Impact Area Review Team

River River Drops of rain on a leaf

Impact Area Review Team
Quashnet Valley Country Club
Mashpee, MA
December 10, 2002
6:00 p.m. Ė 9:00 p.m.

Meeting Minutes





Ben Gregson

Groundwater Program


LTC David Cunha

HQ Camp Edwards


Marty Aker




Todd Borci



Margery Adams



Len Pinaud



Ellie Grillo



Dick Judge



Evelyn Hayes



Tom Cambareri




Joel Feigenbaum



Janet Pepin



Richard Hugus



Peter Schlesinger



Kevin Hood

TOSC/TAB/University of CT







Jim Murphy








Tina Dolen

Groundwater Program


MAJ Bill Myer

Groundwater Program


Mike Minior



Meghan Cassidy



Jane Dolan



Joseph McInerny



Dave Williams




Robert Mullennix

Bourne resident



Kevin Dennehy

Cape Cod Times


John Garry



Jim Quin

Ellis Environmental


Dave Egan

Shaw Environmental


Rick Carr



Christine Fairneny

Scheduling Solutions


Dave Heislein

Harding ESE


Kris Curley



Lori Boghdan



Jennifer Washburn



Action Items:

  1. The Groundwater Program (GWP) will verify the zones of contribution (ZOCs) depicted on maps of the Monument Beach wellfield, and the Massachusetts Department of Environmental Protection (DEP) will confirm those depictions.

  2. The Impact Area Review Team (IART) asks that the GWP provide a plume map depicting the perchlorate contamination at the Monument Beach wellfield.

  3. The GWP will update the IART on the response from the Natural Resource Trustee Council (NRTC) regarding a date for an NRTC presentation to the IART.

  4. Dr. Feigenbaum asks that the GWP provide the IART with an estimate of the amount of groundwater contaminated to date at the Central Impact Area.

  5. EPA will forward to IART members copies of the current Central Impact Area schedule and approvals for extension requests, as appropriate.

  6. Mr. Hugus requests that the GWP provide a cleanup plan for the contamination, as currently defined, emanating from the Southeast Ranges. Also, Mr. Judge asks that additional monitoring wells be installed in order to fully define that contamination.

  7. The IART requests that the National Guard Bureau (NGB) report to the team on the status of negotiations with Textron.

  8. Mr. Schlesinger requests that Installation Restoration Program (IRP) extraction wells associated with the Fuel Spill 12 (FS-12) plume be depicted (and identified as IRP wells) on Southeast Ranges maps.

  9. Dr. Feigenbaum requests that Southeast Ranges maps include a plume contour line pertaining to perchlorate detections at levels that exceed 100 parts per billion (ppb).

  10. Mr. Hugus asks to be provided with clarification of "MK1A" hardware on the J-3 Range, as noted in the Archive Search Report (ASR) summary.

  11. Mr. Hugus requests that Robert Varney, Regional Administrator of the U.S. Environmental Protection Agency (EPA), attend a future IART meeting to discuss the issue of "making the Cape whole."

  12. The GWP will confirm that the Army audit of the cleanup program is accessible to the public.

  13. Mr. Mullenix requests that his application for IART membership be discussed at the January 2003 IART meeting.

Future Agenda Items:

  • Gun and Mortar Firing Positions Workplans
  • Fate and Transport Presentation (proposed for March 24, 2003)
  • Demolition Area 1 Rapid Response Action/Release Abatement Measure (RRA/RAM) for Groundwater (January 28, 2003)
  • Demolition Area 1 RRA/RAM for Soil (February 24, 2003)
  • Update on the Programmatic Agreement being Pursued by MMR with Respect to Cultural Resource Surveys

Handouts Distributed at Meeting:

  1. Responses to Action Items from the October 22, 2002 IART Meeting
  2. Presentation handout: Investigation Update
  3. Presentation handout: ASR Interview Update
  4. Summary of Interviews Ė Witness #25 through Witness #52 and Follow-up Interviews Conducted as Part of the MMR Archives Search Report (ASR) Integration and Enhancement Effort/September 25, 2001 Ė March 25, 2002
  5. Demo 1 Soil/Groundwater Operable Unit RRA/RAM Schedule
  6. Summary of the Audit for the Impact Area Groundwater Study Program by the U.S. Army Audit Agency 9/23/02
  7. FW: Audit Criticizes Camp Edwards Groundwater Study Program
  8. Impact Area Groundwater Study Program Update/November Ė December 2002

Agenda Item #1: Welcome, Review Draft Agenda, Approval of October 22, 2002 Meeting Minutes

Mr. Murphy convened the meeting at 6:00 p.m. and the IART members introduced themselves. Mr. Murphy reviewed the agenda. He also asked if there were any changes or additions to the October 22, 2002 IART meeting minutes. No changes were recommended and the minutes were approved as written.

Agenda Item #2. Review Responses to Action Items from the 10/22/02 IART Meeting

Mr. Hugus referred to Action Item #3, which pertains to the Royal Demolition Explosive (RDX) detection that occurred in the community supply well at the Schooner Pass condominiums located near the Cape Cod Canal in Bourne. He stated that just because follow-up sampling of that well turned out to be nondetect for RDX does not necessarily mean that the problem has gone away, and he feels certain that the earlier RDX detection indicates that a real problem exists. Mr. Hugus said that he thinks that the efforts being made on behalf of the Schooner Pass residents are inadequate, and he believes that the blame should be placed with DEP, whose policy in this case is quarterly sampling. He also said that he would urge the Schooner Pass residents to request more sampling, "for the sake of their own health," and further noted that he thinks that the Guard should provide a new water supply for this residential area.

Mr. Pinaud made a point of noting that the RDX detection that occurred in the Schooner Pass well was at a level of 0.28 ppb, just over the reporting limit for RDX, which is 0.25 ppb, and well below the health advisory for RDX, which is 2 ppb. He also noted that the well was sampled again in November, and DEP would reconsider the sampling frequency based on those results.

Mr. Judge said that DEP would have to notify all the residents of Schooner Pass in the event of another detection of RDX in their well. Mr. Pinaud clarified that it would be up to the water supplier to make that notification, and itís his understanding that the water supplier did notify the residents when RDX was first detected in the well. Mr. Judge mentioned concerns about liability and suggested that it would be to DEPís benefit to take responsibility for notifying the residents of any future detections in the community supply well. He also said that there are plans to build another group of homes in that area.

Mr. Judge then referred to Action Item #2 and asked whether Laurie Perry, the Interim Tribal Historic Preservation Officer of the Wampanoag Tribe of Gay Head Ė Aquinnah, has responded to the GWPís invitation to come to a future IART meeting to discuss cultural resources survey activities at the Massachusetts Military Reservation (MMR). Ms. Dolen replied that Ms. Perry has not yet responded to the invitation. Mr. Judge requested that the GWP send another letter to Ms. Perry asking that she or a designee address the IART at a future meeting. Ms. Dolen noted that the original letter included a request for either Ms. Perry or a designee to speak to the IART. She also said that she would be happy to reiterate that request. Mr. Judge stated that itís been over three weeks since the letter was sent to Ms. Perry, with no response. He then asked for a copy of the original letter to Ms. Perry, which Ms. Dolen agreed to provide. Mr. Judge further noted that he would also like to have a copy of the follow-up letter and any response.

Dr. Feigenbaum asked that the IART be provided with the results from the November sampling of the Schooner Pass well, via e-mail, as soon as they become available. Mr. Gregson agreed to e-mail the results to team members.

Mr. Schlesinger inquired about the status of sampling the well across the street from Schooner Pass, at the Gallo Ice Arena. Mr. Gregson replied that he believes that a sample was collected from that abandoned water supply well last week.

Agenda Item #3. Late-Breaking News

Mr. Murphy confirmed that there was no late-breaking news to report at this time.

Agenda Item #4. Investigations Update

Monument Beach Wellfield Ė Recent Results

Mr. Gregson noted that supply well #1 at the Monument Beach wellfield continues to operate, while supply wells #3, #4, and #6 have been shut down. He then reported that wells 00-1 and 00-2 have been sampled, and noted that perchlorate was detected at 0.43 ppb in well 00-1, while well 00-2 tested nondetect for perchlorate. He also reminded the group that the DEP advice level for perchlorate, which was issued to the Town of Bourne, was 1 ppb. Mr. Gregson also reported that the GWP recently sampled a well that the U.S. Geological Survey (USGS) had installed about 25 years ago as part of a study of the freshwater/saltwater interface around Cape Cod. He noted that the wellís three screens in freshwater (BHW-222, 223, 224) were tested and the results were nondetect for perchlorate.

Mr. Hugus referred to the map of the Monument Beach wellfield area and asked Mr. Gregson to point out the location of supply well #1, which he did. Mr. Gregson then noted that up through December 18, 2002, the GWP would be accepting comments on the Monument Beach wellfield investigation workplan, which had been mailed out to IART members.

Mr. Cambareri asked Mr. Gregson to talk about the ZOCs shown on the map. Mr. Gregson stated that the ZOCs shown are based on the most recent AMEC groundwater model, using 2000 pumping rates. He noted that the figure shows the ZOCs for supply wells #4, #1, and #3, while the ZOC for supply well #6 is off the view of the map. Mr. Hugus asked if that ZOC is off the map because of the depth of the well. Mr. Gregson confirmed that that is the primary reason.

Mr. Cambareri asked if itís correct that perchlorate must be somewhere within the ZOCs that correspond to the supply wells that were shut down. Mr. Gregson replied that this is correct, but also noted that itís important to consider that pumping rates might have changed over time, which would cause the ZOCs to shift. He also asked the team to keep in mind that whatís being shown is a plan view representation of the ZOCs. Mr. Cambareri asked whether Mr. Gregson had a cross-section that shows the ZOCs. Mr. Gregson replied that he did not. Mr. Cambareri then inquired about a view that shows the upgradient side of the ZOCs. Mr. Gregson replied that when he discusses Demolition Area 1 he would show a view that includes upgradient portions of the ZOCs for supply wells #6, #3, and #1.

Dr. Feigenbaum asked whether the USGS well is thought to be serving the purpose of monitoring downgradient of the Monument Beach supply wells. Mr. Gregson replied that the GWP believes that the USGS well provides valuable information on the water quality downgradient of the wellfield. That, coupled with monitoring data from the wellfield itself, supports the idea that the leading of edge of perchlorate contamination is "somewhere in this part of the wellfield." Dr. Feigenbaum said that the USGS well appears to be "not quite downgradient" of supply well #1; therefore, he would like to renew the request for the installation of a new monitoring well thatís "more approximate to the wellfield and directly downgradient" of supply well #1.

Mr. Hugus commented that it seems that the ZOC shown on the map for supply well #1 would go just north of that well. Mr. Gregson said that he could check up on this with the AMEC modeler, who was not present at the meeting. Mr. Hugus asked Mr. Gregson to share his opinion on the ZOC. Mr. Gregson pointed to the curve of the groundwater contours and a low lying area that affects flow, and said that he has no problem envisioning that that ZOC would curve slightly to intercept the well. Mr. Hugus said that the kindest interpretation he could offer is that it doesnít appear that the ZOC is wide enough to cover all water that would reach supply well #1.

Mr. Hugus also inquired about the strategy for protecting public health in Bourne. He noted that supply well #1 is in close proximity to well 02-13, where perchlorate has been detected. Mr. Gregson replied that the GWP continues to conduct weekly monitoring of supply well #1, which has been nondetect for perchlorate right along. Also, the GWP continues to monitor upgradient wells, and itís looking at whether there is a viable technology that can treat perchlorate at levels like those being seen at the Monument Beach wellfield. Furthermore, the GWP meets every two weeks with Bourne Water Districtís Ralph Marks, his consultant, and DEP Water Supply.

Mr. Hugus proposed that with weekly sampling itís possible that perchlorate could go undetected at supply well #1 for six days, and he doesnít think thatís adequate protection for public health. Mr. Gregson noted that all of the perchlorate detections west of the base boundary have been below DEPís 1-ppb advice level. Therefore, if perchlorate were seen at that well, thereís every indication that it would be at a level below 1 ppb. Mr. Hugus noted that the other Monument Beach production wells were shut down because of perchlorate detections less than 1 ppb. He also said that he doesnít believe that a public water supply with any perchlorate, or any RDX, should be allowed to continue operating.

MAJ Myer mentioned that both DEP Water Supply and the Bourne Water District have seen the ZOCs as depicted on the map and are in agreement that they are an accurate representation.

Mr. Schlesinger questioned why some monitoring well labels shown with a square drawn around them Ė which the legend notes is indicative of a well with greater than or equal to three rounds of validated detections of perchlorate Ė refer to well locations shown as green dots, which indicate validated nondetects. Mr. Gregson explained that the color-coding is based on the most recent round of data, while the boxes pertain to historical detections. Mr. Schlesinger noted that that helps to make sense of why the GWP considers the USGS well to be downgradient of the perchlorate contamination.

Mr. Judge said that it seems to him that the ZOCs would loop down toward the draw of the water bodies Ė Mill Pond, Shop Pond, Freeman Pond, and Upper Pond. He then asked if the ponds are spring fed. Mr. Gregson pointed out "spring 1" on the map. Mr. Judge said that he would appreciate it if someone could take a look and explain why the ponds and that spring wouldnít be pulling the ZOCs down toward the southwest.

Mr. Cambareri said that while he thinks itís good that the USGS well tested nondetect for perchlorate, heís suggesting that another monitoring well be installed farther north, along County Road Ė a location that he believes would be downgradient of supply well #1. He also noted that any effects on the perchlorate contamination from pumping supply well #1 are unknown. He then asked if itís correct that supply well #1 is actually four different wells hooked up to a manifold. Mr. Gregson confirmed that it is.

Mr. Murphy noted that an action item that came out of this discussion is for DEP to take another look at the ZOCs for the Monument Beach supply wells. Mr. Gregson agreed and noted that AMEC also would look at those ZOCs and confirm that theyíre located correctly and take into consideration the influence of the spring and the groundwater discharge to the south.

Mr. Gregson again mentioned the workplan that was sent to team members, and asked that they submit their comments to the GWP or EPA by December 18, 2002. He also suggested that team members mark the map with a dot to indicate recommended monitoring well locations. He then reiterated that the GWP believes that the downgradient extent of perchlorate contamination at the Monument Beach wellfield has been defined adequately. He noted that the GWP has not proposed any additional wells downgradient of supply well #1. Dr. Feigenbaum stated that he is making his comment now, rather than submitting it later, that an additional monitoring well should be installed on County Road, directly downgradient of supply well #1.

Mr. Hugus requested that the GWP provide a plume map depicting the perchlorate contamination at the Monument Beach wellfield. Mr. Judge noted that he too would like to request that an additional monitoring well be installed on County Road, downgradient of supply well #1. Mr. Cambareri said that he thinks an appropriate well site would be farther north on County Road, downgradient of the cluster of detections at wells 00-1, 01-2, and 01-1. Mr. Schlesinger recommended siting a monitoring well adjacent to the pond just east of County Road and west of well 00-1.

Mr. Judge inquired about the possibility of supply well #1 drawing in perchlorate contamination detected at wells 00-1, 01-2, and 01-1. Mr. Gregson replied that he thinks thereís very limited potential for that contamination to be drawn into that well. He noted that groundwater flow in that area is toward the west, and he also pointed out the ZOC for water supply well #1. Mr. Judge asked that his concern about this possibility be noted.

Ms. Garcia-Surette inquired about the concentration level that would be used to draw the perchlorate map Ė for example, 1.5 ppb, nondetect, or some other level. Mr. Gregson replied that the GWP deals with a couple of regulatory limits for perchlorate Ė DEPís 1-ppb advice level and the 1.5-ppb MMR relevant standard thatís used for evaluation of cleanup alternatives. He also noted that in the past the GWP has drawn plumes to the nondetect contour. Mr. Hugus clarified that his request was for a plume map that includes anything above nondetect.

Demolition Area 1 Ė Recent Results

Mr. Gregson showed a map of Demolition Area 1, pointed out the plume boundary, and noted that the extent of RDX contamination is shown in tan, and the extent of perchlorate contamination is shown in pink and includes a nondetect contour and a 1.5-ppb contour. He also pointed out the source area, a depression where open burn/open detonation of explosives took place.

Mr. Gregson then reported that the profile result for monitoring well 248 (MW-248) was nondetect for explosives and perchlorate, and itís hoped that this is an indication that the toe of the perchlorate contamination has been found. He also noted that a well currently is being drilled at location D1P-18, south of MW-248, and if that proves to be nondetect, the next location to be drilled will be D1P-17. If the well at D1P-17 turns out to be nondetect, the GWPís position will be that the toe of the plume has been defined.

Central Impact Area Ė Recent Unvalidated Detections

Mr. Gregson showed maps depicting the Central Impact Area and noted that the area of RDX contamination includes a nondetect contour, 2-ppb contours, and greater-than-10-pbb contours. He also explained that the color-coding of the wells represents perchlorate results, not RDX. He noted that red represents perchlorate detections above 1.5 ppb, yellow represents perchlorate detections up to 1.5 ppb, and green represents nondetects.

Mr. Gregson then reported that perchlorate was recently detected at 0.5 ppb in MW-102 on Burgoyne Road. He also noted that RDX was detected at 9.2 ppb, High Melting Explosive (HMX) at 0.41 ppb, and perchlorate at 1.1 ppb, in the first sampling event at the new well east of Turpentine Road and north of Tank Alley, MW-235. Mr. Gregson then pointed out MW-245, which is a well related to J Range work, but located in the Impact Area. He noted that profile sampling at MW-245 showed RDX in 11 intervals at concentrations from 0.3 to 6.5 ppb. He also reported that at MW-249, to the west, profile sampling showed RDX in one interval at 0.94 ppb, as well as a 0.38-ppb detection of trinitrotoluene (TNT), which has a health advisory of 2 ppb, and is not usually seen in groundwater. Screens are being installed in MW-249, after which it will be determined whether those detections are repeated in groundwater sampling.

Mr. Hugus inquired about the upper limit of the greater-than-10-ppb RDX contours. Mr. Gregson replied that those detections are not much above 10 ppb; he believes that concentrations in the Central Impact Area are all less than 20 ppb. Mr. Hugus stated that he thinks that the IART ought to begin discussing concrete plans for cleanup of the Central Impact Area plume. He asked the regulators to share their opinions on this suggestion, and noted that heíd like some time set aside at an upcoming IART meeting for discussion about cleanup.

Mr. Borci stated that some Central Impact Area schedules have been provided. However, due to additional detections, the Guard has requested some extensions to the original milestone dates set by EPA. These milestones have to be revised while the effort to determine the full nature and extent of the contamination continues. Mr. Borci said that he thinks the first step is to provide the IART with the most recent schedule, as well as copies of EPA letters granting any extension requests. Mr. Borci assured the team that while "things are in a little bit of flux right now," the Central Impact Area work is not being ignored.

Mr. Murphy noted that the January and February IART meetings would focus on Demolition Area 1, but itís possible that the March meeting could focus on Central Impact Area work. He also noted that the latest schedule would be sent out to the team before then.

Mr. Gregson stated that three additional wells have been proposed to define the extent of RDX contamination in the Central Impact Area. Also, a round of sampling was recently conducted to look at the extent of perchlorate there. In a step-wise fashion, the GWP is trying to gather enough information on the extent of groundwater contamination for both RDX and perchlorate before moving to the next step, the feasibility study for cleaning up the Central Impact Area. Mr. Gregson asked the team to keep in mind that this would be a complicated cleanup process because there are multiple source areas and multiple plumes.

Mr. Schlesinger referred to the map and inquired about the small bone-shaped area of gray within the RDX contour, and near MW-17. Mr. Gregson explained that that is an area of nondetect. He also noted that gray is the background color of the map. Mr. Schlesinger also asked why additional wells arenít being proposed downgradient of the recent perchlorate detections. Mr. Gregson replied that the perchlorate definition is not as far along as the RDX definition, and itís possible that more wells will indeed be proposed.

Mr. Judge questioned whether the Natural Resource Trustee Council (NRTC) was aware of the extent of contamination at the Central Impact Area. He also repeated a previous request to have a voting member of the NRTC address the IART. Mr. Murphy noted that this was an action item from the October IART meeting, and a letter has been forwarded to the NRTC. Ms. Dolen added that she spoke with Dale Young of the Executive Office of Environmental Affairs (EOEA), who said that an effort is being made to determine a date Ė possibly February or March. Ms. Dolen also said that she would update the team as soon as the NRTC commits to a specific date. Mr. Judge said that heíd like to hear more about how the state plans to account for pollutants, especially when it comes to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), which, he believes, defines unexploded ordnance (UXO) as scrap metal, not as a pollutant of concern. Mr. Pinaud noted that DEP has an advisory role on the NRTC and provides regular updates on MMR activities to EOEA, the trustee for the Commonwealth.

Dr. Feigenbaum asked that the GWP provide the IART with an estimate of the number of gallons of water contaminated at the Central Impact Area. Mr. Murphy noted this request for information as an action item.

Mr. Gregson continued with his presentation by reporting that a first-time perchlorate detection occurred in existing well 95-6, at a concentration of 0.74 ppb. He noted that the forward particle track from that well goes to the northwest and eventually intersects the Cape Cod Canal, while the backward particle track goes back through the Central Impact Area and down to a location just east of Turpentine Road. He further noted that AMECís prediction, based on the model, is that it would take 85 years for a particle to travel from that well to the base boundary. Mr. Gregson stated that something doesnít make sense, given that perchlorate wasnít used at MMR until the late 1940s. He said that this indicates that thereís a problem either with the model or the detection. He also noted that the well was resampled last week, and results are expected to be available soon.

Ms. Hayes inquired about the status of the EPA process to establish a standard for perchlorate. Mr. Gregson replied that itís his understanding that EPA currently is looking at toxicity information and expects to issue a value for the Integrated Scientific Information System (ISIS) database by the end of this year. However, under the current regulatory and public comment process, it will be years before an official maximum contaminant level (MCL) for perchlorate is established. Mr. Gregson also said that the GWP is in favor of whatever EPA could do to accelerate that process, but understands that many considerations go into establishing that number, not only from a technical standpoint, but also from economic and practical standpoints. Ms. Hayes asked whether the lack of an established standard impedes some of the GWPís work. Mr. Gregson replied that it mostly affects whatís done with the data that are collected Ė for example, it isnít really known what a 0.7-ppb detections means, other than that itís lower than 1.5 ppb and 1 ppb.

Mr. Judge stated that as long as areas of perchlorate contamination are defined to nondetect, the standard really isnít an issue because it can be applied later, once itís been established. Mr. Gregson said that itís more a matter of wise allocation of resources. Mr. Judge maintained that when an area is defined to nondetect, the standard doesnít matter right away Ė however, the effort does define the extent of the plumes and decisions can be made based on that knowledge alone. He also said that the reason for drawing nondetect contours is to identify pollution that wasnít there before, which ties in with the idea of "making the Cape whole," an idea that he believes is in everyoneís best interest.

Mr. Schlesinger referred to the base-wide map and asked about the level of RDX contamination shown there for the Central Impact Area. Mr. Gregson replied that the base-wide map shows Central Impact Area RDX contamination greater than 2 ppb, the health advisory.

Ms. Garcia-Surette responded to Mr. Judgeís comments by saying that the cleanup project is based on a requirement to either achieve or approach background, i.e., nondetect. She said that unless thereís a situation that hinders the GWP from getting there, that is the expectation.

Mr. Cambareri inquired about sampling of the Bourne landfill monitoring wells. Mr. Gregson said that he believes that those wells are part of the GWPís long-term monitoring program. He noted that the Bourne landfill routinely samples the wells for volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), metals, and so forth, while the GWP has data pertaining to explosives and, he believes, perchlorate. Mr. Gregson also agreed to provide this information to the team.

Southeast Ranges Ė Recent Unvalidated Detections

Dr. Feigenbaum referred to the Southeast Ranges maps displayed by Mr. Gregson and said that he thinks itís a good idea that they show perchlorate and RDX contamination separately.

Mr. Gregson noted that the GWP collected groundwater samples from three wells installed by the Air Force Center for Environmental Excellence (AFCEE) as part of the FS-12 investigation Ė wells 90WT0004, 90MW0019, and 90MW0038. He reported that perchlorate was detected in well 90MW0019 at 0.6 ppb, in well 90MW0038 at 0.5 ppb, and in well 90WT0004 at 0.7 ppb. He also reported that perchlorate was detected at 0.7 ppb in MW-218, located on the northern boundary of Snake Pond. Mr. Gregson noted that this was a deep detection, 123 to 128 below the water table, underneath the pond. He further noted that surface water sampling conducted at Snake Pond during the summer months has consistently been nondetect for perchlorate.

Mr. Gregson then reviewed some profile results. He noted that perchlorate was detected in profile samples from MW-243, at concentrations from 0.4 to 1.2 ppb. In addition, 2,6-dinitrotoluene (2,6-DNT) was detected in one interval at MW-243. In MW-246, which is located on the east side of the perchlorate plume, profile sampling showed perchlorate in one interval, at 0.48 ppb. Mr. Gregson also reported that in MW-247, profile sampling showed perchlorate in seven intervals, from 0.8 to 5.7 ppb.

Mr. Schlesinger asked about plans for cleanup of the Southeast Ranges contamination. Mr. Gregson replied that the process for the Southeast Ranges isnít as far along as those for Demolition Area 1 and the Central Impact Area. He also said that the current drilling program at the Southeast Ranges is attempting to define the extent of perchlorate and RDX in that area. Mr. Gregson then mentioned that the GWP has been thinking about the extent to which the existing FS-12 treatment system captures contaminants in that area, and whether adjustments could be made to that system and the extraction wells in order to capture the perchlorate.

Mr. Schlesinger questioned how that system could stop the perchlorate plume, given that the FS-12 fence is located on the other side of Snake Pond. Mr. Gregson pointed out a line of extraction wells for FS-12 "that extends out to a location somewhere in here" and noted that whether or not that layout would be effective in capturing the perchlorate depends on where the perchlorate is. He said that itís not possible to begin cleanup until itís known where the contamination is located. Mr. Schlesinger noted that no monitoring wells are located in the area to which Mr. Gregson referred. Mr. Gregson explained that itís a step-by-step process and it takes time to install the wells.

Dr. Feigenbaum asked Mr. Gregson to identify the highest level of perchlorate in the plume. Mr. Gregson replied that the highest level, which is about 150 ppb, occurred in MW-198, where the original profile sample was, he believes, as high as 300 ppb. Dr. Feigenbaum said that he thinks the map should include a 100-ppb contour. Mr. Gregson explained that because plume shells are not updated for each IART meeting, at this point the map doesnít reflect many of the data that have been collected over the past few months. Dr. Feigenbaum noted that there have been repeated requests for a 100-ppb contour, and heíd like this request to be noted as an action item. He also said that he thinks the current map would be completely misleading should it be released to the public. Mr. Gregson stated that this information would be included in the map the next time that itís updated, and that update is expected to occur with a report on this investigation thatís due out in May 2003.

Mr. Borci stated that some of the results being discussed this evening are profile results, and itís necessary to wait for the actual well screen data before updating the map. He also acknowledged that May "is a while off" and he would like it if the map were updated before then, if possible. Dr. Feigenbaum said that incorporating old data in a meaningful way is a slightly different issue than waiting for new data. Mr. Borci agreed, but also said that the map has been updated somewhat over the previous months. He also said that right now there is only one well with a detection higher than 100 ppb. Dr. Feigenbaum stated that he thinks that finding the extent of that extremely high level of contamination should be a priority. Mr. Borci replied that while that is recognized as a priority, another priority has been to get a handle on some high detections along Greenway Road and in the vicinity of Snake Pond.

Dr. Feigenbaum commented that he considers the contamination from the Southeast Ranges to be an area of critical concern, given its proximity to Snake Pond and the Weeks Pond well. He also said that he thinks the plume is going to catch the western edge of Snake Pond, "not miraculously cross the pond and go into the FS-12 treatment system," which isnít even set up to handle perchlorate. Dr. Feigenbaum said that he thinks itís important to get started on cleaning up this plume because its toe is right at a residential area.

Mr. Borci clarified that the FS-12 extraction well locations to which Mr. Gregson referred earlier are locations that currently arenít being used by the FS-12 system. He said that the Guard is looking at the possibility of using locations that were selected for FS-12, but were never turned on.

Mr. Hugus stated that he too is frustrated by the lack of action on this plume, and he wishes that there were some incentive for the Guard to expedite investigations. He said that the burden always falls on the public to wait for new data to come in, with no penalty "except the not very strong ones" place on the military by EPA to hurry up and define the plumes in order to get to cleanup. Mr. Hugus remarked that years and years go by before any progress is made, which is frustrating for the citizen members of the team. He also said that he sometimes feels that heís being used in the process in the sense that it seems the military is making it look as though the citizens have input, when their presence really just makes it possible for the military to say that thereís citizen involvement. Mr. Hugus added that he feels his time is being wasted "when it comes to plumes like this," where the team constantly asks for action that is not provided.

Mr. Judge said that he is asking the GWP to immediately begin installing the necessary wells to define the plume, while, at the same time, implementing a plan to collapse the plume that utilizes the existing FS-12 extraction wells that arenít currently operating. He also remarked that it would be a "whole other ball of wax" should RDX and perchlorate start to be detected in Snake Pond and the military has to explain that it knew about the contamination years before, but it took "three years to define it, another three years to implement a plan, another three years to set up a pump-and-treat system."

Mr. Schlesinger asked if future maps could include the FS-12 extraction wells, and identify them as such. Mr. Gregson agreed that this could be done.

Mr. Judge inquired about Textronís involvement at the Southeast Ranges. Mr. Gregson replied that Textron has conducted some cleanup actions at the J-3 Range, such as removing some drums, and is working with EPA on additional response actions. Mr. Judge asked whether those response actions include paying for part of the cleanup. Ms. Adams stated that while Textron may be responsible for a lot of the cleanup at the J Ranges, thatís a claim that the Department of Defense (DoD) needs to assert against Textron under CERCLA. She said that itís her understanding that this claim has been the subject of some negotiation, but she doesnít know the current status. She also noted that EPA is looking to the NGB to "get action" on the Southeast Ranges, and intends to push the NGB to do so.

Mr. Judge stated that, as a taxpayer, he would appreciate it if the NGB could send a bill to Textron to help pay for the cleanup. He said that he would like to know whether Textron is going to step up to the plate and provide money. Ms. Adams suggested that an appropriate action item would be a request for a report on the status of NGBís negotiations with Textron. Mr. Gregson said that he could provide that report.

Mr. Pinaud said that while he understands the IARTís concerns about this area, and is himself concerned, he wouldnít want anyone to think that the solution is as simple as "turning on some dormant extraction wells and everything will be okay." He noted that the FS-12 system uses carbon treatment and itís not known how effectively carbon will treat perchlorate. He also noted that turning on those upgradient extraction wells would radically change groundwater contours in an area where active investigation is ongoing. Mr. Pinaud suggested that it makes sense to proceed with caution, and again noted that turning on those dormant wells "is not easy, itís complicated."

Mr. Schlesinger asked whatís being done to answer questions about treating perchlorate by carbon filtration. Mr. Pinaud replied that itís his understanding that the Guard currently has a performance evaluation in the works. Mr. Gregson agreed and noted that the pilot study work being done in relation to the perchlorate contamination in Bourne is looking at the effectiveness of carbon to remove perchlorate, as well as an ion exchange resin technology to treat perchlorate. He then noted that the FS-12 treatment system was designed to take care of a fuel spill problem, and what the GWP is proposing would add a whole new dimension to that system. He also said that the first thing the GWP wants to do is avoid ruining the cleanup thatís under way. Mr. Schlesinger replied that, on the other hand, thereís been a lot of talk that the FS-12 system is going to be the solution to the contamination in this area. He then suggested that perhaps the IART needs a report on the effectiveness of the existing FS-12 carbon system, relevant to the measures being investigated with respect to Bourne.

Ms. Hayes asked whether Mr. Pinaud was indicating that he thinks that the current process is adequate, and he would advise against a rush to judgment that may cause more damage than good. Mr. Pinaud replied that he thinks that the FS-12 treatment system has some potential, but it will take some time to see how well it can work to address the Southeast Ranges plume. He also noted, however, that he thinks that the delineation of the plume could be expedited, and he is in favor of that.

Mr. Judge indicated that he thinks the most important thing to do is move forward with some type of treatment. He suggested, for example, building a system to address the RDX contamination right away, and then, later, as more is known about treating for perchlorate, make the appropriate changes to that system.

Dr. Feigenbaum said that he thinks the first step has to be to expedite delineation of the plume. Mr. Pinaud indicated that he has no objections to that. Dr. Feigenbaum also said that in terms of perchlorate treatment, the Guard needs to come up with an answer soon, given the upcoming plan for Demolition Area 1 groundwater. Mr. Gregson stated that the GWP would be presenting that plan, which will include a strategy for perchlorate, at the next IART meeting. Dr. Feigenbaum observed that answers to the perchlorate question are starting to be developed, and once thereís a plan for Demolition Area 1, the GWP should have the capability to quickly develop a treatment system for the Southeast Ranges plume, whether or not that involves the FS-12 system.

Mr. Gregson referred to the Southeast Ranges map for RDX and reported that profile results at MW-247 showed RDX in three intervals from 96 to 116 feet below water table, at concentrations from 0.45 to 1.14 ppb. He noted that if these detections hold up in groundwater samples, the plume contour would have to be expanded out to the west.

J-2 Range Ė Recent Unvalidated Detections

Mr. Gregson referred to the northwest end of the J-2 Range where a magnetic anomaly was identified as an ordnance demolition area. He reported that MW-230 had a perchlorate detection at 0.7 ppb. He also noted that the deeper screen at MW-234 had detections of RDX, TNT, 2A-DNT, and 4A-DNT Ė all at levels below health advisories. The shallow screen at MW-234 had a perchlorate detection at 1.3 ppb. Mr. Gregson noted that proposed location J2P-17 is expected to help further define whatís happening in that region of the J-2 Range.

Mr. Schlesinger inquired about the direction of groundwater flow in that area. Mr. Gregson replied that the groundwater flow is off to the north.

Agenda Item #5. Archive Search Report Interviews

MAJ Myer noted that a summary of Archive Search Report (ASR) interviews #25 through #52 was mailed out to IART members. He then stated that in July 1998 EPA issued a modification to the first Administrative Order (AO), which required the ASR. In summer 1999, the U.S. Army Corps of Engineers (USACE) began the ASR effort, which included conducting 20 interviews. The draft report was completed, and comments from EPA and DEP were received in December 1999. In response to those comments, in September 2001 the Guard began conducting a number of interviews, the findings of which will be discussed this evening. MAJ Myer then stated that from 1999 to the present, over $1 million has been spent on ASR efforts.

J Ranges Significant Information

MAJ Myer noted that an interviewee reported that disposal activities were conducted in the areas identified by the Guard as polygons 1 and 2 at the J-2 Range. He said that interviewees provided specific information that helped fill in some data gaps and focus the investigation. Also at the J-2 Range, an interviewee identified an area behind one of the berms where open burn/open detonation activities occurred. MAJ Myer stated that information from interviews #25 through #52 helped the Guard in locating some of the burn and burial sites; defined some of the firing and target locations, as well as some general practices, on the defense contractor ranges; and helped identify possible source areas and contaminants.

Central Impact Area and Ranges Significant Information

MAJ Myer stated that many of the interviewees identified gun and mortar positions and reported that burning of propellants was a regular activity. He noted that an interviewee identified a specific bunker at the Chemical Spill 19 (CS-19) site where large quantities of TNT, as well as other compounds, were destroyed. MAJ Myer noted that many of the interviews that were conducted helped lead to the extensive ongoing work at the gun and mortar positions, the soil and groundwater work, and work at the Central Impact Area.

Ammunition Supply Pont Important Findings/Actions

MAJ Myer stated that one interviewee reported small arms ammunition buried near or around the current Ammunition Supply Point (ASP), as well as other potential burial sites in that area. In response, the Guard conducted limited geophysical work in the areas identified by the interviewee, and as a result, some other burial sites were found. MAJ Myer reminded team members that in November 2001 they were provided with an interview update that noted that a site with over 300 jet engine starters was found, as was a site where small arms cartridges and spent grenade canisters were found.

MAJ Myer also noted that so far the ASP investigation has not led to the discovery of the small arms burial sites identified by an interviewee, although other burial sites were found. He said that some additional individuals are going to be interviewed in an effort to find out more about the small arms burial sites.

Demolition Areas 1 & 2 Important Findings/Action

MAJ Myer stated that many of the interviewees #25 through #52 identified Demolition Area 1 as the main disposal area. They noted that they destroyed ordnance items there, and that the state police would bring fireworks there to be destroyed. The interviewees mostly identified Demolition Area 2 as having been used primarily for training, although the Guard did find a burial location there containing some Composition 4 (C4), which is a plastic explosive.

Future ASR Actions, and Conclusions

MAJ Myer stated that limited data gaps remain. The Guard has proposed to conduct 10 additional interviews, and currently is in discussion with EPA and DEP about this proposal. Additional information that the Guard wants to obtain has to do with maintenance of the missiles at the Boeing Michigan Aeronautical Research Center (BOMARC) missile facility. Also, the Guard is looking to fill data gaps pertaining to training operations at the ranges from 1945 to 1970, explosives ordnance disposal (EOD) activity from 1945 to 1960, and anything more that can be learned about open burn/open detonation activities conducted by defense contractors who operated on the ranges. MAJ Myer also reiterated that an effort would be made to find out more information about burial sites near the ASP.

MAJ Myer said that information provided by interviewees is not always validated, and the locations the interviewees identify are not always specific. He also noted, however, that interview information helps focus investigation activities, such as locating soil sampling grids or monitoring wells. In addition, conducting the interviews has helped prompt additional investigations. MAJ Myer further noted that the interviewees are a good source for corroboration of information thatís been gathered through investigation.


Mr. Schlesinger asked whether air magnetometry (air mag) was used to survey potential burial sites near the ASP. MAJ Myer replied that ground-based survey work, using an EM-61 tool and handheld schonstadt magnetometers, was conducted there. Mr. Schlesinger questioned whether there are any plans to use air mag for future survey work. MAJ Myer replied that there are no such plans at this time. He also noted that in this situation, better information can be obtained from ground-based geophysical surveys; whereas, the air mag tool was good for finding larger metallic objects, given altitude limitations imposed by trees and the like. MAJ Myer mentioned that air mag had been helpful in identifying an area of barrage rockets at the J-3 Range, as well as some previously unknown targets at the U Range.

Mr. Schlesinger remarked that heíd like to see increased use of air mag in areas where thereís uncertainty about sources Ė for example, he thinks it would be beneficial to conduct an air mag survey upgradient of the perchlorate detections in the Monument Beach wellfield. MAJ Myer stated that thereís a current effort to evaluate archive search information and existing data in order to help focus on potential source areas, such as the corridor between Bourne and Camp Edwards, and follow up with ground reconnaissance to identify whether some kind of source area exists there. He said that this effort is being conducted as a step-wise process.

Ms. Pepin inquired about obtaining a summary document for interviewees #1 through #24. MAJ Myer replied that he could provide a copy of this document to Ms. Pepin. Ms. Pepin also asked about the total number of interviewees so far. MAJ Myer replied that the USACE conducted approximately 20 interviews, while the Guard has conducted a total of 52 interviews. He also noted that some individuals were interviewed two or three times, and he believes that each interview was counted separately, although heís not certain.

Ms. Pepin observed that there seems to be an information gap for the period 1964 to 1974. MAJ Myer replied that information about activities that occurred during the 1970s up to the present is relatively plentiful, but there arenít as many people around who can provide information pertaining to the time period from 1945 up to the 1970s. Ms. Pepin then asked whether information about spills and dumping of waste chemicals is being sought, in addition to information about burning and detonation. MAJ Myer replied that all information is being collected, not just that which relates to ordnance. Ms. Pepin also asked whether the private investigator continues to be involved in the ASR effort, and if so, whether that fee is part of the $1 million spent so far. MAJ Myer confirmed that the private investigator still is involved and that fee is part of the $1 million.

Ms. Hayes noted that sheíd be interested in knowing the percentage of interviews that actually provided pertinent information that led to follow-up activities. She also said that the private investigatorís fee could not have been $1 million, and asked whether the interviewees were paid. MAJ Myer replied that they were not paid. Ms. Hayes then asked how the money was spent. MAJ Myer replied that USACEís initial archive search and interviews had cost approximately $300,000. The remaining portion was spent on the recent round of interviews conducted from September 2001, based on an EPA and DEP recommendation; a military history report, which was part of the regulatorsí recommendation; some contracts research; the private investigatorís investigation; and modifications to the existing ASR. Ms. Hayes said that there were many administrative costs. MAJ Myer agreed and noted that there were many reports.

Ms. Hayes again asked about the percentage of interviews that provided pertinent information that checked out and proved to be helpful in the cleanup. MAJ Myers replied that a lot of the interviews provided good information, such as that having to do disposal activities at the J Ranges and burial locations near the ASP. He also said that while he would have to look up the actual percentage, he believes that any piece of information that can be obtained is going to be useful.

Mr. Hugus asked whether the protocol for conducting the interviews was consistent. MAJ Myer replied that the initial group of interviews was conducted by the USACE, with participation by EPA at some point in time. He also noted that the private investigator, who conducted the more recent interviews, used a standard set of questions that was developed by the Guard, EPA, and DEP. MAJ Myer said that his assumption is that the private investigator conducted the interviews in a consistent manner, asking the same questions of all interviewees. He also noted that EPA, DEP, and the Guard were present for some follow-up interviews that included site visits where the interviewees actually pointed out specific areas. MAJ Myer concluded that the initial group of interviews conducted by USACE differed from those conducted by the Guard from September 2001 to the present. Mr. Hugus commented that he thinks itís helpful to have consistency.

Mr. Hugus also noted that an interviewee reported having witnessed destruction of MK1A hardware by burial and incineration. The interviewee also said that MK1A hardware was classified and he would not discuss it. Mr. Hugus then asked MAJ Myer to define MK1A hardware. MAJ Myer replied that he would forward this question to the GWPís UXO safety specialist to see if he could provide an answer. Mr. Hugus then noted that the interview summary mentions that SFW weapons were tested at the J-3 Range, and asked what SFW means. Mr. Borci stated that SFW stands for sensor fused weapons.

Mr. Hugus also said that a second interviewee has testified Ė although not absolutely Ė that depleted uranium (DU) was fired in rounds at the J Ranges, as was reported by an interviewee in the first group of interviews. MAJ Myer noted that other interviewees have reported that DU was not fired. He also said that an investigation was conducted to evaluate the presence or lack thereof of DU, and that investigation did not identify any DU on the ranges. Mr. Hugus countered that one interviewee also claimed that Textron didnít bury mortars anywhere on the J Ranges. He said that he thinks that there should be follow-up on reported activities. MAJ Myer again noted that the Guard had conducted a DU investigation that didnít find anything. Mr. Hugus recommended that future interviews include a specific question about DU.

Mr. Hugus also said that the interview summary notes that companies based in Hanover and Wilmington brought their ordnance and explosive material to MMR for disposal. He stated that he doesnít think Cape Cod deserves to be a dumpsite for private defense contractors, and as a resident of Cape Cod, he resents that that occurred. Mr. Hugus also said that he thinks itís worth mentioning that one interviewee reported that 4960 pounds of explosives were disposed at Demolition Area 1 in one event, which indicates the kind of dumping that occurred there, making Demolition Area 1 one of the worst sites on the base.

Mr. Borci noted that every measure has been taken to keep the names of the interviewees confidential. He also said that individuals wanting to share information do not have to go through the formal interview process, and are encouraged to speak to anyone at the Guard, EPA, or DEP, with the assurance that they will remain anonymous. He explained that the idea is to gather as much information as possible so that good decisions can be made with respect to locating a monitoring well, for example, thereby potentially saving money at a particular site. Mr. Borci also said that while he wonít say whether he agrees with the cost of the ASR process to date, he does think that "the money is well spent when it comes to the end cost as far as the investigation." He also reiterated that anyone with information is encouraged to contact the Guard, EPA, or DEP.

Mr. Schlesinger asked about the possibility of providing some sort of reward to entice people to come forward with information. Ms. Adams replied that peopleís initial reticence about coming forward has been addressed by ensuring their anonymity and protecting their privacy. She said that she thinks that itís highly unlikely that individuals would be paid for their information.

Mr. Judge said that he thinks that when the interview process began, it was "a little bit too loose" and led to the search of someoneís home; therefore, he is very appreciative of everyone who comes forward to provide information. Mr. Judge also indicated that his experience with the 1100 mortars that were found behind a school in Sandwich leads him to believe that the archive search is a waste of time. He explained that some microfilm located in Washington, D.C. was supposed to have identified those mortars, but it seemed to him that that microfilm couldnít be located when it was convenient for the military for it to be lost. Mr. Judge also said that everyone he knows whoís worked on the base or had anything to do with firing at the base, says that everything was marked, identified, and documented Ė therefore, the interviews shouldnít be necessary. He noted that heíd like to get a hold of that documented information, but that seems to be very difficult to do.

Mr. Judge also inquired about burning of propellant bags from the Navy. MAJ Myer replied that a variety of different burning activities associated with propellant occurred at the base, including burning of propellant bags for artillery charges, burning of propellant bags for mortar, and burning of propellant left over from rocket motors on the defense contractor ranges. Mr. Judge stated that heís heard from more than one person that at times piles of propellant bags from the Navy "were as big as a house," and they were burned.

Mr. Judge then stated that if thereís been another mention of even the possibility of DU at the base, he thinks the Guard needs to "bend over backwards" to investigate that. MAJ Myer noted that a radiological survey was conducted at the J-3 Range. Mr. Judge noted that that involved handheld instruments, and he thinks that an air mag survey should be conducted in order to get a broader scan of the area. He also mentioned that the interview summary notes that a Textron employee said that that company never buried anything at the base; therefore, he finds suspect Textronís statement about being "pretty sure" that all nine warheads were removed from the base. Mr. Judge concluded by saying that heís concerned about DU and would like to see more investigation done.

Agenda Item #6. Open Discussion/Other Issues

EPAís Response to Secure DoD Commitment to "Make the Cape Whole"

Ms. Adams stated that EPA is still waiting for DoD to provide an update on its plans for "making the Cape whole." She also noted that in the next couple weeks EPAís regional administrator will be meeting with Mr. Fatz and Mr. Woodley, at which time EPA hopes to learn more about DoDís plans to "make the Cape whole." At the same time, EPA is looking into doing some initial coordination with respect to developing a Safe Drinking Water Act (SDWA) order, if in fact that turns out to be necessary. Nevertheless, EPA first wants to hear what DoD has to say.

Ms. Hayes inquired about the gentlemen who would be attending the meeting that Ms. Adams mentioned. Mr. Gregson noted that Mr. Fatz is the Deputy Assistant Secretary of the Army for Environmental Safety and Occupational Health, Mr. Woodley is the Assistant Undersecretary of Defense for Installations and Environment, and Mr. Varney is the EPA regional administrator.

Mr. Hugus asked about the date of the meeting. Ms. Adams replied that she believes the meeting is scheduled to occur on December 17, 2002. Mr. Hugus said that he thinks it would be appropriate for Mr. Varney to attend an IART meeting in order to hear the teamís "side of the story," especially since the citizen members of the team originally invited DoD to talk about its plan for making up lost water supplies. He asked Ms. Adams to pass along the request for Mr. Varney to address the IART. Ms. Adams agreed to do so.

Demo Area 1 Schedule

Mr. Gregson stated that IART members were provided with the Rapid Response Action/Release Abatement Measure (RRA/RAM) schedules for Demolition Area 1. He noted that the presentation and posterboard session on Demolition Area 1 groundwater is scheduled to occur at the January 28, 2003 IART meeting, and will begin a 15-day public comment period. The presentation and posterboard session on Demolition Area 1 soil is scheduled to occur at the February 23, 2003 IART meeting, and also will begin a 15-day public comment period.

Army Audit of the Groundwater Program Office

Mr. Hugus asked whether the NGB is going to be replaced by the Army with respect to the cleanup project. Mr. Gregson replied that the NGB is a respondent under the AO, thatís not going to change, and the people from the GWP office are still going to be on the job.

Mr. Hugus said that he found the Army audit of the GWP to include many "disturbing recommendations." He noted that the audit found that too much money was being spent on the cleanup program and recommendations for remedying that problem included having the Army replace the NGB, and reorganizing the structure of the program such that the Department of the Army would have the final say about "what gets done." Mr. Hugus said that to him this means that DoD wants priority over EPA and its authority under the SDWA for the study. He also said that he assumes that DoD wants this power in order to save money and "maybe not get to our cleanup." He further noted that he thinks that DoD is making a very serious proposal that threatens all the cleanup work thatís being done.

Mr. Schlesinger said that he agrees with everything Mr. Hugus just said. He also asked the GWP to provide a copy of the Army audit. Mr. Gregson noted that an executive summary of the document was provided, and added that it is a public document. Mr. Schlesinger said that he was unable to gain access to the document through the DoD web site. Mr. Murphy said that the GWP could look into whether the complete Army audit document is in fact accessible to the public.

Mr. Borci stated that before EPA saw the audit, it received a letter from DoD requesting that EPA name the Army as principal respondent under the AOs, and the Army would in turn put the Army Environmental Center (AEC) in charge of the GWP. He noted that EPA wrote back to DoD stating that the NGB is the appropriate principal respondent and would remain so. Since that time, EPA has seen the Army audit and now understands where that request originated. Mr. Borci also stated that EPA does not agree with many of the recommendations in the audit report. He said that EPA agrees somewhat with some of the conclusions, but on balance does not agree with the audit.

Ms. Pepin asked whether similar audits are conducted at other bases around the country. She also asked whether the auditors came to any public meetings or read the meeting minutes. Mr. Gregson replied that the audit was conducted by the Army Audit Agency, whose job is to look at how the Army is spending money on a variety of different projects, including environmental cleanups, and ensure that they are being conducted in a fiscally responsible manner. He noted that a team of three or four people from the Army Audit Agency came to the GWP office, attended one of the technical meetings, attended an IART meeting, interviewed individuals at the GWP office, interviewed individuals at the Massachusetts Army National Guard headquarters in Milford, and reviewed some documents and web sites.

Mr. Judge asked whether the team from the Army Audit Agency spoke with any members of the general public as part of their work. Mr. Gregson replied that while he canít answer that question specifically, he can say that the auditors focused on the internal workings of the GWPís organization and so they werenít necessarily auditing public opinion of the project. Rather, the auditors were interested in how the NGB was conducting its business and spending its resources in conducting the investigation.

Dr. Feigenbaum said that it seems to him that the audit was an "in-house job," given that Major General (MG) Van Antwerp requested that the audit be conducted, and then the conclusion from the audit was that MG Van Antwerp should take over the management of the cleanup project. Dr. Feigenbaum also said that since that time, MG Van Antwerp has commissioned a study of the effects of artillery training and mortar training on groundwater, saying that because this type of training has been stopped at MMR, it may be stopped elsewhere, and the Army needs to have data that combat the regulatory agencies and the public. Dr. Feigenbaum noted that MG Van Antwerp doesnít mention the data on groundwater contamination that have already been gathered at MMR, but has "requested the outcome of the study to be known before the study is done." Dr. Feigenbaum also remarked that in his opinion the Army can conduct whatever internal audits it wants, but "it doesnít go to the authority of the EPA under the Safe Drinking Water Act."

Mr. Schlesinger noted that the article provided to the IART tonight regarding the audit report states that "DoD has asserted its plans to take no action on perchlorate contamination unless forced to by regulators." He then asked if that statement is correct. Mr. Gregson noted that the article references a previous draft DoD policy on perchlorate investigation and sampling, the gist of which is that perchlorate sampling and follow-on actions should be conducted in the presence of a regulatory driver. He also explained that the perchlorate investigation work being done at MMR has led to requests by citizens and regulators for other military bases to conduct investigations as response actions for perchlorate. The DoD draft policy was a response and a guidance to other facilities on how to deal with and respond appropriately to those types of requests.

Mr. Schlesinger asked if the regulators plan to force DoD to take action on perchlorate contamination. Mr. Borci replied that this a site-specific issue, "and here at MMR, itís not an issue." He noted that cleanup plans are on the table and theyíll be presented at the next IART meeting.

New IART Member

Mr. Murphy said that Ms. Hayes asked him to update the team on the status of Bob Mullenixís request to become a member of the IART. Mr. Murphy stated that he hasnít yet heard back from EPAís regional administrator on this issue, but hopes to hear from him this week.

Ms. Hayes said that sheíd like Mr. Varney to know that she thinks that this process is taking "an inordinate length of time," and she suggested that perhaps Mr. Varney should attend IART meetings occasionally. Ms. Hayes also commented that to the best of her knowledge, Mr. Mullenix would be the only community member from Bourne, a town thatís affected by many base-related issues. She said that she thinks Mr. Mullenix would be a very valuable addition to the IART.

Mr. Mullenix took this opportunity to reintroduce himself to the team. He noted that heís been a resident of Bourne for 11 years and gets his water from the Bourne Water District. He also told the team that he has a Bachelor of Science degree in chemical engineering from the University of Florida and a Masters of Science degree in environmental engineering from the University of North Carolina School of Public Health in Chapel Hill, and his specialty is water resources engineering. Mr. Mullenix further noted that he works in the environmental engineering field and has been the environmental manager for Ocean Spray Cranberries for the past ten years. Mr. Mullenix said that he would like to be a member of the IART and he thinks that he has much to offer from a technical standpoint because heís been involved in a number of different cleanups. He also noted that heís knowledgeable about perchlorate because of work thatís been done in the western part of the country.

Mr. Mullenix also noted that it was September 2002 when it was indicated that Mr. Varney would review his membership application and the teamís comments and then come forward with a decision in October. He said that it is now December, and while he knows that Mr. Varney is very busy, he would like to formally request that his membership application be included on the agenda when Mr. Murphy meets with Mr. Varney this Thursday to update him on MMR activities, after which heíd like Mr. Murphy to come back with Mr. Varneyís decision as to whether or not he should be a member of the team.

Mr. Judge noted that it was a little over four months from the time he applied to be a member of the team to the time he was accepted. Ms. Pepin noted that the process for her membership took a couple months. Mr. Schlesinger encouraged Mr. Mullenix to attend and offer his opinions at IART meetings while waiting for "the bureaucracy to move."

Ms. Garcia-Surette stated that the DEPís Bureau of Waste Site Cleanup in Lakeville positively endorses Mr. Mullenixís request to be part of the IART. She said that she wants this to go on record "as a positive affirmation of our spirit for balance and different points of view and diversity and ideas," which she believes all works toward the common goal that everyone at the IART has.

Mr. Judge noted that his previously submitted written comments regarding Mr. Mullenixís request for IART membership still stand.

Review Action Items

Because the meeting was running late, Mr. Murphy decided to forego the review of action items.

Statement from LTC Cunha

LTC Cunha stated that something he sensed tonight "on many different sides was a little bit of frustration," which he thinks is in part due to the holidays, and in part due to being a member of the IART for "seven or eight years, and wondering where youíre going and how youíre getting there." He also noted that IART meetings are only four weeks apart, and sometimes a great deal needs to be done in those four weeks.

LTC Cunha then stated that his participation on the IART and the Senior Management Board (SMB), as well as his attendance at Community Advisory Council (CAC) meetings, has taught him about the concern that everyone has, and he knows that he is responsible for ensuring that todayís soldiers are trained well and in a responsible way. He said that he wants to be sure that everyone understands that this responsibility is foremost to him and his staff. LTC Cunha added that while he doesnít think that all the past mistakes that were made were intentional, mistakes were made, and the military is working very hard today to ensure that they arenít repeated.

LTC Cunha then said that attending IART, SMB, CAC, and Science Advisory Board (SAC) meetings has provided him with the opportunity to hear from concerned citizens, and he believes that they want whatís best for their community, and he senses their frustration. He also noted, however, that he knows how hard Mr. Gregson works, as do EPA and DEP. LTC Cunha then told the team that last Thursday, when the base was closed at 1:00 p.m. because of a record snowstorm, DEP, EPA, and GWP staff "just wouldnít leave" the base, but rather "stayed and they worked and they worked and they worked because they were trying to solve some problems."

LTC Cunha explained that he just wanted to let everyone know that although it might not always seem so, "everybody is working as hard as they can." He then concluded by saying, "from all of us on the base we wish you all a happy holiday, and look forward to January."

Agenda Item #7. Adjourn

Mr. Murphy stated that the IART would meet next on January 28, 2003 at a location to be determined. He then adjourned the meeting at 9:10 p.m.

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