clusters of wells and some data gaps, one reason for the modeling is to integrate between those. Dr. Dahmani said that he would suppose that the proposed monitoring wells would address some of the data gaps. Mr. Gregson agreed that they would.
Dr. Dahmani then asked about the possibility of having a three-dimensional visualization of the perchlorate contamination. Mr. Gregson stated that cross-sections, which show the relative depths of the contamination in the third dimension, have been shown during previous briefings and could be shown again at future IART meetings.
Dr. Dahmani inquired about the level of data validation thatís being done. Mr. Gregson replied that AMEC does the data validation, and a certain percentage undergoes the highest level of validation, while other data undergo lower levels of validation. He also said that he would provide the team with specific information about data validation levels.
Dr. Feigenbaum asked how much of the 4.5 million gallons per day (mgd) that the Upper Cape Water Cooperative system is permitted to pump is being used to cover the shortfall in Bourne. Mr. Gregson replied that Bourne is using between 1 to 2 mgd. He also said that he believes that Falmouth just hooked up to the system and is taking 1.5 mgd. Dr. Feigenbaum asked whether the system is exceeding 4.5 mgd. Mr. Gregson replied that it is not.
Dr. Feigenbaum then stated that he recalls Mr. Gregson saying that by the end of this summer there would be some information about another production well as part of the Upper Cape Water Cooperative system. Mr. Gregson indicated that he didnít have a clear recollection of having said that. Ms. Hayes said that she doesnít remember Mr. Gregson making that statement. Dr. Feigenbaum explained that it had occurred during a private conversation.
Mr. Gregson said that he couldnít comment on any plans for additional Upper Cape Water Cooperative production wells. He did note, however, that his office is working with the Bourne Water District in exploring other options to increase the districtís production and decrease its dependence on the 4.5 mgd system Ė one option, for example, being water supply well site 4 (WS-4).
Dr. Feigenbaum remarked that he thinks itís only reasonable for the public to demand that the Army come up with at least one more production well, especially since the Bourne Water District is using almost half of the 4.5 mgd that the Upper Cape Water Cooperative productions wells are permitted to produce. Mr. Gregson replied that he could forward this comment on to the people who make these kinds of decisions. Dr. Feigenbaum asked that this be noted as an action item.
Mr. Pinaud commented that while itís correct that the Bourne Water District was able to meet its demand through the summer by connecting to the Upper Cape Water Cooperative system, it might be that less water from the system is available to Bourne next summer. Therefore itís very important to determine the source of the perchlorate contamination by next spring at the latest, and ensure that Bourne has clean water to distribute.
Mr. Cambareri stated that he thinks itís important to evaluate whether perchlorate has gone beyond the Monument Beach wellfield, and he recommends that the Groundwater Study Program address this concern as part of its investigation. He said that the program seems to be looking at the Monument Beach wells as the endpoint, but heís not convinced that they are.
Ms. Crocker asked, "What is a plume as far as the public is concerned?" She said that she thinks itís important not to scare the public, and if the area of contamination at the Monument Beach wellfield is going to be named a plume, there ought to be an adequate rationale that takes into consideration and makes known to the public "the frequency, the proximity, and the strength of toxicity of each sampling." She questioned whether now is an appropriate time to draw a plume at the Monument Beach wellfield area.
Mr. Gregson replied that now is not thought to be an appropriate time because of the lack of historical information. He also noted that one criterion for defining a plume is repeated detections that are consistent over time. In the case at hand, however, some monitoring wells are nondetect for a period of time, then have a detection just above the method detection limit (MDL) of 0.35 ppb, and then drop down to nondetect again for a couple of sampling rounds. It is not clear how that type of situation fits into the definition of a plume. Mr. Gregson said that this is the type of question that will be considered during technical meeting discussions about how to depict the perchlorate in the Monument Beach wellfield area.
Ms. Crocker asked that when the perchlorate plume is drawn, the Groundwater Study Program office not the scare the public, but let the community know that there are other places in the country with much higher perchlorate concentrations than those being seen at the Monument Beach wellfield.
Mr. Dow said that a woman who lives in the village of Pocasset in Bourne told him that her water tastes different, in a negative sense, now that itís coming from the Upper Cape Water Cooperative system rather than the Monument Beach wellfield. He then asked Mr. Gregson to explain the difference in water chemistry between the two sources. Mr. Gregson replied that offhand he doesnít know anything about the difference in water chemistry at the two sites. He also noted, however that this information is available and could be provided. Mr. Dow said that he would appreciate it if Mr. Gregson would look into an answer to his question.
Mr. Judge commented that itís fortunate that Hap Gonser, who headed up the Upper Cape Water Supply project, saw to it that the Bourne Water District was hooked up to the system very quickly, and itís fortunate that Mr. Gonser built a system capable of pumping up to 6 mgd. Mr. Judge stated that the challenge is the supply, and as a citizen of Sandwich heís particularly concerned about potential effects of drawdown on the Shawme Ponds and the artesian well in downtown Sandwich, where, he said, the water pressure appears to be dropping. He stated that although heís been told that it would take years to witness that kind of response to pumping at the Upper Cape Water Cooperative system, heís also heard that it depends on the moraine and the water table in that area. Mr. Judge said that he thinks that if the system were pumping 6 mgd, it would cause problems for Sandwich, and it still would not be enough to compensate for the perchlorate issue in Bourne.
Mr. Judge also referred to Ms. Crockerís comments and said that in his opinion to have knowledge is not scary, but to find out after the fact that heíd been drinking contaminated water would be scary. With respect to identifying a plume, Mr. Judge said that he thinks the public should be informed of every bit of information thatís available, as well as how that information was obtained, and its degree of accuracy.
Mr. Mullenix noted that perchlorate concentrations seen in the Monument Beach wellfield area have been less than DEPís stated cleanup standard of 1 ppb. He also noted that the California Department of Health Services recognizes an MDL of 4 ppb for perchlorate, while the Groundwater Study Program is using an MDL of 0.35 ppb. He then asked how many laboratories in the country are qualified to report an MDL of 0.35 ppb, and whether anyone within the cleanup program is monitoring quality control at its laboratories.
Mr. Gregson stated that the Groundwater Study Program sends its samples to two laboratories that use an MDL of 0.35 ppb and a reporting limit of 1 ppb for perchlorate. He noted that EPA and DEP have worked with the program to do quality control checks on these laboratories and ensure that theyíre providing usable data. He also said that although he doesnít know for certain, there might be other laboratories starting to use similar methods. Mr. Borci added that the laboratories doing the analytical work for perchlorate have received more scrutiny by EPA than is typical. He also said that the laboratories were asked to lower the MDL from 0.5 ppb to 0.35 ppb, which was not that significant a task for them to do. He then mentioned the perchlorate problem near Aberdeen Proving Grounds and said that theyíll be "looking at a level of around 1.1 ppb." Mr. Borci said that heís certain that other laboratories will soon be or already are detecting down to about the same levels as those seen in the Monument Beach wellfield.
Mr. Pinaud clarified that 1 ppb is not a DEP standard for perchlorate in drinking water. Rather, itís the drinking water advice that DEP provided to the Bourne Water District with respect to risk management for its water supply.
Ms. Dolen said that she thought the team would be interested in knowing that eight homeowners west or north of the Monument Beach wellfield responded to the Groundwater Study Programís offer to sample their residential wells, and all of those wells tested nondetect for perchlorate. Mr. Cambareri replied that he thinks thatís great. He also noted, however, that shallow wells typically are above contaminated areas. Therefore, he would again stress that he thinks the Groundwater Study Program should consider installing a downgradient monitoring well, on County Road.
Mr. Walsh-Rogalski stated that he appreciates that Mr. Gregson has agreed to take a look at the status of further development of Upper Cape Water Supply wells. He also requested, however, that someone from the Department of Defense (DoD) Ė perhaps LTC Rogers Ė come to the next IART meeting to report on the promise "to make the Cape whole," what that means, and how it relates to the question of developing additional water supplies as more and more contamination is found.
Mr. Gregson said that he seems to recall that this very question was addressed a few months ago in a written response to an action item. Mr. Walsh-Rogalski said that he remembers that a response was developed but never delivered to the team. Mr. Murphy stated that he thinks a response was handed out at an IART meeting, but he would have to check to be sure. Mr. Walsh-Rogalski said that he wants to be certain that the need to develop additional water supplies is addressed, "because thatís what itís going to come down to."
Mr. Cambareri remarked that he thinks itís critical to remember that without the far-field wells, which were installed under this program to evaluate contamination on MMR, it wouldnít have been possible to fast-track the supply wells in the northeast corner. Therefore he thinks that the Groundwater Study Program could "make good" by evaluating groundwater in and emanating from the remainder of the base, including the northwest corner, which is still somewhat uncharted and might have clean water.
Ms. Hayes commented that she thinks itís a strong point of order that information should be shared among all team members in order to make them all knowledgeable, and that references to conversations among individuals be identified as such. She also asked whether the local communities have expressed any anxiety about not receiving enough water.
Ms. Dolen replied that any concern or confusion
expressed by Bourne residents at "Open House" events held
by the Groundwater Study Program office has pertained to the
quality, rather than the quantity, of the water. She also said that
despite media coverage of the perchlorate situation in Bourne, her
office hasnít heard a major outcry from the public
In response to Ms. Hayesís inquiry about community response to the perchlorate issue in Bourne, Ms. Grillo stated that she has received a couple phone calls from potential homebuyers and others who have read articles in the Cape Cod Times. She said that when she spoke to these callers she explained DEPís drinking water advice for Bourne. She also said that she doesnít hear a lot of people voicing concern, "but there is concern out there."
Mr. Judge remarked that the various citizen teams associated with the base cleanup, the regulatory agencies, and the military organizations deserve a pat on the back for having had the foresight to recognize and address a future problem by building the Upper Cape Water Cooperative system. Otherwise, there would be a major public outcry at this time, given the perchlorate situation in Bourne. Mr. Judge also said that he thinks that thereís an obvious need to request more water for Cape Cod, enough to "make the area whole." He said that he is looking forward to the 10 mgd.
Dr. Feigenbaum said that he agrees that more water for the Upper Cape is needed and he wonders whether EPA has authority under the Safe Drinking Water Act (SDWA) to issue an order that requires the Army to provide that water. He also said that he think that Upper Cape residents definitely are concerned about their water, and most buy bottled water for drinking. He noted that heís often questioned about the safety of the water and for years has been receiving calls about whether or not itís safe to buy a home in certain areas of the Upper Cape. Dr. Feigenbaum further stated that people understand that thereís an ongoing response to their concerns, but they would be "up in arms" the moment that they no longer had that impression.
Demolition Area 1 Recent Detections
Mr. Gregson stated that the Groundwater Study Program is continuing its investigation to define the downgradient extent of the contamination emanating from Demolition Area 1. He showed a map of the area, pointed out the perchlorate and RDX contamination contours, and reported that perchlorate was detected recently in MW-210 at 12 ppb, in MW-211 at 3 ppb, and in MW-173 at less than 1.5 ppb, which is EPAís relevant standard for perchlorate at MMR. He also noted that MW-175 tested nondetect for perchlorate, as did MW-221, while profile results from MW-231 showed perchlorate detections ranging from 0.46 to 0.64 ppb.
Mr. Gregson said that based on an unvalidated perchlorate detection of 2.9 ppb at MW-225, unexploded ordnance (UXO) clearance is ongoing at the location where well D1P-15 will be drilled. Depending on results from D1P-15, the plan is to drill another monitoring well about 600 feet to the west of where the plume toe is mapped currently and obtain information that defines the downgradient extent of perchlorate.
Mr. Gregson stated that the Groundwater Study Program office is in the process of putting together a Rapid Response Action (RRA)/Release Abatement Measure (RAM) plan at Demolition Area 1. A detailed schedule will be part of that plan, but the conceptual schedule is to do modeling and planning work this fall and winter and begin construction in the spring/summer construction season. He noted that there would be two response actions: soil removal at the Demolition Area 1 source area and the installation of a groundwater pump-and-treat system to address the Demolition Area 1 plume. He also said that both actions are on similar schedules.
Mr. Hugus questioned whether the power line west of the current plume outline would be a good location for capturing the toe of the plume. Mr. Gregson replied that that would depend on data from monitoring wells whose locations are contingent upon whatís seen at well D1P-15. He also noted that initial reconnaissance of that area is being conducted to find potential well locations. Mr. Hugus said that data from D1P-15 would provide information about the northern boundary of the plume, not the western boundary, which is a higher priority in terms of capturing the plume at its toe. Mr. Gregson said that a high detection of perchlorate at D1P-15, such as 13.5 ppb, would influence a decision to install a well farther to the north, while a nondetect there would mean installing a well farther to the south.
Mr. Hugus remarked that it seems that progress at Demolition Area 1 is moving very slowly. He noted, for example, that Mr. Gregson had mentioned that construction wonít begin until the spring/summer construction season, which is a year away, and he wonders why construction couldnít begin this year, during the fall/winter construction season. Mr. Gregson explained that a great deal of planning, modeling, and other activities have to be done before construction begins, although an effort is being made to move forward as quickly as possible.
Mr. Hugus stated that the RRA is not supposed to be the final answer on Demolition Area 1. He also commented, however, that there isnít enough available information on which to base a response action. He said that he doesnít think enough progress is being made, and that resources equivalent to those being put into the Monument Beach wellfield area should also be put into the Demolition Area 1 plume. Mr. Gregson clarified that the plan is not to define the toe of the plume before planning and designing the RRA. Those activities are occurring now and defining the toe is "just a piece of the puzzle as to what that ultimate plan will look like."
Dr. Dahmani asked whether the Demolition Area 1 plume delineation is based on detections at different depths. Mr. Gregson replied that it is, and noted that itís a relatively simple plume in that it has a single source area and is fairly well defined both in plan view and cross-section. Dr. Dahmani also asked about the degree of confidence in the unvalidated data. Mr. Gregson clarified that all data become validated, although there are varying validation levels.
Dr. Feigenbaum questioned whether the perchlorate contour lines shown on the map were drawn based on MW-173ís perchlorate detection of less than 1.5 ppb and MW-175ís nondetect result. Mr. Gregson replied that thatís correct. Dr. Feigenbaum suggested that a very large area of the plume was defined based on just those two wells. Mr. Gregson noted that data are also available from MW-211 and MW-231. Dr. Feigenbaum commented that the map seems to indicate that the leading edge of the perchlorate contamination is defined, when in fact that is not the case. Mr. Gregson noted that the perchlorate contour lines are dashed, not solid lines.
Dr. Feigenbaum also said that he thinks that nondetect contour lines on a map provide some additional measure of information "about how secure the plume boundaries are." He noted that the IRP refuses to draw the nondetect contour on its maps. He also asked when more wells would be installed in the leading edge area of the Demolition Area 1 plume. Mr. Gregson replied that data from well D1P-15, which is going to be drilled as soon as possible, could be available by the next IART meeting. Subsequent wells will be drilled based on data from D1P-15.
Dr. Dahmani suggested that in addition to noting the contaminant concentration, future maps should also note the depth at which a sample was taken. Mr. Gregson acknowledged this suggestion and noted that he would also see to it that cross-section figures are available at the next IART meeting.
Central Impact Area Recent Detections
Mr. Gregson showed a map depicting recent detections in the Central Impact Area, pointed out the RDX plume contour lines, and noted that perchlorate was detected recently at several locations at 1 ppb or less. He also reported that recent RDX detections include a concentration of 2.7 ppb at MW-206M1 and a concentration of 1.75 ppb at MW-223. He noted that the health advisory for RDX is 2 ppb.
Mr. Gregson then pointed out an area of contamination that was "connected up with the main area of contamination" in the current version of the map. He also noted that some changes were made to the CS-19 plume shell based on information that that the Air Force Center for Environmental Excellence (AFCEE) acquired through its remedial investigation process.
Mr. Schlesinger asked for confirmation that the darkest contours on the map represent RDX detections greater than 10 ppb. Mr. Gregson confirmed that they do. He also pointed out that the perchlorate detections at MW-10 and MW-15 are outside the RDX area of contamination, and noted that the Groundwater Study Program currently is acquiring data on perchlorate in that area to determine its extent and whether it matches up with the RDX contamination.
Mr. Schlesinger also said that he thinks that the map is incorrect in that MW-99 and MW-98 should have been included in the 2 to 10 ppb contour. Mr. Gregson agreed to find out whether those wells should in fact be included in that contour.
Dr. Dahmani asked whether the contours were drawn by hand. Mr. Gregson replied that they were. He also noted that the pattern of contamination at the Central Impact Area is much more complicated than that at Demolition Area 1. The Central Impact Area contamination may or may not be connected between wells and there are multiple source areas and multiple fingers of contamination. Dr. Dahmani questioned whether the Central Impact Area map was based on one round or on multiple rounds of sampling. Mr. Gregson replied that itís based on multiple rounds and shows the highest concentrations detected.
Ms. Crocker said that she would like to submit a letter sheíd written, to be distributed with the minutes from this meeting. She noted that the letter has to do with the "backyard excavations" that previously occurred in Sandwich and caused "a lot of scariness" in that town. Mr. Murphy stated that the topic of submitting letters and other documents and distributing them to the team would be discussed later in the meeting.
Southeast Ranges Recent Detections
Mr. Gregson stated that investigations are continuing in the Southeast Ranges, which are also known as the J Ranges. He displayed a figure that shows the J-2 Range and pointed out MW-215, which was drilled upgradient of MW-57, where perchloroethylene (PCE) had been detected previously. He reported that PCE was not detected at MW-215, although RDX was detected at 2.09 ppb and High Melting Explosive (HMX) was detected at 0.83 ppb. He also pointed out MW-228, where profile results showed detections of RDX, HMX, and 2,6-DNT, with the RDX concentration above the health advisory. Mr. Gregson then stated that profile results from three wells downgradient of Polygon 2 showed detections of a number of different explosives, including perchlorate, trinitrotoluene (TNT), RDX, HMX, 2,6-DNT, and nitroglycerin. He said that heís quite sure that all of the detections were below their respective health advisories, although heís not certain that this is true of nitroglycerin.
Mr. Gregson then displayed a figure that shows RDX detections in the southern part of the J Ranges and pointed out the J-2 Range, the J-1 Range, the L Range, and Snake Pond. He pointed out MW-217 and MW-218, which had shown detections of RDX and perchlorate in profile sampling, and reported that RDX was detected in set well screens there, but perchlorate was not. He also noted that RDX was detected at 10.96 ppb in MW-227, to the north. Mr. Gregson pointed out the RDX contours and noted that the contamination originated at the central part of the J-3 Range. He also mentioned that the white circles one the map represent proposed well locations.
Mr. Gregson also displayed a figure that shows perchlorate detections in the southern part of the J Ranges and pointed out MW-232 and MW-227, which were installed to define the western edge of contamination. He noted that profile sampling showed perchlorate detections from 1 to 5 ppb at MW-232, and from 0.4 to 2.3 ppb at MW-227. He said that more locations would be drilled as part of the investigation.
Mr. Schlesinger noted that the plume boundary shown on the RDX plume map of the Southeast Ranges should, but does not, include MW-54. Mr. Gregson said that he thinks that Mr. Schlesinger is right and thanked him for pointing out the error.
Dr. Dahmani inquired about the PCE detection that Mr. Gregson had mentioned. Mr. Gregson stated that the PCE detection occurred a couple of years ago in a deep screen at a concentration less that the health advisory of 5 ppb. He added that PCE hasnít been seen in any other areas that were discussed this evening. Dr. Dahmani questioned whether that might be due to the sampling method thatís used. Mr. Gregson said that he doesnít think it is. Dr. Dahmani asked whether there are records of PCE having been used in that area of the base. Mr. Gregson stated that the single detection he had mentioned occurred outside of any known areas of PCE contamination. He also noted, however, that the IRP had conducted an investigation of the CS-8 site, which involved either PCE or trichloroethylene (TCE).
Dr. Feigenbaum referred to the map that shows perchlorate contamination in the Southeast Ranges and asked whether itís correct that the highest concentration of perchlorate detected in that area was 300 ppb. Mr. Gregson replied that this is correct, although he couldnít recall the exact well where that detection occurred. Dr. Feigenbaum remarked that he thinks itís a bit misleading not to show a 100 ppb contour on the map. Mr. Gregson said that he could confirm that detection and add a 100 ppb contour. Dr. Feigenbaum stated that doing so would provide a better idea of the intensity of the perchlorate problem there. He also noted that perchlorate at 10 ppb is "barely 500 feet away from" Snake Pond and he thinks itís important to begin developing some plans for remediation. Mr. Gregson replied that this area is one of the Groundwater Study Programís highest priorities because of the high concentrations, and because the RDX and perchlorate have reached beyond the base boundary. He said that his office is actively considering response actions that might be taken to arrest that plume migration.
Mr. Hugus referred to MW-54, which, as Mr. Schlesinger noted, at one time had a detection of RDX. He then said that with respect to the debate on whether or not to flag nondetect wells that previously had detections, he is in favor of continuing to flag those wells. He also noted that he wouldnít object if there were a way to indicate that those wells currently are nondetect.
Mr. Borci explained that for the purpose of clarity, the maps that are shown and discussed at IART meetings are not plume maps per se, but maps that show recent detections. He also said that the issue of presenting data on maps could be revisited at the next technical meeting "because clearly weíre not achieving clarity." Mr. Gregson also noted that active investigations are ongoing and therefore the plume maps are expected to change.
Dr. Stahl observed that there are no proposed wells between MW-227 and proposed well site J3P-31. He recommended that consideration be given to installing a monitoring well to the west of MW-142 and MW-143.
Dr. Dahmani commented that he thinks that people are concerned about where contamination is located, but are not concerned about when releases occurred.
Mr. Judge requested and received clarification that MW-54 continues to show detections of RDX. He then said that he would "really like to see these when theyíre drawn correctly." He also suggested that proposed well J3P-19 be moved farther to the west.
In response to Mr. Judgeís suggestion regarding J3P-19, Mr. Borci pointed out proposed well J3P-22, which is southwest of J3P-19. He then said that the plume map would be given "a drastic rewrite" after the proposed wells are drilled and data are gathered. He also asked team members to keep in mind that they are receiving data as soon as they are available Ė either profile, validated, or unvalidated. Mr. Borci further noted that the most recent plume map, with all the detections, could be found in "Additional Delineation Workplan #1," which was sent out to the team. Mr. Gregson added that the purpose of these presentations is to update the team on recent detections.
Mr. Dow asked whether the RDX and perchlorate occur at the same depths in the vertical profile. Mr. Gregson replied that they do occur at roughly the same depths. He also noted that RDX detections are now being seen in MW-227, which will cause the RDX boundary to shift a little to the west. Mr. Dow asked whether RDX and perchlorate move through groundwater at the same rate. Mr. Gregson replied that RDX moves more slowly. Mr. Dow said that itís his understanding that RDX is down at Snake Pond, but perchlorate hasnít reached there yet. Mr. Gregson replied that a possible explanation would be that they might have similar source areas, but different timing on the releases.
Mr. Dow also asked whether the hydrologic models show that the influence of Snake Pond is pulling the perchlorate upward, such that it might discharge into the pond at some point in the future. Mr. Gregson replied that based on the available data, the perchlorate is not far enough to the south to see that type of influence.
Ms. Hayes noted that the meeting is running late,
and requested that the team stay with the meeting agenda. She also
suggested that the team consider having another meeting, given that
it seems obvious that not enough time is being allotted for everyoneís
Agenda Item #5. CS-19 Supplemental Remedial Investigation Update
Mr. Aker showed a diagram of the CS-19 source area and noted that itís about 220 feet by 220 feet in size. He said that a magnetic survey of the area was conducted, magnetic anomalies were identified, and three trenches were laid out over the strongest anomalies. He also noted that two of the trenches are approximately 30 feet long, the third is approximately 70 feet long, and all of them are 10 feet deep.
Mr. Aker reported that most of the magnetic anomalies were located in the top 3 to 5 feet of the trenches. The deepest anomaly was a cluster of 155-millimeter (mm) rounds at about 5 feet, which indicated that the area was in fact a disposal area and that the rounds were buried there. Mr. Aker noted that the magnetic anomalies consisted of buried ordnance scrap, such as spent or cracked shell casings; metal debris, such as casing fragments, shrapnel, and rocket motors; and a great deal of waste debris, such as cable, pipe, and angle iron. He further noted that items found in the trenches included those that contained high-explosive compounds. These were a 57-mm projectile, an 81-mm mortar, and a 36-mm projectile. Many inert items also were found, including cracked 155-mm rounds, miscellaneous mortar bodies, practice bombs, and so forth.
Mr. Aker stated that approximately 1100 cubic yards of contaminated soil were removed during the remedial investigation (RI). Any soil that exceeded cleanup levels for lead, zinc, dioxin/furans, and RDX was transported to a facility in Elliot, Maine called Aggregate Recycling.
Mr. Aker showed a slide of an aerial photograph and pointed out the CS-19 plume as well as the Central Impact Area plume currently being investigated by the Groundwater Study Program. He noted that the CS-19 plume was mapped based on some of the most recent data, and vadose zone modeling was conducted. He also said that the "funny bend" in the plume is caused by a geological change from a moraine to an out-wash plain.
Mr. Aker then showed a figure entitled "CS-19 Groundwater Contours (Ķg/L) Maximum Detections RDX, Aug 1, 2001 to June 4, 2002." He noted that historically the highest concentrations have occurred at MW-9, where a 13.6 ppb RDX concentration was seen in a past sampling even. He also pointed out MW-2, where a 16.3-ppb RDX concentration was detected recently. Mr. Aker then referred to well 201, located far west within the plume, and explained that the dashed outline in that area indicates that itís uncertain whether or not the RDX detected at well 201 came from the CS-19 source area. He said that reverse particle tracking indicates that it may fall short of actually going back to the source area; however, it is included in the current conceptual model.
Mr. Aker stated that the conservative steady-state leaching model predicts that the plume might extend slightly beyond well 201, but some additional groundwater work still needs to be done in order to define the plume further. He also reported that the maximum perchlorate detection within the CS-19 area was 2.09 ppb, at MW-15B. He noted that the Groundwater Study Programís MDL for perchlorate is 0.35 ppb and the current EPA Region I relevant standard for perchlorate at MMR is 1.5 ppb. Mr. Aker then showed the cross-section view of CS-19 and pointed out the CS-19 source area, MW-9, MW-2, and well 201.
Mr. Aker stated that the RI findings for groundwater are that RDX particulate in soil is leaching to the groundwater and will be a continuing source until the soil is removed; that RDX contamination from the site forms a mappable plume; and that the inclusion of the detection at well 201 results in an RDX plume extending approximately 4500 feet from the source area.
Mr. Aker then referred to the human health risk assessment conclusions and noted that with respect to soil, carcinogenic risks exist due to RDX and arsenic. With respect to groundwater, a municipal well installed in the highest concentration area Ė which is an unlikely scenario Ė would pose a risk. Mr. Aker also said that thereís probable risk due to RDX, alpha-BHA, DDT, and arsenic, and that the remaining UXO debris may pose a safety hazard. He then referred to the ecological risk assessment conclusions and stated that the additive effects of TNT and its breakdown products in surface soil and standing water puddles pose a low risk to individuals of target terrestrial species, such as the vesper sparrow.
Mr. Aker again noted that the remaining RDX would continue to leach to the groundwater until the contaminated soil is removed. He also said that itís believed that the observed RDX plume will dissipate below the health advisory level within approximately 12 years Ė or sooner Ė after removal of the contaminated soils. He further noted that the regulatory agencies and AFCEE are in the process of resolving comments on the Draft Supplemental RI Report and will work to develop a schedule for appropriate follow-on activities.
Mr. Hugus asked what was found in the 1100 cubic yards of soil that were removed. Mr. Aker replied that a handout is available that lists everything that was found in that soil, which underwent a type of modified loam process. Mr. Hugus inquired about the public process associated with the soil removal effort. Ms. Grillo replied that an update was provided at a PCT meeting.
Mr. Hugus then commented that heís encouraged that AFCEE conducted the soil removal. He also noted, however, that the risk assessment conclusions and the statement that the plume would dissipate within 12 years lead him to believe that AFCEEís position is to take no action with respect to the contaminated groundwater. Mr. Aker said that more groundwater data are needed in order to determine what needs to be done, and the Remedial Project Managers (RPMs) are working together right now to make that determination. He also said that he would assume that at the least there would be some additional wells and sampling.
Mr. Hugus made a point of noting that CS-19 was first named as a site 13 years ago, in 1989, and he considers it disgraceful that in all that time no action has been taken toward remediation of the plume. He suggested that if this were to set a precedent for how to address other plumes in the Impact Area, his descendants would have to take his place at the IART table long into the future.
Mr. Minior reminded the group that EPA sent a letter requesting that the IRP stop its activities at CS-19 for a period of time; otherwise, the process at CS-19 would be further along at this point.
Mr. Walsh-Rogalski referred to the human health risk assessment conclusion regarding groundwater and stated that because the aquifer in this case is a sole-source aquifer and a potential water supply area, he would say that the point of compliance should be throughout the aquifer, and he thinks that the National Contingency Plan reads that way.
Mr. Judge questioned how long the CS-19 process was put on hold because of EPAís request. Mr. Minior replied that the process was stopped for over two years. Mr. Judge asked whether Mr. Minior wouldnít consider 13 years to be "an exceedingly long time." Mr. Minior replied that he would not, given the agreements that need to be reached with the regulatory agencies and the point in the process Ė between the Supplemental Investigation and the Remedial Investigation Ė when work was stopped. He said that it may seem like a long time, but itís actually relatively normal.
Mr. Judge commented that he likes the dotted-line portion of the CS-19 plume outline because it clearly indicates the uncertainty there. He also said that he appreciates having a cross-section view of the plume because it provides a good understanding of whatís happening there.
Mr. Schlesinger noted that the RI conclusions do not include a statement about perchlorate, and he wonders whether there is "something there." He also said that perchlorate has been seen to move much faster than RDX, and so he would expect that it would be "way beyond this location." He questioned whether the IRP would attempt to look for the perchlorate or just let it go because of the low concentration.
Mr. Aker showed a map depicting Groundwater Study Program perchlorate values, pointed out the CS-19 RDX plume and source area, and noted that the red dots represent perchlorate detections above the 0.35 ppb MDL. Mr. Schlesinger observed that the RDX is at the same point on the map, and he would have thought it would be quite a bit farther along. He asked again whether the IRP plans to look in that area for perchlorate. Mr. Aker replied that he doesnít think so, although a determination hasnít been made yet.
Dr. Stahl inquired about the status of the anomalies outside of the trenches at the source area. Mr. Borci replied that those anomalies have not been excavated yet. However, as part of the comment resolution process, AFCEE has agreed to conduct a digital geophysical survey there so that the anomalies can be addressed in the future. Mr. Aker clarified that AFCEE has taken care of some of the anomalies outside of the trenches. He also stated that more soils are going to be removed after the digital geophysical survey is conducted.
Dr. Dahmani asked about the purpose behind using the steady-state leaching model. Mr. Aker replied that the model was used in order to determine how much contamination would have to be in the soil to contribute to the plume and result in concentrations like those that are being seen. Dr. Dahmani remarked that running the model was an exercise to determine whether or not the source area was delineated properly. He then asked which leaching model was used. Mr. Aker replied that the SESOIL model was used. Dr. Dahmani also inquired about the vadose zone model. Mr. Aker replied that that was also SESOIL.
Mr. Schlesinger asked if itís correct that the investigation will not be extended farther west, beyond well 201. Mr. Aker reiterated that this is still under discussion, but his opinion is that it will not extend farther west, given that itís believed that the RDX plume doesnít extend out that far. Mr. Schlesinger noted that RDX was detected at 4.1 ppb in well 201, and he questioned how AFCEE could know that there isnít a second slug of RDX in that area. He recommended the installation of another monitoring well half way between well 201 and MW-183. Mr. Aker replied that the regulators and AFCEE are still discussing what will be done in the future.
Dr. Feigenbaum asked if the dispersion that Mr. Aker mentioned would pertain to both RDX and perchlorate. Mr. Aker replied that it would and again showed the aerial photograph, pointed out the moraine and the out-wash sediments, and said that the plume disperses and dilutes as it meanders through the various types of sediments Ė tight silts, clays, and so forth. Dr. Feigenbaum said that there doesnít appear to be any evidence of dispersal because the plume isnít getting wider or splitting. He then asked whether biological degradation of the perchlorate is expected. Mr. Aker replied that it is not and noted that only dispersion is being considered. Dr. Feigenbaum said that he would expect to see a different shape if the plume were dispersing.
Mr. Minior stated that the plume outline shown on the map depicts the RDX contamination as it relates to the health advisory of 2 ppb. He also said that itís important to note that perchlorate was detected only once in only one well associated with what is now defined as the CS-19 plume. He reminded the group that the Groundwater Study Program has developed a site characterization work plan for perchlorate sampling and more information will be forthcoming. Mr. Minior reiterated that right now there is only one perchlorate detection within CS-19.
Dr. Feigenbaum stated that it was about three months ago when he first learned that the regulatory agencies and AFCEE needed to resolve some disagreements regarding CS-19. He said that itís taking a long time to resolve this problem and heíd like Mr. Pinaud to summarize the disagreements so the team will understand them.
Mr. Pinaud stated that currently the discussion pertains mostly to EPAís comments about using SESOIL for the modeling. Mr. Borci added that a number of comments still have to be resolved. One has to do with the cleanup number for RDX in soil, and another has to do with naming perchlorate as a contaminant of concern in the plume. He also said, however, that AFCEE has agreed to conduct a digital geophysical survey at the CS-19 site. Mr. Borci further noted that the cleanup number for RDX in soil currently is under review by a national laboratory in Idaho thatís working with EPA. Itís hoped that resolution on this point will be reached sometime after completion of that review.
Dr. Dahmani commented that he thinks that there arenít enough data to delineate the plume, and there arenít enough data to say that dispersion is going to occur. He said that until further information is available, itís nothing more than a judgment call.
Mr. Schlesinger said that he agrees. He also
stated for the record that he is recommending that the IRP install a
monitoring well downgradient of well 201 Ė about half way between
well 201 and MW-183 Ė in order to ascertain "whether the RDX
goes farther off base than where itís located." He said that
he thinks that having those additional data will lead to a better
Agenda Item #6. Open Discussion/Other Issues
Ms. Hayes stated that sheís interested in knowing how news releases are coordinated, and whether team members speak for themselves or for the entire team. She said that itís important for the public to receive accurate and current information, and she doesnít always see that happening. She noted, for example, that she wondered about the accuracy of a recent report having to do with Mr. Walsh-Rogalski.
Mr. Schlesinger said that earlier this summer he received in the mail a news release pertaining to Snake Pond, which contained a map from February or March of this year. He said that this seemed to him to be misleading to the public, given that he had seen more up-to-date maps with better information. Mr. Schlesinger questioned whether there is a process in place to reach agreement on "what is current."
Ms. Dolen stated that information reaches the public via the media, either through news releases produced by the Groundwater Study Program office, or through articles generated, developed, and researched by the media themselves. She explained that the news release process is outlined in the Public Information Plan, which is derived from the administrative orders. Whether a news release is required, or for something thatís considered newsworthy, her office produces a draft thatís reviewed by EPA and DEP. Based on the regulatorsí comments, the release is revised and usually the regulators then review the revised version. Nothing is released without going through the regulators, at least 90% of the time, and the process can take quite a while. Ms. Dolen noted that when once a release is issued, the press could choose to print it "as is," not print it at all, or print a modified version.
Ms. Grillo clarified that the mailing that Mr. Schlesinger received was not a news release but a combined fact sheet with Air Force data and Groundwater Study Program data. She also noted, however, that it should have contained up-to-date information. Ms. Dolen added that this fact sheet also went through the regulatory process, and itís hoped that such cross checks will ensure accuracy.
Mr. Walsh-Rogalski referred to the "report" by George Seaver, which Ms. Hayes had mentioned, and then explained what had happened. He stated that a number of years ago Paul Zanis, then a member of the IART, informed EPA that a contractor who had done work near the base had uncovered some munitions while digging an excavation in a certain area. Mr. Walsh-Rogalski said that Mr. Zanis identified that area, and based on that information, EPA asked the Massachusetts Army National Guard to conduct a survey with a schonstadt in the backyard of one home. Although not requested to do so, ultimately the Guard agreed to survey the entire neighborhood.
Mr. Walsh-Rogalski continued by noting that Mr. Seaver then sent a Freedom of Information Act (FOIA) request for a copy of EPAís notes from the interview with the contractor. EPA informed Mr. Seaver that such an interview never occurred, but it did hand over notes on the conversation with Mr. Zanis. Mr. Walsh-Rogalski said that it appears that Mr. Seaver infers that thereís some kind of ongoing conspiracy because EPA didnít provide him with the document he requested Ė a document which, in fact, never existed.
Mr. Walsh-Rogalski said that he thinks that Mr. Seaverís story contained many inaccurate suggestions He also clarified that the story was not a report, but an opinion/editorial piece that the Cape Cod Times chose to print. He further stated that he believes that the facts, as he just relayed them, are accurate.
Mr. Murphy noted that the IART is a public team and its membersí names and contact information are available on the Groundwater Study Programís web site. He said that any team members who donít want to be contacted by the media should request that the Groundwater Study Program ensure that their contact information does not appear on the web site.
Mr. Judge stated that the survey conducted in the Sandwich neighborhood did in fact lead to the discovery of, he believes, rocket motors and/or bazooka rounds; therefore, people were not "getting excited about nothing." He said that he thinks that that area "rests a lot easier today because itís been scoured," and he believes that the effort was worthwhile. Mr. Judge also commented that heís satisfied with the news release process that the Groundwater Study Program office follows.
Dr. Feigenbaum emphasized that Mr. Seaver had not written a news article, but an opinion piece called "My View." He also said that he thinks itís entirely out of order at this time for Mr. Walsh-Rogalski to be called upon to answer to that opinion piece. Dr. Feigenbaum further stated that when he speaks to the media thereís no question that heís speaking for himself and only for himself, and he thinks that this is a non-issue.
Mr. Murphy clarified that no one is challenging anyoneís right to speak to the media. He also noted, however, that he thinks that Ms. Hayes had received a call from the media, and was wondering why she was called and whether the team had some type of policy. Ms. Hayes agreed that her questions had to do with process and policy. She also said that she appreciates the excellent job Ms. Dolen did of explaining this for her.
Ms. Garcia-Surette stated that DEP has a very strong public involvement component, and as such, sheís asking Ms. Dolen to explain the 10% of documents that would not undergo regulatory review, given that Ms. Dolen mentioned that about 90% are reviewed by the regulators. Ms. Garcia-Surette also referred to Ms. Dolenís comment that a review can take quite a long time, and noted that she wants to say for the record that Ms. Grillo of DEP, a dedicated public involvement coordinator for the region, "turns around those comments immediately" on any kind of news release or article.
Ms. Dolen explained that when she said that a review could take a long time, the point she was trying to make is that the review process is very comprehensive and thorough, not that thereís any undue delay in any respect. With respect to the 90% sheíd mentioned, Ms. Dolen said that she was trying to be very conservative in her estimate, and probably should have said 98%. She explained that the exception she had been referring to was a news release that came out of her office last year regarding a personnel appointment.
Ms. Grillo stated that in the past the Plume Cleanup Team (PCT) put together some guidelines Ė not hard-and-fast rules Ė for speaking to the media, speaking on behalf of the individual, speaking on behalf of the team, and so forth. She suggested that it might be beneficial for IART members to take a look at these guidelines, which she described as not very prescriptive, but very helpful.
Mr. Grillo also said that she wants it clearly understood that when a reporter asks DEP for the name of an IART member to contact, DEP never chooses a particular team member, but provides the entire list of members. She said that DEP feels very strongly that it would be quite inappropriate to pick one team member over another.
Mr. Schlesinger asked how often informational materials associated with the Groundwater Study Program are updated. He also noted that heíd heard that there are some changes occurring in terms of materials being distributed to the local libraries for the MMR information repositories housed there.
Ms. Dolen replied that the Groundwater Study Program office has a regular schedule of producing fact sheets and reports, and currently is updating the long-form fact sheet developed with the IART about a year ago. She also noted that her office follows an internal public affairs policy manual that the team is welcome to see. Included in that policy is that, when requested, the full list of IART members would be provided to the media. Ms. Dolen said that anyone who wants his or her name removed from that list should let her know. She also stated that she agrees that itís extremely important to be factual and up to date. She said that her officeís goal is to incorporate the most recent information into any news release or document that goes out to the public.
Mr. Schlesinger inquired again about the information being distributed to the libraries. Ms. Dolen explained that all of the information contained in the repositories is being uploaded to the Administrative Record, so it will be available on the Groundwater Study Program web site, and is also being uploaded to the Cape Libraries Automated Materials Sharing (CLAMS) network, so that any library thatís part of the CLAMS network can request documents from the information repositories. She said that the libraries have limited space and so requested that outdated materials be removed. A very methodical effort to do so has been under way for about six months, and any outdated materials are being kept only at the Coast Guard library and in a space at the Groundwater Study Program building.
Mr. Schlesinger stated that many people donít have computers and donít use the Internet, and he thinks itís "a sin" to take this information out of the libraries. Ms. Dolen explained that the request to remove material came from the libraries themselves. She also noted that a great deal of material remains at the libraries; however, thereís also a tabletop display that directs users to a number of other resources, including the CLAMS network and the web site, which can be reached via library computers that are available for public use.
Ms. Grillo said that the Sandwich library was the first to indicate that it had no more capacity for MMR documents. She also noted that when the cleanup information repositories were put together back in 1989/1990, the Falmouth library agreed to house a hard copy of the Administrative Record, and the Air Force funded the necessary space and equipment. Ms. Grillo said that the volume of information has increased significantly over the years, different libraries have different requirements, and so a concerted effort was needed to organize the information such that it would accessible to the end user.
Ms. Grillo commented that the CLAMS network, which is an inter-library loan system, is a "good thing." She also mentioned that it might make sense for the libraries to keep documents that are in an open public comment period at the reference desk, so they can be obtained easily. Ms. Grillo stated that the Joint Program Office (JPO) originally was coordinating the project to update the information repositories and the Environmental & Readiness Center (E&RC) graciously has picked up that coordinating role. She also said that she would continue to ask for updates on the project to reorganize the information repositories.
Mr. Murphy recommended that this topic be added to the list of future agenda items.
Request Regarding Potential IART Member
Mr. Minior commented that "EPA is quite proud of the openness of this forum." Therefore, he would hope, and request, that EPA ensure that comments submitted by the IART regarding prospective team member Mr. Mullenix be shared among all IART members. He noted that when the PCT is considering adding a new member to the team, thereís an open public discussion about that individualís qualifications and the teamís input is forwarded to the Senior Management Board (SMB), which approves the addition of new team members. Mr. Minior stated that although the IARTís process is a little different, he still would hope that the comments that Mr. Murphy forwards to EPAís regional administrator would be shared with all the members of the team.
Mr. Murphy stated that this decision would be up to regional administrator. He also acknowledged that the two processes do differ. He noted that at one time, discussions about prospective team members did take place at IART meetings, but some team members asked that the practice be changed as a courtesy to the person wanting to join the team. Mr. Murphy further noted, however, that negative comments have never been received about anyone. Mr. Minior replied that EPA should then be more than willing to provide all the comments and avoid a "kangaroo court" type of consideration. Mr. Judge took exception to Mr. Miniorís use of the term "kangaroo court."
Ms. Hayes stated that she agrees with Mr. Minior and thinks that itís very appropriate for all team members to see the comments made by other team members.
Mr. Murphy said that he doesnít imagine that the comments would be kept secret in any circumstance, but is not in a position to make that promise.
Mr. Mullenix stated, as the subject of this
discussion, heíd like to comment, "I really donít care one
way or another."
Mr. Murphy stated that earlier in the evening Ms. Crocker had asked if she could submit a letter to be distributed with the meeting record. He then noted that two months ago, at Ms. Crockerís request, he had included copies of an e-mail sheíd written with the distribution of the June IART meeting minutes. He explained that he had agreed to distribute the e-mail as a courtesy to Ms. Crocker because the July IART meeting had been canceled, but his feeling at the time was that it wasnít appropriate for EPA to distribute anyoneís comments on an ongoing basis.
Mr. Murphy said that he doesnít think itís right for EPA to get into distributing letters and so forth for individuals who arenít able to attend a meeting, although theyíre welcome to do so on their own. He also noted that comments made at meetings are distributed via their inclusion in the meeting minutes. Mr. Murphy also suggested that the team take up this discussion at the next IART meeting.
Mr. Schlesinger objected to the idea that an individual should have to be physically present at a meeting in order to have a comment distributed among the team members. Mr. Murphy reiterated that this discussion could be continued at the next meeting.
Agenda Item #7. Adjourn
Mr. Murphy announced that the IART would meet next on September 24, 2002 at the Bourne Best Western. He then adjourned the meeting at 9:28 p.m.