Impact Area Review Team
Handouts Distributed at Meeting:
Agenda Item #1. Welcome, Approval of January 22, 2002 Meeting Minutes, Review Draft Agenda
Mr. Murphy convened the meeting at 6:05 p.m. and the Impact Area Review Team (IART) members introduced themselves. Mr. Murphy asked if there were any comments on the January 22, 2002 IART meeting minutes. No comments were offered and the minutes were approved as written.
Mr. Hugus asked that an update on the Demo Area 1 plume be added to tonightís agenda under "Open Discussion." Mr. Murphy added this item to the agenda and noted that a handout on the Demo Area 1 plume was provided to team members. He also reviewed the remainder of the agenda.
Agenda Item #2. Review Action Items
Mr. Murphy asked if there were any questions regarding the responses to action items from the January 22, 2002 IART meeting.
Mr. Hugus referred to Action Item #7 and asked when the team could expect to see test results from monitoring well 181 (MW-181). Mr. Gregson replied that he expects that results will be available in time to present them at the March IART meeting.
Mr. Hugus referred to Action Item #8 and asked if drilling grease is the entire answer to the question of the presence of petroleum-like material (PLM) in some wells. Mr. Gregson replied that this is not the entire answer, and noted that the PLM in MW-164 is not answered by the cross-contamination issue, and more information is needed regarding that detection. Mr. Grant of AMEC clarified that the drill rig itself was not the source of the PLM; rather, it appears that the drill rig transferred the PLM from MW-164, where it was first encountered, to the next two holes that were drilled.
Agenda Item #3. Late-Breaking News
Mr. Gregson stated that the late-breaking news that he has to share with the team will be included in the "Bourne-Field Wells" item later in the meeting.
Agenda Item #4. Investigations Update
Mr. Gregson referred to the map and explained that yellow stars represent recent detections in monitoring wells below health advisories, red stars represent recent detections in monitoring wells above health advisories, yellow circles represent profile sample detections below health advisories, and red circles represent profile sample detections above health advisories.
Mr. Gregson reviewed recent detections at the Central Impact Area. He reported a 0.5 parts per billion (ppb) perchlorate detection at MW-85M1, which is located at the intersection of Turpentine Road and Tank Alley; a 0.5-ppb perchlorate detection in the shallow screen and a 0.8-ppb perchlorate detection in the middle screen of MW-90, which is located north of MW-85M1; and a 0.4-ppb perchlorate detection at MW-108, which is located on Burgoyne Road. He also reported a 22.6-ppb Royal Demolition Explosive (RDX) detection and a 0.85 High Melting Explosive (HMX) detection at MW-184, one of the wells installed as part of the delineation effort for the Central Impact Area RDX plume. Mr. Gregson reminded the team that the health advisory for HMX is 400 ppb and the health advisory for RDX is 2 ppb.
Mr. Gregson said that the Impact Area Groundwater Study Program (IAGWSP) has been sampling some existing Air Force Center for Environmental Excellence (AFCEE) monitoring wells at Chemical Spill 19 (CS-19) in the Impact Area. He noted that there have been a number of perchlorate detections there, both validated and unvalidated, that range from 0.37 ppb to 1.39 ppb, all of which are below the current U.S. Environmental Protection Agency (EPA) limit of 1.5 ppb, which the IAGWSP is working with in for its feasibility studies.
Mr. Hugus stated that he is glad to see a spirit of cooperation between AFCEE and the IAGWSP in that AFCEE is allowing sampling of its CS-19 wells.
Mr. Gregson reviewed detections at the Southeast Ranges, which also are known as the J Ranges. He referred to MW-187 and MW-191, and noted that they are located at the J-1 Range cook-off test area. He then reported a 1.4-ppb RDX detection and a 3-ppb HMX detection at one of the middle screens of MW-191, and a 2.12-ppb RDX detection and a 7.7-ppb HMX detection at another one of the middle screens of MW-191.
Mr. Gregson then reported below-health advisory level detections of 0.8 ppb RDX and 0.4 ppb HMX at the middle screen of MW-187. He also noted that in MW-187ís deep screen, which is 200 to 210 feet below the water table, there was a 0.3-ppb RDX detection, as well as detections of benzene, toluene, ethyl benzene, xylene, chloromethane, and naphthalene, which are compounds typically associated with petroleum. He reported that the benzene was detected at 1000 ppb, the chloromethane was detected at 75 ppb, and the naphthalene was detected at 43 ppb.
Mr. Gregson stated that a particle backtrack from that location tracks farther up on the J-1Range to the center of the mound area. He indicated that an explanation for the detections at that deep screen, which is just above bedrock, is that groundwater flow dives deep near the top of the mound and then spreads out as it gets down to the bottom. Mr. Gregson also confirmed that the maximum contaminant level (MCL) for benzene is 5 ppb, for chloromethane it is 3 ppb, and for naphthalene it is 100 ppb. Dr. Feigenbaum inquired about the direction of groundwater flow in that area. Mr. Gregson replied that the direction of groundwater flow at that spot is off toward the northwest.
Mr. Gregson continued his review of recent detections at the Southeast Ranges by referring to the shallow screen of MW-196, located at the melt/pour building on the J-3 Range. He reported the following detections there: trinitrotoluene (TNT) at 11.8 ppb, which is above the health advisory of 2 ppb; 2A-dinitrotoluene (2A-DNT) at 0.92 ppb; 4A-DNT at 0.66 ppb, HMX at 43.9 ppb, and 1,3,5-trinitrobenzene at 0.3 ppb.
Mr. Gregson then stated that in the third round of sampling at MW-157, which is located south of the J-3 wetland, perchlorate was detected at 0.5 ppb. He indicated that previous nondetects for perchlorate in that well could have to do with the fact that over the past six months the detection limit for perchlorate has gone from 2 ppb down to 0.35 ppb. He also noted that MW-157 is located along a forward particle track from MW-22 where there have been detections of perchlorate up to 2 ppb.
Mr. Hugus suggested that a line should be drawn on maps to connect the perchlorate detections at these two wells. Mr. Gregson replied that the investigation is ongoing, more wells are being installed in the area, and he will try to keep the team updated on possible connections as the investigation proceeds. Ms. Dolan told Mr. Hugus that preliminary plume maps for RDX, HMX, and perchlorate can be found in a document called "J Ranges Additional Delineation Workplan Number 2."
Mr. Hugus asked if the perchlorate detection in the drive-point off the spit at Snake Pond could be related to the perchlorate detections at MW-157 and MW-22. Mr. Gregson replied that the detection near the spit is so shallow that itís unlikely that itís connected to a deeper groundwater plume. He also noted that this question is something that the IAGWSP will try to answer as part of the additional delineation workplan.
Mr. Hugus then asked if itís correct that perchlorate was used in the Minuteman missile systems that were tested at the J Ranges. Mr. Borci replied that he believes that the certain stage of the Minuteman propellant that was tested at the J-3 Range did contain perchlorate. Mr. Hugus remarked that he finds this interesting because it could have been a source of perchlorate that was disposed of in quantities.
MAJ Myer noted that, according to the Section 104E request from Textron, that company conducted self-destruct mechanism tests on sections of plywood mockup missiles, which were not associated with perchlorate. He added that Textron may have done some testing on propellants, but he does not recall that it did.
Mr. Hugus said that he thinks that investigation of the 1000-ppb benzene detection should be a high priority. He also asked it there could be any possible relationship between that detection and Fuel Spill 12 (FS-12). Mr. Gregson replied that the fuel pipeline ran along the other side of the mound; therefore, given the hydrology, itís unlikely that theyíre related.
Dr. Feigenbaum asked if the Textron narratives referred to any spills or dumping. Ms. Dolan replied that Textron had performed cook-off tests where fuels were used. She noted that witnesses also have referred to other contractors that performed similar tests that involved the use of fuels to ignite a mixture.
Dr. Feigenbaum inquired about the depth of the benzene detection. Mr. Gregson replied that the detection was at bedrock, which at that location is about 200 feet below the water table. He also said that Denis LeBlanc of the U.S. Geological Survey (USGS) had indicated that the unusual depth of the benzene detection is due to its proximity to the top of the mound. He said that Mr. LeBlanc had explained that water near the top of the mound is directed at an extremely high angle downward until it reaches bedrock.
Dr. Feigenbaum asked if any petroleum compounds were detected in soils in that area. Ms. Dolan replied that she thinks that petroleum compounds were not detected in soils there. Dr. Feigenbaum also asked if groundwater samples had been tested for ethylene dibromide (EDB). Mr. Gregson and Ms. Dolan both replied that they werenít sure. Dr. Feigenbaum said that heíd think that EDB testing would have been done. He also noted that EDB is much more stable in groundwater than benzene is.
Mr. Pinaud stated that some anomalies at the J-1 Range havenít yet been investigated, and itís possible that something buried out there might be just releasing. He noted that fuel degrades fairly rapidly, leaving behind components like EDB, which donít degrade rapidly. Therefore, he thinks that such a high concentration of benzene could have to do with either a huge release or one that occurred in the fairly recent past. Dr. Feigenbaum noted that a release that occurred in the recent past would be seen in the soil.
Ms. Dolan noted that, as part of the Central Impact Area investigation, within the next couple of months a well is going to be drilled at a location that happens to be directly downgradient from MW-187.
Mr. Gregson reported that after the benzene was detected, an additional sample was collected from MW-187 to analyze for a suite of analytes that included volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), and extractable petroleum hydrocarbons (EPH) and volatile petroleum hydrocarbons (VPH). A hydrocarbon finger-printing analysis also was done to determine how the sample compared to the PLM that was detected at the other well. Mr. Gregson stated that these results should be back soon.
Mr. Dow asked if dissolved oxygen (DO) levels were measured at the location of the deep benzene detection. Mr. Grant said that he believes that DO is a field parameter. Mr. Dow stated that depressed DO levels would indicate degradation and the existence of more contamination upgradient, whereas natural background levels of DO probably would indicate that the benzene moved down to that location rapidly, since thereís no microbial activity at that depth. Mr. Borci said that he believes that DO measurements were available, and that they were low and indicative of reducing conditions.
Mr. Borci also referred to the idea that the detection might be related to the FS-12 spill and said that sampling results from MW-45 donít match up to whatís being seen at MW-187. He further noted that trace levels of compounds n-nitrosodiphenylamine and di-n-butylphthalate, which seem to tie in with propellant and burning activities, also were detected at MW-187. Mr. Borci also mentioned that because the top of the mound is at the J Ranges any type of disposal activity there is cause for concern. He said that it makes some sense that benzene was detected in MW-187, and now it has to be tracked back and investigated further.
Ms. Grillo said that action items coming out of this discussion should be tracked to ensure that responses are provided.
Mr. Hugus stated that this topic should be included on next monthís IART meeting agenda. He also suggested that Mr. LeBlanc be invited to that meeting to tell the team more about the hydrogeology of the mound. Mr. Hugus added that he thinks thereís a definite need to follow up on this very serious benzene detection.
Dr. Feigenbaum requested that IART members receive an e-mail response to the question of whether or not thereís been testing for EDB.
Mr. Cambareri suggested that it might be beneficial for the team to see a rundown on the depths where fuel-like VOCs and SVOCs have been found.
Mr. Gregson continued with his presentation by discussing recent detections in other areas. He noted that the first three rounds of sampling at MW-33 and MW-36 in the Demo Area 1 plume were nondetect for perchlorate. However, the fourth round of sampling turned up unvalidated detections of perchlorate that are close to the EPA limit of 1.5 ppb Ė 1.4 ppb and 1.5 ppb at MW-33 and 2.2 ppb at MW-36. Mr. Gregson also stated that after two nondetect rounds, RDX was detected at 2.2 ppb during a third round of sampling at MW-160, which is located at the Demo Area 2 site.
Mr. Gregson also reviewed recent detections in profile samples from the Central Impact Area. He reported that at MW-201, which is located on Burgoyne Road, RDX was detected at four intervals at concentrations ranging from 0.27 to 3.8 ppb. In addition, 2,6-DNT was detected there at two intervals at concentrations ranging from 0.3 to 0.4 ppb. At MW-202 RDX was detected at two intervals at depths between 220 and 270 feet below ground surface; concentrations there ranged from 0.27 to 0.34 ppb. Also, at MW-205, which is located on Wood Road, RDX was detected at four intervals at concentrations ranging from 0.4 to 3.2 ppb.
Update on J Range Polygons
Mr. Gregson stated that an investigation being conducted at the Southeast Ranges involves excavating or interrogating magnetic anomalies in 64 different locations. He said that since the last IART meeting, two locations Ė #8 and #9 Ė have been investigated in the J-2 Range. He reported that the #8 site contained fuses, fuse components, inert 81-millimeter (mm) and 60-mm mortars, and assorted ordnance-related items. The #9 site contained 81-mm mortars. Mr. Gregson also noted that six other sites in that area are being excavated and characterized.
Agenda Item #5: High Use Target Area II
Scope of Work Objectives
MAJ Myer introduced himself as the Environmental Restoration Chief for the IAGWSP. He stated that the High Use Target Area (HUTA) II investigation is an additional investigation of HUTAs within the Central Impact Area, the purpose of which is to determine the nature and extent of explosive, chemical, and ordnance items. Data collected from the continued investigation work will be used to support the ongoing soil and unexploded ordnance (UXO) feasibility studies at the Central Impact Area.
MAJ Myer noted that the HUTA II investigation sites consist of five 200-meter-long by 7-meter-wide transects that are made up of 7-meter by 7-meter grids. He reported that the HUTA II investigation will involve determining the density drop-off rate of ordnance on and below ground surface moving out radially from the target; quantifying and cataloging UXO; analyzing contaminants on or below corroded, cracked, and/or leaking UXO items; and attempting to characterize contaminant distribution in the soils along the transects.
MAJ Myer showed a figure that depicts the five transects and pointed out the Impact Area boundaries, the J Ranges, and Five Corners, where the contained detonation chamber (CDC) is located. He also mentioned that as part of the HUTA II investigation, a schonstadt device is being used to reacquire or look for potential buried mass of metal.
MAJ Myer noted that the HUTA II investigation involves the same general areas of fieldwork as the first HUTA investigation did. However, some aspects of fieldwork in HUTA II have been revised based on lessons learned from the first investigation. He noted, for example, that 200-foot by 100-foot test pits were studied in the first investigation, and now the length of the transects has been narrowed. In addition, it was learned from the first investigation that most UXO were encountered at depths from about three to four feet. MAJ Myer noted that like the first investigation, the HUTA II investigation includes brush clearance, surface clearance, geophysical surveys, and chemical sampling.
Summary of Findings to date
MAJ Myer said that fieldwork at transects 1 and 5 has been completed. He reported that two UXO items were identified at transect 1, an area suspected to have historical targets from 1930 to 1950. One of the items was determined to be unsafe to move and underwent open detonation; the other item remains in place pending chemical analysis to determine whether it contains explosives or inert filler. Eight UXO items were identified at transect 5, a suspected target on the southwestern boundary of the Central Impact Area. Inert training rounds were also found at transect 5: fifty-five 81-mm mortars and seven 60-mm mortars. Seven of the eight UXO items were determined to be unsafe to move and underwent open detonation. The eighth item remains in place pending analytical results.
MAJ Myer then showed a video of transect 5 that was taped from a Black Hawk helicopter. He noted that a minimum amount of vegetation was removed and that the investigation hadnít required a lot of excavation work. He said that the lessons learned from the first HUTA investigation were applied, while allowing collection of data needed to support the HUTA II investigation.
MAJ Myer stated that the fieldwork at transects 2, 3, and 4 is ongoing, and to date two UXO items identified at transect 2 had to be blown in place. He also noted that transect 2, which is across from a visible target, is located near the northeastern boundary of the Central Impact Area. At transect 3, which is near the eastern boundary of the Central Impact Area, four UXO items were blown in place. At transect 4, which is near a sub-caliber aircraft rocket (SCAR) range, seven UXO items were blown in place. MAJ Myer reminded the team that fieldwork at these transects continues and more UXO items could be found.
MAJ Myer noted that work in progress includes quality control of fieldwork at transects 1 and 5, analysis of chemical data from soil samples at all transects, and continuation of fieldwork at transects 2, 3, and 4, which is scheduled to be completed by April 5, 2002. He also mentioned that rather than one large report like the one submitted for the first HUTA investigation, individual technical memos on each of the transects will be submitted to the regulators for review.
MAJ Myer concluded his presentation by showing a photograph of a 105-mm heat round, taken by Tetra Tech as part of its process to catalog UXO items. He then asked if there were any questions from the team.
Mr. Hugus urged the Guard to secure the thermal neutron analysis (TNA) device as soon as possible in order to avoid unnecessary blow-in-place (BIP) events and associated soil contamination. MAJ Myer stated that post-detonation soil sampling does not always yield detections of contaminant. Mr. Hugus expressed surprise that soil removal is not routinely done after each BIP, given that they are known to cause contamination. MAJ Myer assured him that analytical results indicate that not all craters contain residual explosives. However, soil is removed when residual explosives are detected.
MAJ Myer also stated that items determined to be unsafe to move can not be put into the TNA device. He explained that a safe-to-move item actually is inserted into the device, which bombards the item with neutron energy, and then indicates whether the item contains explosives, phosphorus, or inert wax filler. Mr. Hugus noted that the purpose of the TNA device is then just to determine whether an item needs to be put into the CDC. MAJ Myer agreed.
Mr. Hugus also questioned why intensive investigation is happening only at defined transects. MAJ Myer said that that the purpose of the HUTA II investigation is to collect enough data to support the soil feasibility study for the Central Impact Area, as well as the UXO feasibility study. He explained that transects are being used in order to learn how far from targets ordnance would be found, and to understand the soil contaminant distribution for explosives away from a target. MAJ Myer also noted that the targets are located in the center of the transects. Mr. Borci added that some of the transect locations were chosen based on air magnetometry survey data.
Mr. Borci then referred to the issue of BIPs and noted that the Guard has done some work to lower the detection limit method. He said that up until June 2000 post-detonation detections were seen about 50% of the time, and it will be interesting to see if the lower detection limit affects that number. He also noted that if the spotting charge on an inert mortar round hadnít gone off, it is not safe to move.
Dr. Feigenbaum asked if the TNA device could be redesigned so that it could be used on items determined to be unsafe to move. MAJ Myer replied that this possibility is being explored and may become a reality in the future. However, for the time being, the off-the-shelf technology is going to be used for safe-to-move items. Dr. Feigenbaum asked for assurance that a redesigned device is being actively pursued. MAJ Myer replied that his office is working with Nick Iaiennaro at the U.S Army Corps of Engineers to evaluate all available information that might help in better management of UXO items encountered during investigation.
Dr. Feigenbaum asked how the neutrons in the TNA device are generated. MAJ Myer replied that a Californium source generates the neutrons. He also noted that a detailed technical explanation that answers this question is included in the "Response to Action Items" document available at tonightís meeting.
Mr. Hugus asked if there is a typical charge thatís used for BIPs. Mr. Borci said that he believes itís a shape-charge RDX that has a copper liner. Mr. Hugus questioned why each BIP wouldnít then leave the same amount of explosive residue Ė unless the item itself contained explosives. Mr. Borci replied that there are different theories on that, including weather conditions and the way the charge was physically set by a person. He noted that data are being collected and an effort is being made to come up with some explanation.
Agenda Item #6. Update on J-1 Range Polygon #1
Mr. Borci noted that this item was inadvertently missed during the "Update on J Range Polygons." He then reported that 1600 to 1700 items have been pulled out of polygon #1 at the J-1 Range. Over 1400 of the mortars are inert and are being staged. Unfortunately, however, itís not possible to identify the content of some of the rounds that were remotely pulled out; therefore several BIP detonations are upcoming, and about nine detonations already have occurred. Mr. Borci stated that polygon #1 is one of the larger disposal areas found at the J Ranges so far. He also noted that the batch found there included mostly 81-mm mortars, but also 105-mm rounds, several of which were blown in place because they were considered high explosive.
Dr. Feigenbaum commented that the BIPs are occurring nearby to the adjacent neighborhood. Mr. Borci noted that a protective sandbag/plywood system was constructed and set up between that area and the neighborhood. He also noted that the Sandwich protocol dictates that detonations occur only during certain hours.
Mr. Borci also mentioned that there are instances where some of the mortars appear to have been burned, and those are absolutely unsafe to move anywhere. Dr. Feigenbaum said that he has heard that it might be necessary to blow in place up to 400 items. Mr. Borci replied that he believes that, at this time, that number is 60 to 70.
Ms. Dolen noted that in addition to notifying the Town of Sandwich selectmen and town administrator, her office hand-delivers notices to residents in neighborhoods adjacent to any area that triggers the notification protocol. She also mentioned that schoolchildren in that area are provided with notices to take home to their parents.
Mr. Hugus expressed concern about air contamination resulting from the detonations. Mr. Borci explained that the rounds are being remotely pulled by rope into a trench, where shape charges are attached, and the rounds are then covered with sandbags. The detonation essentially is tamped and there are no air emissions. Mr. Borci also noted that it wouldnít be possible to get sampling equipment close enough to the detonation to detect anything. However, pre- and post-detonation soil sampling is conducted.
Mr. Murphy announced the beginning of a ten-minute break.
Agenda Item #6. Bourne Far-Field Wells
Mr. Gregson showed a map and pointed out the Bourne water supply wells, the Bourne sentinel wells, and the Bourne far-field wells. He stated that the water supply wells have consistently tested nondetect for explosives and perchlorate. However, while last October the sentinel wells tested nondetect for perchlorate, in the most recent sampling event low levels of perchlorate were detected in three of those four wells. Also, there have been detections of perchlorate in the deep screen at far-field well MW-80, and a 2,6-DNT detection at MW-84, the southernmost far-field well.
Mr. Gregson stated that one key question to answer tonight is whether the water from the supply wells is safe, and the answer to that is yes. He noted that the supply wells were last sampled on January 30, 2002 and will be sampled again this week. He also reported that perchlorate detections in the sentinel wells have been validated and are: 0.45 ppb at well 97-1, 0.5 ppb at 97-2, and 0.74 ppb in 97-4. Well 97-3 was nondetect.
Mr. Gregson noted that the method detection limit for perchlorate is 0.35 ppb, and the values at the sentinel wells are estimated or "J" values because they are below the method laboratory reporting limit of 2 ppb. He also said that the increasing number of perchlorate detections has to do with the lower detection limit of 0.35 ppb, which last year at this time was close to 2 ppb.
Mr. Gregson stated that perchlorate is a salt thatís used in rocket propellant as ammonium perchlorate. From a risk or health standpoint, perchlorate interferes with normal thyroid function. He also noted that the IAGWSP is using a 1.5-ppb perchlorate limit to assess remediation technologies as part of the feasibility study process. Nationwide, perchlorate drinking water levels have been set between 4 and 18 ppb. Also, as mentioned at the last IART meeting, EPA has come out with some extensive toxicity information, currently out for public comment, that would lower the safe exposure level to 1 ppb.
Mr. Gregson then reviewed the history of detections at MW-80. In August 2000 the well tested nondetect for perchlorate with a method detection limit of 1.5 ppb. In August 2001, there was a 1.7 ppb perchlorate detection, also with a method detection limit of 1.5 ppb; a duplicate sample at that time was nondetect. In October 2001, MW-80 had a 1.5 ppb perchlorate detection with a method detection limit of 0.85 ppb. And in December 2001, there was a 1.6 ppb perchlorate detection with a method detection limit of 0.35 ppb. Analyses for explosives at MW-80 were nondetect for all rounds.
Mr. Gregson reviewed the history of detections at MW-84. He stated that the middle screen of the well tested nondetect in November 1999, March 2000, July 2000, and August 2000. A sampling round conducted on August 24, 2001 showed a 0.27 ppb detection of 2,6-DNT in the middle screen, and last Decemberís sampling was nondetect for that screen. A similar pattern of detections occurred in the deep screen: four rounds of nondetect, followed by a 1.9 ppb 2,6-DNT detection, and another round of nondetect.
Mr. Gregson also reported that Bourneís production wells were sampled for explosives on eight occasions between August 1999 and October 2001 and were nondetect for all rounds. They were sampled for perchlorate on two occasions Ė October 2001 and January 2002 Ė and results were nondetect both times.
Mr. Gregson stated that the four sentinel wells were sampled and analyzed for explosives once in 1997 and twice in 1999 and all results were nondetect. The sentinel wells were sampled for perchlorate in October 2001 and results then were nondetect. It was the most recent sampling event, on February 12, 2002, that showed detections of perchlorate in three of the four sentinel wells.
Mr. Gregson reported that over the past couple of weeks his office has met with the Bourne Water Districtís Ralph Marks and his consultant on three separate occasions, and engaged in several telephone conversations with them to discuss monitoring results and plan next steps. In addition, a meeting that was attended by representatives of the Bourne Water District, the Massachusetts Department of Environmental Protection (DEP) Division of Water Supply, EPA, and the Guard took place this afternoon to determine next steps that need to be taken.
Mr. Gregson then reviewed next steps, as follows: immediately resample all the production wells and sentinel wells to see if perchlorate detections in the sentinel wells are repeated; resample far-field wells MW-80, MW-81, and MW-82 at all five screen levels in each well; sample four additional monitoring wells in the vicinity of the sentinel wells; sample water supply well WS-4, one of the Upper Cape Water Supply project wells, which is to the north; and complete some additional groundwater modeling particle tracking to look for a potential source area. Mr. Gregson further noted that this Friday the Guard will be meeting with the Bourne Water Districtís consultants and the regulators to look at locations for additional monitoring wells. He said that the Guard believes that itís important to move quickly, define the extent of perchlorate contamination in this area, and base future actions on whatís found in that investigation.
Mr. Pinaud stated that detections of perchlorate in the Bourne sentinel wells is of great concern to DEP, which today insisted that the Guard provide an aggressive plan and schedule for addressing the contaminant in the sentry wells and further delineating perchlorate in the groundwater. He said that DEP will be looking for some kind of a plan to review by the end of this week.
Mr. Hugus inquired about public notification regarding the perchlorate detections. Ms. Dolen stated that the first step taken was to inform the Bourne Water District. She also reported that the Bourne selectmen have been notified, as have the IART members and audience at this meeting. She noted that on Thursday she will be meeting with representatives from DEP and EPA as well as IAGSWP community involvement staff to lay out a Notification Protocol similar to the Sandwich Notification Protocol, but which will address this particular incident and any others like it that may occur. Mr. Gregson added that the perchlorate detections will be discussed at tomorrow nightís Senior Management Board (SMB) meeting. Ms. Dolen also mentioned that her office will work with the media to ensure that the information is made public in a full and timely fashion.
Mr. Hugus said that because the Bourne sentinel wells werenít tested for perchlorate until October 2001, it really isnít known whether perchlorate had affected them prior to that date. He also said that he thinks itís quite clear that the perchlorate will reach the Bourne supply wells unless a fast treatment system is put in place. He asked what the Town of Bourneís plans are for the supply wells once the perchlorate reaches them.
Mr. Gregson noted that while this is new information, the Guard will be working with the Bourne Water District to look at all the options. He acknowledged that the situation is one where itís necessary to act quickly and come up with viable options. Mr. Gregson also stated that the Guard has offered to sample the Bourne production wells on a monthly basis to build that database.
Mr. Hugus asked if itís correct that EPA is using a limit of 1 ppb for perchlorate. Mr. Borci explained that the EPA guidance reference dose number was used to calculate the 1.5 ppb value that the Guard currently is using for its feasibility study evaluations. Since that time, EPA has put out revised toxicity data that recommend a 1 ppb value as the health advisory or maximum contaminant level for perchlorate. Once this undergoes the peer review process, EPA will make a determination, regionally, as to whether or not to use that 1ppb limit.
Mr. Hugus questioned what would happen if perchlorate levels in the range of 0.74 ppb were detected in the production wells. Ms. Garcia-Surette said that she thinks that before this very hard question can be answered, the plan that was discussed at todayís meeting needs to be set in motion. This includes assessing the contamination, resampling the wells as soon as possible, and moving forward the notification protocol project.
Mr. Murphy noted that the Notification Protocol is still a draft item that the team members havenít seen yet. Ms. Dolen explained that the protocol begins with the identification of a triggering mechanism, such as the detection of a certain level of perchlorate, for instance, in a well thatís part of a public water supply or is in the zone of contribution for a public water supply, and then outlines next steps to take with respect to notification.
Mr. Dow asked how much of Bourneís water is supplied by the production wells downgradient from the perchlorate detections. Mr. Marks of the Bourne Water District replied that the Monument Beach wellfield currently provides 65% to 70% of the water supply. Mr. Dow asked if the newly-established Upper Cape Water Supply Cooperative could produce enough capacity to provide that much water, should perchlorate reach the Bourne supply wells. Mr. Gregson replied that this is option will be considered. He also noted that currently there is no pipeline from that water supply system to the Town of Bourne.
Dr. Feigenbaum asked why the team hadnít heard about perchlorate detections in the far-field well prior to this meeting. Mr. Gregson said that he believes that the team was briefed on those detections. Mr. Borci agreed that the team was presented with the information at one or more IART meetings. Dr. Feigenbaum remarked that this was important information that should have been presented with great emphasis.
Dr. Feigenbaum then said that heís sure that Mr. Marks knows that activated carbon doesnít do anything for perchlorate. He also said that he thinks that Mr. Marks would want to be as protective as possible, keeping in mind that EPA has proposed a 1 ppb limit for perchlorate. He further noted that, as heís mentioned many times before, there are no error bars associated with reported detection levels.
Dr. Feigenbaum went on to say that the Town of Bourne is confronted with a situation where a dangerous level of perchlorate is impinging upon its production wells, and he thinks that tomorrow nightís presentation of this information to the SMB should come not only from Mr. Gregson, but also should include a statement from the regulators to emphasize that danger.
Mr. Cambareri inquired about the length of the screens in the sentinel wells. Mr. Gregson replied that there is one screen per well, and they measure 5 to 10 feet in length. He also noted that the detections there were relatively shallow Ė at around 30 feet below the water table in one well, with the deepest detection around 80 feet below the water table at another well. He added that in the wellfield bedrock is relatively shallow, about 100 feet below ground surface.
Mr. Hugus asked who would make the decision regarding whether to continue using the Bourne supply wells. Mr. Pinaud replied that he believes that several agencies would play a role in that decision, including the Massachusetts Department of Public Health (MDPH), DEP, EPA, the Town of Bourne, and the Bourne Water District. Mr. Hugus said that he too recommends that this information be presented to the SMB with the appropriate emphasis because itís a very important public health issue.
Mr. Cambareri said that he thinks it would be good to revisit the protocol for disseminating information about detections in the far-field wells. Mr. Gregson noted that DEP has asked the Guard to develop a method to routinely report detections within zones of contribution of water supply wells. He said that although these data have been included in the monthly report, it will be easier for the water suppliers to focus on them when theyíre reported separately. Mr. Cambareri suggested that it would make sense to have reciprocal reporting of detections back and forth between the Upper Cape Water Cooperative and the IAGWSP office.
Ms. Dolen stated that the Notification Protocol thatís under development, which is similar to the IRP Notification Protocol thatís been in effect for many years, lays out a series of possible scenarios and subsequent notification procedures to follow. She said that 13 or 14 specific plans are expected to come out of the Notification Protocol document.
Agenda Item #7. Open Discussion/Other Issues
Prescribed Burn Permit
Mr. Gregson announced that a week ago DEP issued a permit to the Guard to conduct prescribed burns for natural resources and habitat management. The Guard will be looking at the specific requirements of the permit and working them into the Integrated Natural Resources Management Plan (INRMP), and will be coordinating with the local communities and fire departments to put the plan into place. Mr. Gregson said that at future meetings the Guard will brief the IART as to specific areas on the Massachusetts Military Reservation (MMR) that are targeted for prescribed burns.
Mr. Pinaud noted that the permit entails a five-year burn plan, the primary purpose of which is ecological management and wild land fuel hazard reduction, and the secondary purpose of which is wildfire suppression and fire training. Conditions stipulated in the permit are that no burns shall occur between July 1 and September 15 of each year, the total acreage that can be burned each year is limited to 600 acres, and the Guard is obligated to notify DEP by letter regarding its intent to conduct a burn a minimum of 10 days but no more than 21 days in advance of the event, and then notify DEP again within 48 hours of the burn. In addition the Guard must notify the public through the media a minimum of one month before the prescribed burn, and again within 48 hours of the actual event.
Mr. Pinaud also noted that the permit contains a line item that speaks to coordination of prescribed burns with IAGWSP and IRP activities; it states that remedial activities shall take priority over scheduling conflicts that canít be resolved. In addition, the permit calls for yearly reporting of the results of each burn, due by January 15 of each year.
Mr. Hugus said that he thinks it should be noted that natural resources protection is not the only purpose of the prescribed burns, but that they also are conducted to facilitate military training at Camp Edwards. MAJ Magrini acknowledged Mr. Hugusís comment.
Mr. Cambareri asked if the request for the permit has been discussed with the newly formed Environmental Management Commission (EMC). Mr. Cody replied that the use of prescribed burns as a forest management technique is included in the Final Environmental Impact Report (FEIR) and the INRMP. He also clarified that the training associated with the burns pertains to nature conservancy people, who can then conduct prescribed fires at other locations, such as Shawme-Crowell forest. He said that there is no facilitation of military training associated with the burns. Mr. Cody also stated that the prescribed burns will be discussed with the EMC and the Citizens Advisory Council (CAC). Mr. Cambareri suggested that this would be a good topic for the EMCís March meeting agenda.
Mr. Hugus said that he believes that prescribed burns did in fact have a direct use for the military prior to 1997, when explosives were being blown up at the Impact Area. Mr. Cody clarified that compared to now, the need for prescribed burns was less when live firing was occurring at the base because the high explosives did cause fires that maintained the habitat. He noted that 25 of the 36 state-listed species live in the Impact Area, which is a fire ecology, and the species need the fire to survive so that higher canopies do not come in and take over the scrub oak and pitch pine environment. Mr. Cody also stated that the local town fire departments are very much on board with the Guardís implementation of the five-year permit.
Dr. Feigenbaum asked who made the decision regarding preventing higher canopies from coming in. Mr. Cody replied that the Guard worked with the Natural Heritage and Endangered Species Program and set goals in the FEIR and the INRMP to maintain a certain amount of scrub oak and pitch pine, which requires conducting prescribed burns.
Mr. Murphy asked if there is a mechanism for providing public comment on this issue. Dr. Feigenbaum said that he thinks there ought to be some kind of public hearings, given the air emissions caused by the fires and the high rate of lung cancer in this region.
Mr. Cody noted that the FEIR, for which many opportunities for public comment were provided, included extensive information about prescribed burning as a management technique. He also stated that the INRMP included an environmental assessment, and that document was reviewed by the regulatory agencies and was put out for public comment several times.
Dr. Feigenbaum remarked that one can not just assume that thereís no downside to the tremendous amount of smoke produced by these fires. Mr. Cody agreed and noted that Geographic Information System (GIS) capabilities are used to plot out the fires and track, depending on atmospheric conditions, where the plume will go, how high it will go, where it will come down, and so forth.
Dr. Feigenbaum questioned who is reviewing this work and the protocol concerning the direction of wind, for example. Mr. Cody replied that DEP had reviewed the Guardís permit request and the Guard also works closely with the Nature Conservancy. Mr. Pinaud confirmed that smoke management practices are included in the DEP permit.
Dr. Feigenbaum stated that he doesnít understand why the Guard has an interest in conducting prescribed burns. He said that the Guard is not a forest manager, and he thinks that these concerns should now be left up to those under state environmental auspices who are now involved with managing the base
Mr. Borci explained that information about the prescribed burns is being presented in this forum primarily to inform the team that the burns will not be allowed to throw off enforceable schedules pertaining to the cleanup.
Ms. Wadsworth introduced herself as the public affairs specialist with the Environmental & Readiness Center (E&RC) and noted that tomorrow Dr. Mike Chiaranca of her office and the Nature Conservancy will be attending an all-day seminar regarding the prescribed burns. She said that on Friday she and Dr. Chiaranca will be developing a news release about the burns. Ms. Wadsworth also offered to speak with Dr. Feigenbaum outside of the meeting and provide him with further information.
Demo Area 1
Mr. Hugus stated that until he realized that thereís no schedule for defining the toe of the Demo Area 1 plume, he had thought that the plume should be defined completely before beginning any sort of treatment. He said that tonight he wants to make it clear that he thinks that treatment at the high-concentration area of the plume should begin while definition of the downgradient part of the plume is being completed. Mr. Hugus also mentioned that he has concerns that decisions regarding the plan to treat the plume are being made away from the table.
Mr. Borci said that EPAís preference is to have the entire plume defined before moving forward with the remedy selection. He explained that while itís known that the plume has areas of 100-ppb-plus of RDX, the remediation timeframe is defined by how quickly the 2-ppb edges of the plume are collapsed. Therefore, EPA thinks that the best way forward is get more information and then put a real plan on the table thatís going to cover everything.
Mr. Hugus asked how long it will take to get the needed information. Mr. Borci replied that the first well, D1P9, would be installed the middle of next month. Mr. Hugus said that the answer then is that it will take a total of four months. Mr. Borci agreed, but also noted that data collection is starting right now.
Mr. Hugus asked how Mr. Borci knows that the plume will be delineated in four months, and there wonít be a need to drill farther downgradient. Mr. Borci replied that clean wells that are far downgradient already exist.
Mr. Hugus said that while he understands Mr. Borciís explanation, he doesnít necessarily agree with the rule about collapsing the 2 ppb contour. Mr. Hugus said that he thinks that the best treatment is to go after a 100 ppb-plus area right away, because its location is known. Mr. Borci pointed out that data needed to define the entire plume would be acquired long before that treatment system could be designed and implemented.
Mr. Hugus stated that he believes that the first rule is to reduce mass as quickly as possible Ė not to consider the overall remediation time. Mr. Borci replied that he would agree, if the Demo Area 1 plume were a simple fuel or solvent spill. However, perchlorate complicates the mix, and he believes that the entire problem should be understood completely before attempting to remediate it. Mr. Borci noted that it comes down to a four-month difference, which is worth the wait.
Dr. Feigenbaum noted that the CS-10 plume is a very complicated project that AFCEE has been remediating in pieces. He said that he thinks itís a reasonable strategy to begin addressing the 100 ppb area of the Demo Area 1 plume while simultaneously hunting down its leading edge. He then asked if itís correct that there are contingency plans with respect to whatís found in the first well to be drilled, D1P9. Mr. Borci replied that a decision matrix of what to do and where to go from there already has been determined.
Dr. Feigenbaum asked when drilling of D1P9 is scheduled to begin. Mr. Borci replied that drilling will begin in two weeks, and all data are expected to be back by April 9, 2002, a "soon-to-be-proposed" enforceable milestone date. He also explained that if the RDX detection at D1P9 turns out to be less than 2 ppb, the effort will focus on determining the width of the plume; if itís greater than 2 ppb, the investigation will move to a point farther to the west, which will be based on modeling and available data. Dr. Feigenbaum suggested that it could take years to "get it right," and in the meantime he thinks that cleanup activities should begin.
Mr. Pinaud assured Dr. Feigenbaum that this is a very aggressive and prudent way to define the toe of the plume. He said that DEP agrees with this approach, which involves six wells with contingent approvals based on the rationale that Mr. Borci described. Mr. Pinaud also noted that itís very important to further delineate the downgradient edge of the plume so that the reinjection piece can be implemented properly, without negatively influencing the path of the plume.
Ms. Garcia-Surette stated that DEP and EPA are united on this particular issue because, as they draw on their past experience with the IRP cleanup, they see examples where the selection of a good overall remedy was compromised by moving too quickly.
Dr. Feigenbaum asked how long it would take to install and sample all six wells, if that needs to be done. Mr. Borci replied that all six wells would be installed and sampled by July 9, 2002. He added that profile results would be available immediately and validated data would be available a couple weeks after that.
Dr. Feigenbaum indicated that he thinks itís arbitrary to assume that sufficient data will be available by July. He also asked if there is a guarantee that the plume will be treated with an axial system. Mr. Borci replied that five alternatives will be put forward, and the IART will have input into the selection of a remedy. He also noted that the IART had a chance to preview the alternatives at the November meeting.
MAJ Magrini urged the IART members to operate together as a team and accept that everyone is putting forth best efforts. Dr. Feigenbaum asked MAJ Magrini to understand that even though he may have an argument with Mr. Borci, for example, this doesnít mean that theyíre not congenial or that they donít work together as members of a team. He also stated that the citizen members of the team are here to ask hard questions of the professionals, and he mentioned having been very disappointed by some of the past cleanup decisions made on the Air Force side. MAJ Magrini said that understands and is familiar with that history.
Agenda Item #9. Agenda Planning & Review Action Items
Mr. Murphy noted that "Bourne Water Supply Wells 1, 2, 3 Update" is scheduled to be on the March IART agenda. He said that anyone who wants to recommend specific points to be covered in that update should contact Mr. Gregson and/or Mr. Borci or Mr. Pinaud. With the teamís approval, Mr. Murphy decided to forego a review of the action items, but noted that they would be included in the mailing.
Agenda Item #10. Adjourn
Mr. Murphy adjourned the meeting at 9:20 p.m.