Impact Area Review Team

River River Drops of rain on a leaf

Impact Area Review Team
Falmouth Holiday Inn
Falmouth, MA
June 25, 2002
6:00 p.m. Ė 9:00 p.m.

Meeting Summary






Tina Dolen (sitting in for Ben Gregson)

Groundwater Program


LTC David Cunha

HQ Camp Edwards


Marty Aker




Margery Adams



Todd Borci



Ellie Grillo



Len Pinaud



Janet Pepin



Evelyn P. Hayes



Richard Judge









Jim Murphy









Pam Richardson

Groundwater Program


Bill Gallagher

Groundwater Program



Dave Hill

Groundwater Program


Mike Minior




Henry Byers



Jim Baker



Brian Rogers



Ed Wise




Joe McInerny




Millie Garcia-Surette



Suzanne Condon



Martha Steele



Dave Williams




Cynthia Coffin

Bourne Board of Health



Kevin Hood

University of Connecticut



David Dow

Sierra Club



Robert Mullennix

Bourne resident



Kevin Dennehy

Cape Cod Times



George Gardner



Jim Rice

ICF Consulting


R. Skryness



L. Clarke



Rob Paine



Marc Grant



Kim Harriz




Eric Banks

Jacobs Engineering



Paul Feshbach-Mermey

Parsons Engineering


Kelly McQueeney

Envirogen, Inc.


David Cobb

Envirogen, Inc.


Rick Carr




Kris Curley



Lori Boghdan



Jennifer Washburn



Jane Moran



Action Items:

  1. The Groundwater Program office will ensure that all Impact Area Review Team (IART) members have received copies of IART comments and responses to comments regarding interim action alternatives to address the Demolition Area 1 plume.
  2. Ms. Hayes recommends that IART members who were not in attendance at the June 25, 2002 IART meeting be provided with an opportunity to comment on the response to Action Item #7 from the May 25, 2002 IART meeting, which pertains to the contractor selection process.
  3. The IART requests that the Groundwater Program office invite Dr. Fred Cannon to a future IART meeting to present information on granular activated carbon (GAC) treatment for perchlorate.
  4. The IART requests that perchlorate sampling be conducted at existing wells in the Chemical Spill 10 (CS-10)/BOMARC area.
  5. The Groundwater Program office will e-mail IART members who didnít attend the June 25, 2002 IART meeting to notify them that the July 23, 2002 IART meeting has been cancelled.

Future Agenda Items:

  • Fate and Transport Presentation
  • Gun and Mortar Firing Positions Workplans
  • Munitions Management Plan
  • CS-19 Remedial Investigation
  • Results of MDPH Health Study re: Potential Perchlorate Exposure in Bourne
  • Discussion on Media Coverage

Handouts Distributed at Meeting:

  1. Responses to Action Items from the May 25, 2002 Impact Area Review Team Meeting
  2. Presentation handout: Monument Beach Wellfield Update
  3. Presentation handout: MDPH/BEHA Presentation to the IART
  4. Presentation handout: IAGWSP Investigation Update
  5. Data Tables: Validated and Unvalidated Data
  6. Presentation handout: NRTC Update
  7. Impact Area Review Team (IART) Groundrules
  8. Impact Area Groundwater Study Program Update, June 2002
  9. Map: Groundwater Finding, Massachusetts Military Reservation, March 2002

Agenda Item #1. Welcome, Approval of May 28, 2002 Meeting Minutes, Review Draft Agenda

Mr. Murphy convened the meeting at 6:07 p.m. and asked if there were any changes or additions to the May 28, 2002 IART meeting minutes. No changes were recommended and the minutes were approved as written.

Because of a lack of citizen members in attendance, Ms. Hayes asked whether the team requires a quorum in order to proceed with a meeting. Mr. Murphy replied that according to the IART groundrules, a quorum is not required. The IART members then introduced themselves, and Mr. Murphy asked if there were any changes or additions to the agenda. Ms. Hayes asked that Mr. Murphy add "Media Coverage" to the agenda, and he agreed to add the item under "Open Discussion/Other Issues."

Agenda Item #2. Review Action Items

Mr. Murphy asked if there were any comments on the responses to action items from the May 25, 2002 IART meeting.

Mr. Judge referred to Action Item #1, which pertains to the teamís request for a health study that looks at potential perchlorate exposure in Bourne, and asked whether any high-level Massachusetts Department of Public Health (MDPH) representatives would be presenting at this meeting. Mr. Williams of MDPH noted that Suzanne Condon and Martha Steele were on their way to the meeting.

Ms. Hayes referred to Action Item #4, which pertains to the teamís opportunity to comment on Demolition Area 1 plume interim response actions, and asked whether IART members would be receiving a breakdown of responses to those comments. Ms. Dolen said that she believes that an e-mail containing responses to comments was sent out from her office. Ms. Hayes and Mr. Judge noted that they hadnít received that e-mail. Ms. Dolen agreed to provide copies of comments to those who didnít receive them.

Ms. Hayes also referred to Action Item #7, which pertains to the new contract awarded by the U.S. Army Corps of Engineers for Impact Area cleanup work, and suggested that team members not in attendance tonight Ė particularly those who had expressed disappointment with the contractor selection process Ė be provided with an opportunity to comment on the response to this item.

Action Item #3. Monument Beach Wellfield Investigation Update

Recent Activities

Mr. Grant reviewed the history of the Monument Beach wellfield investigation by noting that perchlorate detections at monitoring well 80 (MW-80), which is located on the Camp Edwards boundary, led to increased sampling of early-warning wells and water supply wells in the Monument Beach wellfield. Sampling of supply wells conducted in February 2002 came back nondetect for perchlorate; however, at that time perchlorate was detected in some early-warning wells located between the supply wells and the base boundary. The perchlorate concentrations that were detected ranged from about 0.5 to 0.75 parts per billion (ppb). Based on those findings, the Bourne Water District shut down supply wells #3 and #4, and sampling frequency was increased to biweekly.

Mr. Grant reported that on March 12, 2002 perchlorate was detected at 0.5 ppb in supply well #4, which already had been shut down, and sampling frequency at the supply wells was increased again, to weekly. On March 20, 2002 perchlorate was detected at 0.5 ppb in supply well #3, which also had been shut down previously. On April 2, 2002 perchlorate was detected at 0.5 ppb in supply well #6, which was shut down within days of that detection. At that time, perchlorate was detected for the second time in supply well #3.

Mr. Grant stated that currently there are fewer perchlorate detections overall than reported at the last IART meeting and prior to that. He noted that wells 02-02, 02-03, 02-04, 02-05 and 02-07, where perchlorate had been detected previously in well sampling or profile sampling, are now nondetect.

Ms. Hayes asked Mr. Grant to explain why there is a detection at a particular location during one sampling event, and then there isnít a detection there during the next event. Mr. Grant replied that this is due to changes in groundwater conditions over time. Ms. Hayes asked if the lack of detections where there previously had been detections would be considered a good finding. Mr. Grant replied that itís good that the detections arenít going up in concentration. However, itís not good to have any detections within the vicinity of the supply wells, even though the detections are very low and the Groundwater Program at the Massachusetts Military Reservation (MMR) uses the lowest detection limit for perchlorate in the country.

Ms. Pepin inquired about the status of water supply well site 4 (WS-4). Mr. Grant stated that at the Bourne Water Districtís request, the Guard currently is conducting pump tests and taking other measures to determine whether WS-4, which initially was investigated by the Joint Program Office (JPO) for potential use as part of the Upper Cape Water Supply project, can be used to help meet the summer water demand in Bourne.

Mr. Grant then continued his presentation by reporting that perchlorate detections at concentrations less than 1 ppb have occurred in two of six sampling rounds at well 02-13, with the most recent round being nondetect. Also, two consecutive nondetect rounds at well 01-88 followed three rounds of perchlorate detections there at concentrations less than 1 ppb.

Mr. Judge asked for confirmation that the most recent sampling round at well 01-88 was nondetect for perchlorate. Mr. Grant confirmed that it was, but also noted that concentrations that have been detected are so slightly above the detection limit that itís not really possibly to draw conclusions about trends. Mr. Judge indicated that heís concerned that the small amounts of perchlorate being seen in the wellfield could lead to larger amounts in the future. Mr. Grant replied that right now only low-level perchlorate detections are being seen until out near the base boundary, where concentrations, which are a little bit higher, do appear to be heading in the direction of the supply wells.

Mr. Borci pointed out well site BP-1, located to the east of MW-213 and MW-80. He said that that well is being installed upgradient in order to help determine what the concentrations are east of the base boundary, closer toward the presumed source area.

Mr. Grant continued with his presentation by noting that perchlorate was detected at a concentration less than 1 ppb in a new screen at well 02-09. He also noted that the water supply wells continue to be nondetect for perchlorate, but there are detections in monitoring wells or profiling upgradient of supply wells #1, #3, and #4, at wells 97-5, 02-89, 02-10, and 004D. Mr. Grant then reported that last week perchlorate was detected at 0.7 ppb in well 97-2, which is within 100 feet of supply well #6. Prior to that, there were three rounds of nondetect at that well, which followed a detection at a concentration of 0.4 ppb.

Mr. Judge asked whether the Bourne Water District has been notified of the detection at well 97-2. Mr. Grant replied that it has, and added that the Bourne Water District is notified of all detections that occur. Mr. Judge asked if well 97-2 is within the area of influence of supply well #6. Mr. Grant replied that he believes it would be within the area of influence of supply well #6, if that well were operating. He also mentioned that well 02-05, which was installed a little farther away from supply well #6, previously had a perchlorate detection in the past but is now nondetect.

Mr. Grant then reported that MW-80 still has perchlorate detections, with the sample from the M1 screen showing a detection at 1 ppb in the most recent sampling round. The highest concentration of perchlorate detected at MW-213 was 1.4 in the M3 screen, which is the shallowest screen. At a slightly deeper screen, perchlorate was detected at a concentration of 0.7 ppb, while the deepest screen was nondetect. Mr. Grant noted that results of sampling conducted at MW-213 are similar to those at MW-80.

Mr. Judge inquired about perchlorateís ability to sink or mix in groundwater, given the shallow detection at MW-213. Mr. Grant replied that perchlorate neither sinks nor rises; rather, it "just moves with groundwater." He also said that vertical movement would be minimal in that area because itís far away from the top of the mound.

Mr. Judge then referred to the aerial photo that was being shown and inquired about the clearing to the right of MW-213 and MW-80. Mr. Grant replied that he thinks that the cleared area was a gun position. Mr. Judge suggested that it might have been used as a disposal area. He said that it looks "mighty suspicious" to him, especially in light of the right-to-left direction of flow.

Mr. Borci referred to comments about the shallow detection at MW-213, and clarified that "more shallow" is a relative term, and in fact the detections and depths at MW-213 and MW-80 match up well. He noted that well screen locations at MW-213 were selected based on detections in screens at MW-80, which was meant to be an early-warning well and so screens staggered throughout in order to cover as much of the aquifer as possible. With respect to well BP-1, screens will likely be set between 30 to 40 feet below the water table and at about 100 feet below the water table. Mr. Borci further noted that perchlorate detections in MW-213 occurred at about 40 feet below the water table and 110 feet below the water table. In MW-80, perchlorate detections occurred at about 25 below the water table and 100 feet below the water table.

Ms. Pepin said that in a weekly progress update she read about Dr. Fred Cannonís presentation to the technical group regarding granular activated carbon (GAC) for perchlorate treatment. She then asked if there were any handouts from that presentation. Ms. Dolen replied that there were no handouts with that presentation; however, her office and the Bourne Water District plan to invite Dr. Cannon back for another presentation, which could involve the IART. Mr. Judge recommended that Dr. Cannon be invited to present at an IART meeting. Ms. Dolen agreed to extend that invitation.

Mr. Grant again resumed his presentation. He reported that all new monitoring wells in the wellfield have been completed at this point. However, three proposed wells Ė 02-06, 02-11, and 02-14 Ė are on hold for the time being. Over the next month an effort will be made to decide whether those wells are positioned properly or whether additional wells are needed in order to characterize the source and extent of the perchlorate.

Mr. Grant also reported that installation of MW-219, one of two wells to be installed upgradient of WS-4, is being completed. He noted that profile samples collected there were nondetect for perchlorate. However, there were several detections of explosives in profile samples Ė but of compounds frequently seen as false positives, such as dinitrotoluene (DNT). Well screens are being installed this week and samples will be taken to confirm those explosives detections. Drilling of the second monitoring well upgradient of WS-4 is expected to begin in about two weeks.

Mr. Grant then stated that well BP-1, which is located about 1000 feet upgradient of MW-80, currently is being drilled and is expected to be finished within about one week. Based on profiling information, decisions regarding well screen locations will be made.

Ms. Hayes inquired about the highest level of perchlorate detected in this area. Mr. Grant said that he thinks it was around 1.7 ppb. Mr. Borci said that 2.26 ppb comes to mind; nevertheless, both levels are around 2 ppb. He said that he thinks that the 2.26 ppb detection occurred in the M1 screen of MW-80.

Mr. Grant then discussed future actions. He said that the groundwater model is being updated using an approach that was approved by the Bourne Water District and is based on information that was collected when new wells were being drilled. That information pertains to where the bedrock surface is located and what the soil types are, in addition to water table measurements that will be helpful in calibrating the model. Mr. Grant also said that several areas on Camp Edwards are being evaluated as possible sources of the perchlorate contamination. Those areas include gun position 2 (GP-2), GP-24, cleared area 12, and mortar firing position 4 (MP-4), where soil sampling is being conducted.

Mr. Grant then stated that portions of the draft site-wide perchlorate characterization plan are being implemented. The plan, which was distributed to the IART during the second week of June, involves sampling wells across all of MMR and trying to determine whether there are sources of perchlorate that are headed in the direction of the Monument Beach wellfield. The remainder of the plan is being discussed with the regulators to determine whether itís adequate.

Mr. Grant concluded his presentation by noting that the Groundwater Program office is in the process of updating and preparing a new response plan to address the next round of investigation in Bourne. This will include information from munitions surveys as well as historical information regarding possible source areas on MMR where perchlorate may have been handled or disposed.

Mr. Judge asked whether perchlorate was contained in the fuel used at the Boeing Michigan Aeronautical Research Center (BOMARC) missile site on base. Mr. Borci replied that BOMARC rockets originally used liquid fuel, but later used solid fuel, or perhaps a mixture of both. He said that it doesnít appear that the liquid fuel contained perchlorate. He also noted that over the past three months the Guard has been trying to determine whether the solid fuel contained perchlorate, and it seems that the Guard is very close to obtaining that information.

Mr. Borci then said that he doesnít know whether perchlorate sampling has been conducted at the CS-10/BOMARC site. Mr. Aker said that he doesnít think that perchlorate sampling has been done at the CS-10 site. Mr. Judge requested that existing wells in the vicinity of the CS-10/BOMARC site be tested for perchlorate.

Massachusetts Department of Public Health Presentation

Ms. Condon introduced herself as the Assistant Commissioner for Environmental Health Programs at MDPH. She also noted that Mr. Williams from the Environmental Public Health Center (EPHC) at MMR, and Ms. Steele, the Deputy Bureau Director who supervises all Cape Cod staff activities, are present at tonightís meeting.

Ms. Condon then stated that, according to data thatís current through June 24, 2002, there have been four perchlorate detections in Bourne municipal drinking water wells since testing began in October 2001. She also said that private wells identified to date in the area adjacent to the Monument Beach well field have tested nondetect for perchlorate, and investigations to determine historical and current distribution of perchlorate in groundwater are ongoing.

Ms. Condon discussed potential health impacts from perchlorate exposure by noting that perchlorate inhibits the uptake of iodine into the thyroid gland, which is important because iodine is essential to the synthesis of thyroid hormones T4 and T3. She explained that insufficient levels of thyroid hormones, or hypothyroidism, can affect a variety of metabolic and developmental processes. She also said that while not replicated in human studies, some animal studies have shown increased thyroid tumor formation from exposure to perchlorate. She further noted that based on census tract data collected several years ago, the rates of thyroid cancer in Bourne actually are relatively low, which is good news.

Ms. Condon said that in an effort to help provide information to the community about the potential for historical or current problems relative to perchlorate, MDPH will be working with researchers from the University of Massachusetts (U Mass) Medical Schoolís Biologic Institute, home of the newborn screening program. The program, which originated several years ago at MDPHís state laboratory institute and then was transferred to U Mass Medical School, explores different types of new and important genetic issues. Ms. Condon noted that MDPH plans to look at some very specific data from the newborn screening program and Ms. Steele already has met with experts from U Mass Medical School to outline MDPHís interests and concerns.

Ms. Condon reported that MDPH also would be working with the Harvard School of Public Health under a new bio-monitoring contract funded through a grant awarded by the U.S. Centers for Disease Control (CDC). She said that Massachusetts was one of three or four states fortunate enough to be chosen for this contract, which will enhance the state laboratoryís capability in the area of biologic impacts based on environmental exposures. Ms. Condon explained that as MDPH learns about new and challenging environmental exposure concerns across the state, itís able to work with Harvard and have its experts determine the best way to go about looking at an exposure concern and provide useful information to the public regarding whoís at risk of exposure. She said that MDPH already has met with people from Harvard with respect to having them develop a feasibility study and determine how to go about bio-monitoring across the community as more is learned about exposure issues from work being done by the regulatory agencies and the military.

Ms. Condon then explained that the newborn screening program was set up to test newborns in Massachusetts for early signs of a number of routine treatable disorders, one of which is hypothyroidism. The babies are screened for T4 levels, which usually are measured within 48 hours after the birth occurs. Ms. Condon reported that the U Mass Medical researchers have agreed to look at T4 levels in newborns from the community of Bourne versus all Upper Cape communities and the state as a whole. She said that numbers that are higher than expected, based on the statewide experience, would prompt further investigation. She also explained that information from U Mass Medical would be provided to Harvard for use in the final design of any kind of bio-monitoring study. Ms. Condon noted that U Mass Medical researchersí preliminary efforts will focus on the years 1999 to 2001, from which the most complete and uniform data are readily available. However, the researchers have been made aware of MDPHís desire to look at historical data as well.

Ms. Condon said that there are about 250 births a year in the community of Bourne, so there would be about 750 births to evaluate over the three years from 1999 to 2001. She also noted that the rate of T4 hormone abnormalities is about 1 in 2000 births. While 750 falls short of 2000, if several cases of T4 abnormalities were seen in this smaller population, that would say something in and of itself.

Ms. Hayes inquired about the population that the newborn screening program is studying. Ms. Condon replied that the population is all of Massachusettsí live births. Ms. Hayes asked whether participation in the study is mandatory. Ms. Condon replied, "Itís routine surveillance data."

Ms. Condon then said that instead of undertaking the development of a big study at this time, working with U Mass Medical and the newborn screening program will allow MDPH to provide meaningful information to the community sooner rather than later. She also said that one possible outcome of the feasibility study to be conducted by Harvard could be to look at T4 levels in all individuals across the population. She added that Harvard might also come up with some other biomarker that emerges through intensive evaluation of this particular issue.

Ms. Condon stated that U Mass Medical expects to be able to provide information from the newborn screening program database by the end of this summer, although she plans to push for a quicker turnaround time. She also noted that she, Ms. Steele, Mr. Williams, and other MDPH staff will be meeting with Harvard researchers this summer to discuss any additional issues and concerns, and at this time she welcomes the comments of the IART community members, regulatory agency representatives, and military representatives.


Mr. Judge asked how the EPHC on MMR is funded. Ms. Condon replied that the EPHC is funded in large part by the Agency for Toxic Substances and Disease Registry (ATSDR) via contract to MDPH, but is also supplemented with state funds. She also noted that while she believes that ATSDR receives a lot of its funds for federal sites from the Department of Defense (DoD), EPHC doesnít receive a "single cent directly from anyone other than ATSDR."

Mr. Judge remarked, "not to say thereís tainted money here," but he thinks itís important to keep in mind that while itís indirect, the EPHC does receive a great deal of its funding from the DoD. Ms. Condon clarified that it receives some money from the ATSDR cooperative agreement, which, she believes, ATSDR funds with DoD money. She then reminded Mr. Judge that U Mass Medical School doesnít receive funding from DoD or MDPH. She also noted that the money being provided to Harvard comes out of a federal grant from the CDC, and DoD has nothing to do with that. Ms. Condon also said that although Mr. Williams is paid through the ATSDR cooperative agreement, he certainly is one of the only people on the federal payroll working on this particular project. She added that whether or not Mr. Judgeís concern is valid, "itís not something that should interfere with anything that Iíve talked about tonight." Mr. Judge said that itís important to him "to have independent observations that would never be even construed as the possibility of infringement on that investigation" and so heís pleased by the involvement of independent universities.

Mr. Judge also stated that thereís quite a difference between descriptive and analytic epidemiological studies. Ms. Condon replied that descriptive studies often lead to the generation of hypotheses for analytic investigations. Mr. Judge then asked if itís correct that the study being done by U Mass Medical is a descriptive epidemiological study. Ms. Condon replied that it is. Mr. Judge questioned whether thereís sufficient information to move ahead with an analytical study at this time.

Ms. Condon said that based on the available environmental exposure data, and animal and human studies, there isnít a need to design an analytic study because the exposures havenít reached a level where certain health outcomes would be expected. However, MDPHís approach differs in that it asks the questions, "If it could have happened, whatís the marker? How do we look at this and evaluate what the likelihood is that exposure took place?" Ms. Condon stated that in this particular case thereís an opportunity to look at descriptive data relative to hormone abnormalities in newborns. These are not routine descriptive data, but data that pertain to the very thing that would be affected if exposure were to have occurred. She said that she thinks it would be unwise to move forward with the design of an analytic study before looking at descriptive data that might help guide that study.

Mr. Judge commented that he thinks it would be unwise only if there were no problems on Cape Cod, and so his suggestion is to "get up to running speed right away," especially since itís been determined that perchlorate is in the water. He also said that the determination of whether or not to move forward should be based on available knowledge; however, in this case, little is known, and so he questions where to go from here. Ms. Condon reiterated that the newborn screening data are not routine descriptive data, but a kind of surveillance system thatís very active. Mr. Judge expressed his frustration that, given the "challenges for the last couple years," more health data havenít been gathered on the people who live and have lived on Cape Cod.

Mr. Judge also asked whether individuals could develop hypothyroidism later in life as a result of exposure. Ms. Steele replied that hypothyroidism can be developed later in life, and a variety of factors may contribute to that. She also noted, however, that when looking at health endpoints and different populations that might be affected by exposures, one certainly would want to look at a sensitive population, such as newborns. Mr. Judge said that heís concerned that the study wonít pick up on whatís happening with the adult population on Cape Cod. Ms. Condon explained that the Harvard piece of the study would address how to go about evaluating population-wide impacts.

Ms. Condon then said that she thinks that MDPH is trying to use the best resources available in the wisest way in order to best address the communityís concern. She also noted that a lack of health data is a problem all over the country, not just on Cape Cod. However, the federal government is starting to make some money available for communities to put in place tracking systems that could answer a whole range of different questions that canít be answered easily right now.

Ms. Condon further stated that as someone whoís worked in environmental epidemiology for almost two dozen years, she realizes the importance of looking at populations within populations. She referred to the Woburn study, for example, and noted that although anyone who lived in Woburn received some contaminated well water at some point in his or her life, a clear association was made between pregnant women who consumed contaminated well water during critical periods of their pregnancy and the children who developed childhood leukemia. Without that detailed exposure assessment, efforts to look at the community as a whole were greatly hampered.

Mr. Judge then said that Dr. Knorr, who works for MDPH, came to Cape Cod and told a large group of residents that the childhood leukemia on Cape Cod was statistically insignificant. Ms. Condon replied that if Dr. Knorr used the words statistically insignificant, sheís glad that Mr. Judge told her, because no childís illness is insignificant.

Ms. Grillo, on behalf of the Massachusetts Department of Environmental Protection (DEP), thanked Ms. Condon for coming to the meeting and presenting an option that could address some of the lingering questions about the perchlorate issue in Bourne. She also asked Ms. Condon how the results of the study would be presented to the public, and whether she envisions coming back to the IART. Ms. Condon replied that if the IART is the appropriate group, she would be happy to come back and share information learned from U Mass and Harvard. She also said that she would look to the IART for advice on the community involvement aspect of the study. For example, if itís found that a high number of babies have T4 hormone levels, and Harvard designs a study, she would be happy to share a draft protocol with IART members for their review and comment. Ms. Grillo thanked Ms. Condon and remarked, "we like to look at data." Ms. Condon said that sheíd share whatever data she has, as long as it doesnít have names on it.

Ms. Pepin asked whether Ms. Condon was referring to incidence or prevalence when she said that thyroid cancer rates in Bourne are low. Ms. Condon replied that that was based on neighborhood-level incidence data, current through 1994. Ms. Steele added that those data were from the years 1986 to 1994. Ms. Pepin also inquired about the latency for thyroid cancer and exposure. Ms. Condon replied that thyroid cancer has a window of somewhere between 15 and 30 years.

Ms. Pepin asked Ms. Condon to identify the contact person who could answer any questions team members might have. Ms. Condon replied that the best person to contact is Ms. Steele; however, she (Ms. Condon) would be happy to help as well. Ms. Pepin then said that she knows a family who moved to the Bourne area about 10 years ago, and all the members of that family have developed thyroid problems. She then asked whom they should contact and the course of action they should take. Ms. Condon replied that the family should contact Ms. Steele. She also noted that MDPH has two environmental and occupational physicians under contract who would review the familyís medical records in a very confidential way and work with their physicians to see if there are any tests to be done that might determine the likelihood that exposure contributed to the disease. Ms. Condon said that one of those physicians, Dr. Kim Pierson, lives on Cape Cod.

Ms. Pepin asked about collaboration with ATSDR on the Bourne thyroid study. Ms. Condon replied that ATSDR has a staff person located at the EPHC. However, MDPH has been dealing directly with Harvard University and U Mass Medical with respect to the study. The only other involvement comes from the state laboratory. Ms. Pepin asked if Harvard has looked at any other communities in terms of bio-monitoring for MDPH. Ms. Condon replied that it has not, and noted that the contract with Harvard is brand new.

Ms. Pepin also informed Ms. Condon that the EPHC representative at the April IART meeting said that MDPHís position was that no ill effects were anticipated from the water that had been tested up to that point. She told Ms. Condon that a number of Bourne residents found this statement to be insensitive. Ms. Condon said that she believes that Mr. Williams, the EPHC representative who spoke at that IART meeting, made that statement in answer to the question of whether negative health effects would be expected based on perchlorate levels recently detected at the Monument Beach wellfield. She noted that animal and human studies suggest that perchlorate exposures at levels of 0.5 to 1 ppb would not be important in terms of causing future health effects. However, she also acknowledged that thereís a risk communication issue associated with Mr. Williamsís statement, given that MDPH is not assuming that perchlorate levels have always been the same. Ms. Condon clarified that the community is asking MDPH for help and MDPH stands ready to provide that help.

Ms. Dolen said that the Groundwater Program office is very interested in working with MDPH and the other agencies in terms of community involvement. She noted that her office invited members of the Bourne community to the April IART meeting, and over 200 Bourne residents attended. She then asked Ms. Condon whether she would say that the Bourne community should be concerned about exposure, shouldnít be concerned about exposure, or should be concerned only about historic exposure Ė given that supply wells #3, #4, and #6 have been shut down and the Bourne Water District distribution system has tested nondetect for perchlorate. Ms. Condon replied that if the data available to date were all there was to consider, she thinks that Mr. Williamsís statement is what most public health researchers would say. However, she thinks that the best way to answer Ms. Dolenís question is to get the newborn screening data and see what it looks like. Ms. Dolen said that she thinks thatís a good plan and she hopes that Ms. Condon will be able to get the information by mid-summer.

Ms. Hayes asked whether any other statesí public health departments have conducted studies like the one MDPH has proposed to undertake. Ms. Steele replied that she knows of similar studies conducted in California, Nevada, and Arizona. Ms. Hayes inquired about the results of those studies. Ms. Steele replied that while sheís not familiar with all the details, she recalls that some results indicated that there wasnít much difference in T4 levels between certain areas, while there were some differences in other endpoints. Ms. Hayes asked whether it would be safe to say that so far the studies have not shown anything alarming. Ms. Condon replied that she thinks itís fair to say that not an awful lot has been done. She also said that MDPH is asking Harvard to look at everything else thatís been done and then recommend the best way to proceed.

Ms. Hayes said that although she expects that Ms. Condon would agree that "you canít base it on one or two families," she wanted to mention that her brother and his wife have lived in Bourne for about 35 years, have raised four children there, and have had no problems whatsoever.

Mr. Dow noted that a woman who works at Amherst College informed him that a professor at U Mass/Amherst, whoís involved with a national group studying safe perchlorate levels for the U.S. Environmental Protection Agency (EPA), is concerned that perchlorate might be an endocrine disrupter. He said that because of the potential perchlorate problem on the Cape, the woman from Amherst College had asked his advice about distributing this information locally and she noted that the professor from U Mass/Amherst was interested in working with some local people. Mr. Dow noted that he provided her with contact information for Mr. Murphy. He also mentioned that he knows that effects from endocrine disrupters in fish can be exerted at levels that normally wouldnít be considered problematic from a carcinogenic or toxigenic perspective.

Ms. Condon noted that as a result of Silent Spring Instituteís breast cancer and environment study, which is being funded by MDPH, a significant amount of municipal water testing has been done for endocrine disrupters throughout Cape Cod. She also said that sheís glad that Mr. Dow raised this issue because itís something else that can be discussed with the people from Harvard.

Mr. Judge commented that when statements are made that no problems are seen "based on available data," itís important that the public understand what that amount of data is Ė whether itís a small amount, a large amount, or none at all. He also asked that future statements and conclusions from the Bourne study be presented in relation to rates of disease in states across the country as well as across Massachusetts. Ms. Condon agreed to provide that information. She also referred to Mr. Judgeís first point and clarified that MDPH was provided with whatever data were also available to the other agencies. She said that no one would have said that there were no data. Mr. Judge explained that it was respect to the PAVE PAWS issue that heíd been told that, based on available data, thereís no problem for Cape Codders, and was later told that the Air Force had no data on phased array radar.

Ms. Hayes said that her brotherís family, who, as sheíd mentioned earlier, lives in Bourne, is concerned about a rush to judgment and an alarmist attitude, which she believes any good epidemiologist would avoid at all costs. Ms. Condon replied "absolutely" and Ms. Hayes said that she is counting on that.

Mr. Minior asked whether the newborn screening database is available by zip code, and noted that not all Bourne residents get their water from the same place. Ms. Steele replied that it is available by zip code. Ms. Condon added that MDPH could ask U Mass Medical to present the data in that kind of a structure. She also noted that the phone number where she, Ms. Steele, and others at MDPHís Environmental Health Program can be reached is 617-624-5757.

Agenda Item #5. Investigations Update

New Wells/Recent Detections

Mr. Grant referred to the map entitled "New Wells and Recent Detections in the Central Impact Area" and noted that RDX contamination is shown in three shades of tan and brown to represent concentrations lower than the health advisory, between the health advisory and 10 ppb, and greater than 10 ppb. He also mentioned that Central Impact Area perchlorate contamination, which would be shown in shades of pink, would be mapped after samples that are being collected now are analyzed.

Mr. Grant reported that perchlorate was detected recently in groundwater samples from MW-1M2, MW-2M1, and MW-38M3, at concentrations less than the 1.5 ppb relative standard for MMR that was set by EPA. He also noted that 2,6-DNT was detected in a profile sample from MW-220, and both 2,6-DNT and 2-nitrotoluene were detected in a profile sample from MW-224 Ė all at levels below drinking water guidance. In addition, Royal Demolition Explosive (RDX) was detected in several profile samples from MW-223, with at least one detection at a level above the RDX health advisory of 2 ppb. Mr. Grant said that these new wells were installed in order to get a better handle on the extent of RDX contamination in the Central Impact Area.

Mr. Grant then showed a map entitled "Southeast Corner of the Ranges, Recent Detections," and pointed out the J-3 Range, the L Range, the J-1 Range, the J-2 Range, the former H Range, the J-3 wetland, and Snake Pond. He reported that perchlorate was detected recently at about 1 ppb in two drive-point locations on the eastern beach of Snake Pond that previously tested nondetect for perchlorate. Mr. Grant said that the recent perchlorate detections in the drive-points are very shallow Ė just below the pond bottom Ė and donít match well with the current understanding of contamination in that area. He noted that a number of actions will be taken in an effort to get a better handle on these shallower detections, and the first action will be to expedite validation of the data from those locations.

Mr. Grant reported that more monitoring wells are going to be installed and the Guard is involved in discussions with the Air Force Center for Environmental Excellence (AFCEE) regarding how the Fuel Spill 12 (FS-12) plume treatment system might be affecting groundwater movement in that area. He also noted that surface water samples taken from Snake Pond continue to come back nondetect for perchlorate.

Ms. Pepin inquired about the status of the public water supply well on the southern edge of Weeks Pond. Mr. Grant said that he believes that the Weeks Pond well was used for intermittent supply in the past, but he doesnít know whether itís in use currently. Ms. Pepin asked whether the well has been sampled for perchlorate. Mr. Grant replied that it had been in the past, but he doesnít think itís been sampled recently. He also referred to the map and pointed out one of the Weeks Pond sentinel wells that has been tested. He then pointed out the J well and said that he doesnít know whether or not AFCEE has tested that for perchlorate. Mr. Pinaud said that thereís carbon treatment on the J well, although that might not be too helpful in terms of perchlorate. He also noted that the Sandwich Water District voluntarily shut down the Weeks Pond well some time ago because of the FS-12 plume.

Mr. Judge asked if any other contaminants, besides RDX and perchlorate, were found to be moving in the direction of Snake Pond. Mr. Grant replied that he thinks that High Melting Explosive (HMX) was detected, but not as far south as the RDX plume. He also said that trinitrotoluene (TNT) was detected, but closer to the J and L Ranges.

Demolition Area 1

Mr. Hill explained that a feasibility study to evaluate remediation options for the Demo Area 1 plume was a requirement of EPA Administrative Order #3. Options in that feasibility study were intended to remediate a plume that was assumed to extend just beyond Frank Perkins Road. However, about the time that the draft feasibility study was released, the Groundwater Program came to the realization that the plume extended a significant distance beyond Frank Perkins Road. In December 2001 feasibility study activities were put on hold pending complete delineation of the plume, and by spring 2002 it was realized that the plume actually extended west of Pew Road. At that time, the Guard spoke with EPA about approaching the plume with an interim measure Ė short of completing the feasibility study and beginning remediation. As a result, three proposed interim action options were presented at the May IART meeting.

Mr. Hill noted that AO#3 contains information about Rapid Response Actions (RRA), which generally address soil contamination rather than groundwater contamination. The Massachusetts Contingency Plan (MCP), however, includes whatís called a Release Abatement Measure (RAM), which "fits nicely into any remedial action." Therefore, the Groundwater Program went to the MCP for guidelines on how to proceed with an interim action that wouldnít be so robust that it would have the effect of pre-selecting a comprehensive remedy that, according to the administrative order, was to be the result of a feasibility study and requisite public process. Mr. Hill stated that a RAM provides for an action thatís limited in scope, is relatively easy to implement, and is consistent with options for a comprehensive remedy.

Mr. Hill then reviewed the interim action options: Option A is pumping at the toe of the plume, Option B is pumping at Frank Perkins Road, and Option C is pumping along the eastern axis of the plume. He reported that EPA and the Guard have agreed to pursue Options A and B, given the extent of the plume as itís currently known. He also explained that pumping the plume at the toe would prevent further migration and impact to downgradient groundwater, and pumping at Frank Perkins Road would prevent the mass in the plume from migrating farther downgradient.

Mr. Hill stated that the next step is to develop a schedule for the interim action. At this time design and construction effort activities are being scoped and durations are being assigned to them. He also noted that additional plume delineation is ongoing. He reported that well screens were just selected for the most downgradient well, and he is cautiously optimistic about having found the toe of the plume. Another ongoing activity is conceptual design of the pump-and-treat systems, and itís being evaluated whether or not those two systems would be linked together with a pipeline. Mr. Hill reported that the next document to be released would be a detailed interim action workplan. He also noted that the feasibility study would continue concurrent with implementation of the interim action.

Mr. Pinaud stated that DEP also is cautiously optimistic that the leading edge of the plume has been found. He also asked about the schedule for installing wells D1P14 and D1P15, the next step in terms of delineation. Mr. Hill replied that he thinks that those wells would be installed within a month or so, and he expects data from the wells to be available by the end of the summer. Mr. Pinaud asked if Mr. Hill has a sense of the schedule for the interim action. Mr. Hill replied that itís too early to even guess about a system startup date; however, he thinks that more information about the schedule will be available by the next IART meeting.

Mr. Pinaud then asked whether the redraft of the feasibility study could be expedited while proceeding forward with the interim action, assuming that the leading edge of the plume is defined by the wells that heíd mentioned. Mr. Hill replied that although some significant revisions are needed, it wouldnít take as long as it would to start over completely. He also said that while a date for the next iteration of the feasibility study schedule hasnít been determined yet, the Groundwater Program office soon will be coming up with some schedule information on interim actions to review with the regulators. Mr. Pinaud noted that several months ago, when it was thought that the leading edge of the plume would be found by April, the tentative date for a feasibility study was given as November. Therefore, he would suggest that five or six months out might be a good estimate of when the feasibility study might be completed.

Mr. Borci stated that EPA definitely is in favor of expediting the overall feasibility study. He also noted that EPA would be looking to amend the scope of work for AO#3 to ensure that it covers work associated with the interim action. In addition, EPA plans to work with the Guard to set up enforceable milestones that are based on planned durations of previous actions.

Ms. Garcia-Surette made a point of noting that at last monthís IART meeting DEP clearly indicated the need to have a schedule. She said that she had hoped that by tonight the Guard would be able to articulate anticipated timelines for the various scenarios, and she is disappointed that that is not the case. Mr. Hill explained that because the decision was to undertake two options rather than one, a little more contemplation is needed in order to determine whether they should be linked with a pipeline or done as two independent actions at the same time.

Ms. Garcia-Surette then asked whether it might be anticipated conceptually that by implementing the interim actions, and then undergoing the feasibility study process, the realization would be that the feasibility study process had been fulfilled in terms of arriving at a selection. Mr. Hill replied that it would be up to EPA to select the option. Mr. Borci stated that, as currently structured, AO#3 requires that at least one alternative be designed to attempt to meet a 10-year cleanup. Therefore, he doesnít see that the feasibility study process wouldnít occur.

Agenda Item #5. Natural Resource Trustee Council Presentation

Dr. York of the Army Environmental Center (AEC) introduced himself as the designated Army trustee representative to the Natural Resource Trustee Council (NRTC) at MMR. He explained that although the IART wrote a letter asking the administrative trustee to come to a meeting, he is here tonight because it was thought that the IART would be more interested in the Army position and that he would be able to talk more directly to Army issues.

Dr. York stated that the Natural Resource Damage Assessment (NRDA) process is made up of three phases: a pre-assessment screen, which involves a review of available information and a determination, based on five criteria, as to whether the damage assessment should proceed; an assessment phase, which involves an attempt to quantify the injury and then put a dollar value against the natural resources to determine the damage level; and a post-assessment phase, which involves setting up a restoration account and spending the funds in accordance with a restoration plan developed by the NRTC.

Dr. York noted that NRTCís Community Involvement Plan (CIP) was published in August of 2001. He also reported that, as noted in the CIP, the pre-assessment screen originally was scheduled to be out in the fall of 2001. However, at this time only a preliminary draft has been completed. That draft has been reviewed internally by the trustees and advisers and a number of issues and comments still need to be resolved. Dr. York noted that the NRTC plans to meet this year to complete discussions on the pre-assessment screen and publish it in final form, and a public comment period and public meeting would be part of that process.

Dr. York said that while his presentation so far has pertained to the NRTC as a whole, he will now be giving the Army view of an NRDA issue that is yet to be resolved. He explained to the team that any trustee or any trustee council can assess any release of oil or a hazardous substance Ė independent of which law is being used to drive the response, and even if there is no response action. He then noted that hazardous substance is defined by the law in two ways Ė either itís listed in the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) or it can be added to that list by being declared a characteristic waste under the Resource Conservation and Recovery Act (RCRA).

Dr. York stated that federal funds could be used to assess hazardous substances that are listed or characteristic wastes under CERCLA. However, RDX and perchlorate are not listed hazardous substances, therefore thereís an issue with spending federal funds to do that assessment. Dr. York stated that this is one of the challenges that the NRTC is facing at this time.


Ms. Adams, an EPA attorney, said that although EPAís role is as an adviser to the NRTC, EPA does "have sort of the ultimate call of whatís a waste under RCRA." She then stated for the record that EPAís opinion is that "RDX and perchlorate are characteristic wastes and therefore can be included in a natural resource damage assessment." She noted that perchlorate is ignitable characteristic waste in that itís an oxidizer as defined in "49CFR173.151." She also noted that RDX and HMX are Class A explosives and are therefore considered reactive characteristic wastes. Ms. Adams further noted that to the extent that source areas result from disposal such as burial of munitions, those buried munitions constitute a solid waste under the munitions rule because they werenít used in the ordinary course, and are also considered a hazardous waste.

Dr. York said that he agrees that a regulatory decision needs to be made regarding whether the compounds in question are going to be listed hazardous substances or come into the hazardous substance arena by virtue of characteristic waste. He noted that at issue is the formal process required to do that, and he doesnít think that falls within the purview of the NRTC.

Mr. Judge remarked that the regulators just said that perchlorate and RDX should be included in the damage assessment. He also indicated that heís displeased with the makeup of the NRTC, and then asked Dr. York to list the voting members. Dr. York replied that the voting members on the NRTC are the Army, the Air Force, the Veterans Administration (VA), the Commonwealth, and the Department of Interior. Mr. Judge pointed out that parties responsible for the contamination are in a decision-making role with respect to determining damages. He also noted that the Senior Management Board (SMB) membersí request to become voting members of the NRTC was denied, and they were granted only an advisory role. Nevertheless, he had hoped that the NRTC would put forth a good faith effort to assess the situation on the Upper Cape. However, "calling RDX and perchlorate not hazardous" immediately tells him that a good faith effort is not going to happen. Mr. Judge said that he would request that the Commonwealth of Massachusetts withdraw from the NRTC because "the people have one vote on a trustee council" thatís made up primarily of responsible parties.

Mr. Judge also noted that he believes that the damage assessment should be based on zero contamination, rather than maximum contaminant levels (MCLs) assigned to the various compounds. He said that he thinks this is important because itís "about a billion-dollar decision."

He then remarked that he thinks itís irresponsible for the NRTC to say that because perchlorate and RDX arenít on the list of hazardous substances, it isnít going to include them in its damage assessment. Mr. Judge added that he thinks the Upper Cape would be better off with a class action lawsuit to settle this claim than dealing with a situation where the decision is made that RDX is not hazardous.

Dr. York clarified that he isnít talking about whether perchlorate and RDX are or are not hazardous in terms of exposure. Rather, his point is that by law neither one of them is listed as a hazardous substance. Therefore, until the law is changed to include them or until theyíre included by another process, the NRTC does not have the authority to assess damages associated with those contaminants. Dr. York also noted that RDX contamination has been cleaned up under CERCLA at installations throughout the country. However, the specific issue of natural resources damages in the law refers only to hazardous substances, and RDX isnít included in that list. Dr. York stated that the Memorandum of Agreement (MOA) that founded the NRTC doesnít grant the members any authority over and above what they normally would have.

Mr. Judge asked if itís correct that the NRTCís regulatory authority is built around CERCLA. Dr. York replied that NRDA is a part of CERCLA. Mr. Judge mentioned that some cleanup work on the base is being conducted under the Safe Drinking Water Act. Dr. York clarified that a trustee can assess a release of oil or a hazardous substance whether the response is under the Clean Water Act, the Safe Drinking Water Act, or no act. The operative term is that it must be oil or a hazardous substance.

Mr. Murphy then read a statement e-mailed to him from Dale Young, the director of the NRDA program for the Executive Office of Environmental Affairs (EOEA) in Boston: "As the Commonwealth trustee representative on the Massachusetts Military Reservation Natural Resource Trustee Council, I wanted to relay the following to you as the facilitator of the IART. I regret not being able to attend the June 25th IART meeting. Due to scheduling conflicts Iím not able to attend as the Commonwealthís trustee representative. In regards to the status of the MMR pre-assessment screen, I wanted to briefly acknowledge that there are existing points of disagreement internally at the NRTC. The Commonwealth is continuing to work within the NRTC to try to move forward with the NRD process and reach resolution on outstanding pre-assessment screen issues. I would be interested and available to attend an upcoming IART meeting to discuss these NRTC issues and answer questions."

Ms. Garcia-Surette stated that she wants to clarify for the record that neither EOEA, trustee for the groundwater of the Commonwealth, nor DEP, serving in an advisory capacity, agree with the Armyís position. She also made a point of noting that the Army hadnít raised this issue earlier in the pre-assessment process Ė for example, when the scope of work was approved and when a contractor was selected to perform the work.

Ms. Garcia-Surette said that she thinks itís imperative that any outstanding issues be resolved through a full NRTC meeting, which has not occurred, despite the Commonwealthís call to have that happen. She also noted that the state law, 21E, deals with oil and hazardous substances, "so we do consider these constituents as constituents that warrant evaluation." She then assured the group that itís not the Commonwealth thatís in the position of stalling the process.

Dr. York made a point of noting that he is saying that federal funds cannot be used to assess RDX and perchlorate. He said that there are four federal trustee representatives and one non-federal trustee representative.

Mr. Judge asked whether EPA is federal. Ms. Adams replied that it is, but itís not a voting member of the NRTC. She explained that the way the law is written, trustees on a council are the Department of Interior; the federal agencies at the site, in the case of federal facilities; and the National Oceanographic and Atmospheric Administration (NOAA), which is not involved in the MMR NRTC. Mr. Judge remarked, "EPA is conspicuously missing."

Dr. York noted that almost two years ago, when the NRTC was first formed, Ms. Valiela asked at an SMB meeting whether the Impact Area would be included in the assessment Ė and the answer was yes, the Impact Area would be included. Dr. York then explained that the issue is not the geographic area, however, itís whether or not the compound is a hazardous substance.

Ms. Pepin asked Dr. York to explain why Bruce Leighton hadnít come to this meeting, as requested by the IART. Dr. York explained that the primary reason is that it was assumed that the team would be most interested in Impact Area issues, and the Army, which he represents, is the lead on those issues. Ms. Pepin also asked why Jim Baker isnít at this meeting. Mr. Baker, who was in fact at the meeting, made his presence known and noted that he has relocated to the area and is working for Robert Gill at the Installation Restoration Program (IRP) office. He also noted that he was the one who suggested that Dr. York present at this meeting and provide the Army perspective.

Ms. Pepin asked whether trustees are appointed to an NRTC. Dr. York explained that by law certain federal organizations and states are designated trustees for natural resources Ė either because of their landholdings or because theyíre accountable for a certain type of natural resource. For example, Department of Interior is brought in because of flora and fauna, NOAA can be brought in because of migratory fish, and the Army, the Air Force, and the VA were brought in to this NRTC because they hold land and are responsible for the resources on that land. Ms. Pepin inquired about the specific people who serve as trustees. Dr. York replied that typically the secretary of a federal organization would either be the trustee or designate that trustee responsibility down to a lower level. He noted that he himself is a trustee representative designated by the Army trustee.

Ms. Pepin also noted that the return address for the Waste Policy Institute (WPI) was stamped on a mailing pertaining to the NRTC. She then asked Dr. York to describe the connection between WPI and the NRTC. Dr. York replied that he thinks WPI is the contractor who developed the CIP.

Mr. Dow asked whether the pre-assessment screen has gone forward for contaminants in the southern part of the base, such as volatile organic compounds (VOCs) and ethylene dibromide (EDB), which are hazardous substances. Dr. York replied that the IRP information and the Impact Area information was reviewed and those chemicals that were identified that were hazardous substances were placed in the preliminary pre-assessment screen. He said that other items that are not listed CERCLA hazardous substances, such as RDX, also were identified, although heís not sure that perchlorate had been found at that point. Dr. York explained that it was in the contractorís scope of work to identify each chemical as a CERCLA hazardous substance or something else Ė a pollutant, a contaminant, or a 21E contaminant.

Mr. Dow said that itís his understanding that the Army and Air Force trustees oppose moving forward from the pre-assessment phase to the assessment phase even for the southern part of the base. He then asked why that is, considering that known hazardous substances have polluted "42 billion gallons of groundwater" there. Dr. York replied that in the Armyís view, the major issue preventing the completion of the pre-assessment screen is the challenge regarding the RDX and perchlorate, which must first be overcome. He also noted, however, that there are other issues as well.

Mr. Dow recommended moving forward with the hazardous substance part and leaving the outstanding issue regarding RDX and perchlorate to be resolved at itís own pace. Dr. York replied that that is an excellent point. He also noted, however, that in terms of an NRDA, the NRTC at MMR probably is ahead of a normal schedule from the standpoint of one of the criteria used to determine whether to proceed to an assessment phase. He then read that criterion: "Response actions, if any, carried out or planned, do not or will not remedy the injury to natural resources without further action." Dr. York stated that the trustees really need to have an understanding of how well the groundwater treatment systems are going to perform in order to determine whether the injuries will be sufficiently addressed or whether thereís reason to move on to the next phase. Mr. Dow said that this is not true, and noted that even with remediation to background, lost use would have to be factored into an assessment.

Mr. Dow also mentioned that although the NRTC has a CIP, all of its meetings are held in Boston, not on Cape Cod. Ms. Garcia-Surette noted that NRTC meetings have been held on Cape Cod. Mr. Dow said that heís been following this process fairly closely for a number of years, and heís never heard of any NRTC meetings being held on Cape Cod. He suggested that the meetings should be advertised in order to have meaningful public involvement.

Ms. Grillo noted that a public meeting generally follows an NRTC meeting, and she doesnít anticipate that there would be a public meeting without an NRTC meeting first. Mr. Dow inquired about the notification process for the public meetings. Mr. Minior replied that notices are run in the local newspapers in advance of a meeting. Mr. Dow asked when the most recent meeting was held on Cape Cod. Dr. York replied that it occurred at least a year ago. Mr. Judge asked whether the subject of the RDX and perchlorate issue had been raised by the NRTC within the last year. Dr. York replied that it had, and noted that it was a major subject of discussion during at least one conference call.

Mr. Mullenix, a resident of Bourne, asked whether the Armyís position about RDX and perchlorate is that they canít be addressed because theyíre not listed hazardous substances, or that they canít be addressed because they donít have the characteristics of a hazardous substance. Dr. York replied that the reason is because theyíre not listed. He also noted, however, that "coming through the RCRA characteristic waste route" is one way they could be treated as a hazardous substance.

Mr. Mullenix asked for confirmation that the Army would accept RDX and/or perchlorate into the NRDA process if EPA puts forth "a Memorandum of Understanding or something like that" that determines that they have characteristics of a hazardous substance. Dr. York replied "of course," but added that he doesnít think it would be as easy as just a declaration on a piece of paper. Mr. Mullenix noted that he had asked the question about "a Memorandum of Understanding or a letter or something like that."

Mr. Judge said that he thinks itís important to keep in mind that tonight the IART has heard about the Armyís issue, but it hasnít heard about issues that the Air Force, the Department of Interior, or other voting members of the NRTC might have. Dr. York, without going into particulars about any other trustee, mentioned that the Air Force, as the administrative trustee, does have an issue in terms of a belief that the contractor didnít satisfy the statement of work. Mr. Judge stated that while the IART appreciates having Dr. York at this meeting representing the Army, several team members had asked for Mr. Leighton by name because he is the administrative trustee.

Mr. Minior asked Dr. York to clarify that the NRTC must vote unanimously in order to move the process forward. Dr. York clarified that itís written in the MOA that the NRTC "has to be unanimous" in its decisions.

Mr. Baker said that originally he was going to represent Mr. Leighton by providing an NRTC briefing to the IART; however, he turned the presentation over to Dr. York, the Army representative, because he hadnít been aware that there was an interest in discussing contracting issues. Mr. Judge explained that he wanted to have Mr. Leighton provide a briefing not because of contracting issues, but because of Mr. Leightonís role as an administrator Ė the one who "doles out" the money. Mr. Baker stated that Dr. York has provided accurate information in terms of how federal funds can and cannot be spent. He also said that he thinks the Army would welcome looking at RDX and perchlorate, should they become characteristic wastes. Dr. York stressed that the only restriction he sees is that federal funds canít be used. Other kinds of monies could be used, and the Army would cooperate with parties spending those funds.

Agenda Item #6: Agenda Planning and Adjourn

Mr. Murphy stated that because Ms. Hayes hadnít stayed until the end of the meeting, the "Media Coverage" item that she requested would be moved to a future meeting. He also noted that itís been suggested that the July IART meeting be canceled. Mr. Borci pointed out that only a few citizen members were in attendance tonight, and canceling the July meeting would give the technical team a chance to gather more data and put together some solid presentations for the August meeting. There were no objections to canceling the July IART meeting and the Groundwater Program office agreed to notify absent IART members of the cancellation.

Mr. Murphy adjourned the meeting at 9:12 p.m.

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