Impact Area Review Team

River River Drops of rain on a leaf

Impact Area Review Team
Oak Ridge School
Sandwich, MA
March 26, 2002
6:00 Ė 9:00 p.m.

Meeting Summary






Ben Gregson



LTC David Cunha

HQ Camp Edwards


Robert Gill



Bill Walsh-Rogalski



Todd Borci



Ellie Grillo



Len Pinaud



Jim Stahl



Tom Cambareri




Evelyn P. Hayes

Yarmouthport resident


Janet Pepin

Teaticket resident


Peter Schlesinger

Sandwich resident

Joel Feigenbaum



Richard Hugus

ABC/Falmouth resident








Jim Murphy









Pamela Richardson



Tina Dolen



Kris Curley



Jerrime Oliver

Camp Edwards


Brian Rogers

Dept of Army


Henry Byers



Millie Garcia-Surette




Bob Fagon




Cynthia Baran



Dave Williams




Jean Crocker



Laurie Dinnings




David Dow

Sierra Club



Tom Smith

Pocasset resident



Mary Smith

Pocasset resident



Kevin Dennehy

Cape Cod Times



Kim Harriz



Marc Grant



Mark Applebee



Eric Banks

Jacobs Engineering



Ken Gaynor

Jacobs Engineering



Jeff Carman

Jacobs Engineering



Dave Heislein

Harding ESE


George Peterson



Steve Denahan

Ellis Environmental


Mark A. Franson

Charter Oak


Dave Egan

IT Corp



Larry Hudgins

Tetra Tech


John Webster

Tetra Tech


Peter Redmond

Tetra Tech



William Boyce

Coastal Env. Corp.


R. Skrynesss



Rich Greiling



David Cobb



Doug Larson



Maureen Dooley



Lori Boghdan



Jane Moran



Action Items:

  1. EPA will e-mail to IART members the Textron "Administration Order by Consent" and associated workplans.
  2. Mr. Walsh-Rogalski requests that the IAGWSP change map legends that indicate that there is an MCL for perchlorate, which is not the case at this time.
  3. The IART asks that the IAGWSP test the Range Control well for perchlorate.
  4. The IART asks that maps showing the Bourne wells include groundwater contour lines.
  5. The IART asks that the IAGWSP look into ways to date groundwater where perchlorate is being detected in Bourne wells.
  6. The IART asks that the IAGWSP office update the perchlorate fact sheet as soon as possible.
  7. Ms. Pepin requests more information from EPA regarding the fertilizer with naturally-occurring perchlorate.
  8. EPA will e-mail to IART members the web site address for the Environmental Working Groupís report on perchlorate levels.
  9. The IAGWSP will test LRWS wells and well 95-14, which are located west of the Demo Area 1 plume, for perchlorate.
  10. The IAGWSP will provide the IART with the current schedule for the SE Ranges investigation.
  11. The IAGWSP will provide Mr. Dow with a copy of the HMX/RDX Fate and Transport Study.
  12. CH2M HILL will include in the next IART mailing a reminder that citizen team members are invited to attend a meeting with University of Connecticut representatives regarding new TOSC members on the team. That meeting will take place at 5:00 p.m., April 23, 2002, at the Bourne Best Western, just prior to the IART meeting.

Future Agenda Items:

  • Prescribed Burns (including burns in areas with UXO, and other DEP-permitted burns on Cape)
  • Status of Water Quality in the Northeast Corner of Camp Edwards
  • Fate and Transport Presentation
  • Gun and Mortar Firing Positions Workplans
  • Natural Resource Trustee Council Presentation
  • UXO Management Plan

Handouts Distributed at Meeting:

  1. February 26, 2002 Draft IART Meeting Minutes
  2. Responses to Action Items from the February 26, 2002 IART Meeting
  3. Fact sheet: EPA Perchlorate Update
  4. MMR Fact Sheet: Environmental Matters, October 2001, What is Perchlorate?
  5. Letter from Bruce Leighton re: Meeting with NRTC Representative
  6. Draft Impact Area Groundwater Study Program Update, March 2002
  7. Handout A: IAGWSP Investigation Update and Data Tables
  8. Handout B: Northeast MMR Groundwater Quality

Agenda Item #1. Welcome, Approval of February 26, 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 changes or additions to the February 26, 2002 IART meeting minutes. Mr. Hugus referred to the third line in the first full paragraph on page 17 and asked that the word while be changed to because. The minutes were approved with this change.

Mr. Murphy reviewed the agenda and asked if there were any comments from the team. Mr. Hugus asked that a discussion about the closing of the Joint Program Office (JPO) be added to the agenda. He said that in light of the current situation in Bourne, it seems an inappropriate time for the JPO, which has a commitment to replace water supplies lost on the Upper Cape because of base pollution, to be leaving the Massachusetts Military Reservation (MMR). Mr. Hugus also noted that he would like some time on the agenda for a follow-up discussion on treatment of the Demo Area 1 plume. Mr. Schlesinger requested that the team have five minutes during "Open Discussion" to set a date to meet with the Technical Outreach Services for Communities (TOSC) representatives from the University of Connecticut.

Mr. Murphy noted that neither COL Bleakley nor Ms. Larkin of the JPO were able to attend this meeting. He also mentioned that at tomorrow nightís Senior Management Board (SMB) meeting, COL Materia of the Environmental & Readiness Center (E&RC) would be discussing the JPO transition to the E&RC. LTC Rogers stated that although he is not from the JPO, he will be available at this meeting to discuss the transition. Mr. Hugus said that he sent out an e-mail on this topic a couple of days ago and he finds it irresponsible that the JPO does not have a representative at this meeting.

Agenda Item #2. Review Action Items

Mr. Murphy reviewed the action items from the February 26, 2002 IART meeting.

  1. As previously requested by the IART, an update on MW-181 will be provided to the team as soon as results are available, probably by the March meeting.
  2. Mr. Murphy noted that information on this item will be included in the mailing for the April 23, 2002 IART meeting.

  3. The IAGWSP will contact IART members by e-mail regarding whether monitoring wells at the Southeast Ranges have been tested for EDB.
  4. Mr. Murphy noted that an e-mail was sent out to team members on March 7, 2002.

  5. The IAGWSP will invite Denis LeBlanc of USGS to come to the next IART meeting to discuss "mound phenomena," particularly with respect to the benzene detection at MW-187D at the Southeast Ranges.

Mr. Murphy noted that a handout regarding this information was included in the recent mailing, and this topic will be discussed later in tonightís meeting.

Mr. Murphy asked if there were any comments on the action items.

Mr. Hugus referred to Action Item #1 and noted that the March 4, 2002 Weekly Progress Report contained an ambiguous sentence regarding isotopes and the original profile sample at monitoring well 181 (MW-181). He then gave a copy of the report, with the sentence highlighted, to Mr. Colby of AMEC, who said he would get back to Mr. Hugus later with an answer.

Mr. Hugus asked if the high-level concentration of benzene detected in a deep well at the top of the aquifer in the J Range area is going to be discussed tonight. Mr. Gregson replied that information regarding that well, MW-187, will be included in the "Investigations Update."

Dr. Feigenbaum said that he thought that there had been an action item about getting a report on controlled burns from the new administration of Camp Edwards. LTC Cunha replied that while he hadnít attended last monthís IART meeting, he can report that Camp Edwards requested and received from the Massachusetts Department of Environmental Protection (DEP) a five-year permit to conduct controlled burns. He also noted that this is going to be an agenda item at tomorrow nightís SMB meeting, to be presented by Dr. Ciaranca of the E&RC.

Dr. Feigenbaum asked if controlled burns would be conducted in areas where there are unexploded ordnance (UXO). LTC Cunha replied that the permit pertains to six areas. The reasons for the burns are to reduce the fuel for any wildfire and to assist in wildlife management, and seven or eight additional steps have to be taken before any actual burning is done. LTC Cunha indicated that controlled burns could be conducted in areas where UXO are present. Dr. Feigenbaum said that he is skeptical of any controlled burns that involve the Impact Area, which is the purview of the IART.

Mr. Cody added that the permit specifically stipulates that Installation Restoration Program (IRP) and Impact Area Groundwater Study Program (IAGWSP) projects would take precedence over the controlled burns, which arenít going to begin to occur until the fall. He suggested that questions pertaining to the controlled burns should be asked at tomorrowís SMB meeting. Dr. Feigenbaum disagreed and noted that the SMB is not a technical body. He said that it seems to him that the Guard is trying to circumvent the IART by going to the SMB directly with this issue. He added that he opposes this process and the fact that thereís been no public hearing regarding the burns. He also said that he thinks the burns should be the responsibility of the new Camp Edwards administration coming out of the Executive Office of Environmental Affairs (EOEA).

Mr. Pinaud reminded the team that pages 14 and 15 of the February 26, 2002 IART minutes contain his brief description of the permit criteria.

Mr. Schlesinger asked if controlled burns conducted in the recent past have had any effect on UXO in the Impact Area or elsewhere. Mr. Cody replied that he knows of no instances where ordnance exploded because of controlled burns at MMR. He also noted that the controlled burns involve massive coordination among Camp Edwards, the local fire departments, the Nature Conservancy, and Dr. Patterson of the University of Massachusetts, Amherst, who is an expert on controlled burns.

Dr. Feigenbaum noted that Ms. Wadsworth of the E&RC left a message on his answering machine, but hasnít yet spoken to him regarding answers to some of his questions about the controlled burns. Mr. Cody said that he would follow up with Ms. Wadsworth.

Mr. Murphy said that the specific question seems to be how the controlled burns relate to areas where UXO are present. He then asked that an answer to this question be made available by the next IART meeting. Dr. Feigenbaum said that he thinks it would be foolhardy to conduct controlled burns in areas with UXO. Mr. Cody stated that none of the research heís read shows that the fires get hot enough to actually detonate a round. Dr. Feigenbaum remarked that he thinks this is worthy of public discussion, which has not occurred. He suggested that DEP ought to be tasked to advocate for the IART members by finding out what the environmental effects from this kind of practice are likely to be.

Mr. Cody noted that controlled burns were addressed as part of the Final Environmental Impact Report (FEIR), for which there had been several public meetings, and as part of the Integrated Natural Resource Management Plan (INRMP), for which there had been public comment periods. He also mentioned the involvement of the Nature Conservancy and DEP and said that he believes that there was ample opportunity for public input. Dr. Feigenbaum asked if the possibility of controlled burns being conducted in areas with UXO had been discussed in those public processes. Mr. Cody replied that it had been discussed.

Dr. Feigenbaum said that he doesnít understand the Guardís interest in conducting the burns, and he doesnít believe that it should be the Guardís business to do so. He also said that he thinks that this issue is important enough that it should be an agenda item for the next IART meeting. He added that it seems to him that rather than EOEA taking over supervision of the base, the National Guard is taking over the concerns of EOEA.

Ms. Hayes said that while she can understand Dr. Feigenbaumís concern, the February 26, 2002 IART meeting minutes contain a clear statement regarding this issue. She then read the following paragraph from those minutes: "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 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 MMR that are targeted for prescribed burns." Ms. Hayes said that she anticipates that this is what the process is going to entail, and asked if she is correct in that regard. Mr. Cody replied that she is absolutely correct.

Ms. Garcia-Surette stated that the permit was issued by the Bureau of Waste Prevention, the Resource Conservation and Recovery Act (RCRA) group at DEP, but was done in close coordination with personnel from DEPís Bureau of Waste Site Cleanup. She added that DEP also worked with the military "to ensure that itís done in a correct way."

Mr. Hugus stated that he doesnít agree with the policy of conducting controlled burns in the Impact Area where UXO are present.

Mr. Cambareri asked if the controlled burns were discussed at the Environmental Management Commission (EMC) meeting on March 6. 2002. Ms. Garcia-Surette replied that details regarding the permitting process are outside the purview of the EMC; therefore that kind of conversation probably wouldnít come up at this point in time, during the formative stages. Mr. Cambareri said that he thinks that at least specific instances of controlled burns could use more public notice. Ms. Garcia-Surette said that she and Dr. Ciaranca talked a little about that at the Citizens Advisory Council (CAC) meeting.

Ms. Crocker said that wildlife management by the Guard is one of the basic goals in the INRMP. She also said that controlled burns are a standard method used in wildlife management.

Dr. Feigenbaum asked where else on Cape Cod DEP has issued permits for controlled burns. Ms. Garcia-Surette replied that she is not aware of other permits issued on Cape Cod, as she works for the Bureau of Waste Site Cleanup Ė not the Bureau of Waste Prevention, which issues the permits. However, Mr. Pinaud reported that controlled burns have happened elsewhere on Cape Cod, including Marthaís Vineyard, Nomans Island, the Cape Cod National Seashore, and Washburne Island.

Agenda Item #3. Late-Breaking News

Mr. Walsh-Rogalski announced that the U.S. Environmental Protection Agency (EPA) and Textron have entered into an agreement, or order, under the Safe Drinking Water Act (SDWA) whereby Textron will conduct a limited response action at the J-3 Range. The work, which is scheduled to begin very soon, consists of sampling at two buildings that were used by Textron when it was resident on the range, as well as excavation and disposal of some empty crushed drums left by Textron at the J-3 Range. Mr. Walsh-Rogalski said that the commitment right now is for Textron to conduct this limited amount of work, which it came forward and offered to do.

Mr. Hugus asked if this work is an outcome of ongoing litigation relating to Textron. Mr. Walsh-Rogalski replied that the work is unrelated to any kind of court proceedings. Rather, Textron realizes that it is responsible in part for some things that happened at the base, particularly on the J-3 Range; EPA and Textron are building what appears to be a cooperative relationship.

Mr. Schlesinger asked if test results from sampling at the buildings will become part of the Impact Area Groundwater Study. Mr. Walsh-Rogalski replied that the data will be wrapped into the study, and will become public. Mr. Schlesinger asked if Textron will conduct any necessary cleanup. Mr. Walsh-Rogalski said that Textron hasnít committed to that, but it remains a possibility. He added that he thinks Textron is being cooperative and cautious at the same time.

Mr. Murphy noted that the order and associated workplans will be posted on the EPA web site by the end of this week, and will be e-mailed to IART members within the next two days.

Agenda Item #4. Investigations Update

Update on Perchlorate Detections in Bourne

Mr. Gregson noted that at the February IART meeting he had reported perchlorate detections in four wells: MW-180, which is a far-field well at the base boundary, and Bourne sentinel wells 97-1, 97-2, and 97-5. Detections in those sentinel wells had ranged from 0.45 to 0.74 parts per billion (ppb); sentinel well 97-3 had been nondetect. Mr. Gregson stated that since that time, close to 40 existing monitoring wells have been sampled, and a drilling program has begun.

Mr. Gregson stated that Bourne production wells have been sampled on a biweekly basis and all had tested clean up until last week when perchlorate was detected at 0.48 ppb in production well #4. Sampling results that became available today showed that well #4 was nondetect; however, perchlorate was detected in production well #3 at about 0.4 to 0.5 ppb. Mr. Gregson noted that the IAGWSP is using a 1.5 ppb standard for perchlorate in its feasibility studies, and EPA has issued some toxicological information for peer review that would translate into a drinking water standard of 1.0 ppb. He also mentioned that the Bourne Water District had shut down those production wells a couple of weeks ago, prior to the detections, as a precaution in light of the upgradient perchlorate detections. Mr. Gregson stated that his office has been working closely with Bourne Water District and its consultant to review test results and plan next steps.

Mr. Gregson then reported that to date three new monitoring wells have been drilled and profiled: MW-02-1 came back clean in profile sampling; MW-02-2 had perchlorate detections in profile samples; and MW-02-3 had perchlorate in one profile sample. He noted that screens have been set at the locations of those perchlorate detections and at depths that correspond to production well intake screen depths, and regular groundwater samples will now be collected from those wells.

Mr. Gregson further reported that sentinel well 97-5 is being sampled biweekly and continues to have perchlorate detections between 0.6 and 0.8 ppb. Sentinel wells 97-2 and 97-1, where the initial perchlorate detections occurred, have been clean over the last two sampling rounds. Another result that came back today was a perchlorate detection of 0.39 ppb at a previously existing well, MW-1-88. Mr. Gregson also noted that the drilling of MW-02-5 was just completed, and a number of well locations are yet to be drilled as part of the program, including locations upgradient of production well 1A and south of sentinel well 97-5.

Mr. Gregson stated that in conjunction with field actions, archival research and munitions survey work is being done in an attempt to determine the source of the perchlorate. He noted that particle tracks go back to the general vicinity of the southwest part of the Impact Area, and historical photos are being examined and some field reconnaissance work is planned. Mr. Gregson also stated that by the next IART meeting all the monitoring wells that are part of the current program will have been installed and sampled, resulting in a better understanding of the extent of perchlorate in that area.

Mr. Hugus mentioned that the Weekly Progress Reports indicate that some profile samples showed explosive materials that werenít confirmed by the photo-diode array (PDA) spectra. Mr. Gregson said that some profile samples have shown perchlorate and explosives that were not confirmed by PDA; those are considered to be false positives and not real detections.

Mr. Walsh-Rogalski suggested that map legends that indicate the existence of a health advisory or maximum contaminant level (MCL) for perchlorate should be modified, as such is not the case. Mr. Gregson replied that this can be clarified.

Mr. Cambareri noted that the Weekly Progress Report mentions particle tracks that reach about 8000 feet upgradient. Mr. Gregson stated that several particle tracks have been run, which, because of the varying depths of detections, go back to different locations Ė anywhere from the southern part of the Impact Area out to a point about half-way between the Impact Area boundary and the base boundary. He also noted, however, that the IAGWSP is looking at a 500-acre area that has been established as a potential source area.

Mr. Cambareri inquired about testing for perchlorate in the Central Impact Area using the new lower detection limit. Mr. Gregson replied that a number of wells in the Central Impact Area have been tested for perchlorate using the lower detection limit, and, as heís reported at recent IART meetings, perchlorate detections are being seen in the central part of the Central Impact Area, along Turpentine Road and Tank Alley. Mr. Cambareri inquired about wells along Burgoyne Road. Mr. Gregson said that he doesnít believe there have been any perchlorate detections along Burgoyne Road. Mr. Cambareri explained that he is curious to know how far outside the MMR boundary perchlorate detections can be found. He suggested that it would be prudent to test monitoring wells installed for the Bourne landfill, which are downgradient of the Central Impact Area. Mr. Gregson noted that the area of perchlorate contamination seems to be relatively narrow; perchlorate is not being detected in every well sampled in that area.

Mr. Hugus commented that if the perchlorate detections in Bourne originated anywhere in the southwest corner of the Impact Area, that plume would be comparable in length to plumes originating in the southern part of the base. Mr. Hugus also asked if the IAGWSP has tested the new Range Control water supply well for perchlorate. Mr. Gregson replied that it has not, but added that it would be a good testing location. Mr. Hugus asked why a new supply well was installed. LTC Cunha explained that the other well had been very shallow and had run dry, so a new well was drilled. Mr. Hugus recommended holding off on consuming water from the Range Control well because it could potentially lie in the path of a plume of perchlorate coming from the Impact Area.

Mr. Hugus asked if the sentinel wells were tested for volatile organic compounds (VOCs). Mr. Gregson said that some below-MCL VOC detections were seen in profile samples that were collected, but it remains to be seen whether those will hold up in real groundwater samples.

Dr. Feigenbaum inquired about the direction of groundwater flow in the area of the Bourne wells. Mr. Gregson replied that groundwater flow direction is about due west in that area. Dr. Feigenbaum observed that there appears to be a radial flow out from what is usually thought to be the center of the mound. He also said that it would be helpful to the team if groundwater contours were shown on maps.

Dr. Feigenbaum then asked if the Air Force Center for Environmental Excellence (AFCEE) is testing for perchlorate at Bourne wells 2 and 5 and their associated sentry wells, which are located in the Landfill 1 (LF-1) plume area. Mr. Gill replied that AFCEE has sampled for perchlorate in the LF-1 plume, and currently is working in conjunction with Bourne Water District to resample the sentry wells and wells 2 and 5, using the new lower detection limit for perchlorate, rather than the old limit of 1.8 ppb. He also noted that AFCEE had seen a perchlorate detection close to the landfill source area itself, which will continue to be monitored using the more exacting standard.

Ms. Hayes asked if the IAGWSP was prepared for and could explain the rapidity with which the perchlorate seemed to have moved into the area of the Bourne production wells. Mr. Gregson acknowledged that the contamination does appear to have reached the production wells rapidly. He also noted, however, that a year ago, with the higher detection limit, none of the recent detections would have been seen. He said that he thinks the biggest function of finding the detections has to do with lowering the detection limit over the past six months or so.

Mr. Dow asked if itís possible in this situation to determine how long ago the groundwater layers where perchlorate is being detected were at the surface. Mr. Gregson said that he would have to get an answer to this question. Mr. Dow then asked if there are any conservative tracers that could be used to track the Impact Area plumes, given that perchlorate is being measured down near the analytical level of detection. Mr. Gregson replied that he doesnít have the answer to this, other than to say that perchlorate is a pretty conservative tracer in itself. Mr. Dow said that he just wonders if thereís something that could be used to measure the distance that the plume might have traveled, after which the focus could be on measuring those low levels of perchlorate,

Mr. Schlesinger said that if itís possible to date the water and something is known about the flow, then it would be known how far to backtrack. He then inquired about the sampling frequency of wells upgradient from the recent perchlorate detections. Mr. Gregson pointed out a group of wells for which an initial sampling round was conducted, and also noted that the "97" well series is being sampled biweekly. Mr. Schlesinger also asked about the sampling frequency of downgradient wells, such as MW-001 and MW-012. Mr. Gregson replied that those wells have been sampled once, but a decision on sampling frequency hasnít yet been made.

Mr. Cambareri asked if anything new has been learned about the hydrogeology in the area, given that the detections are shallower there. Mr. Gregson replied that there appears to be a bedrock high in that area where depth of bedrock is between 100 and 150 feet below ground surface, which affects groundwater flow. He noted that this information is being worked into the groundwater model. Mr. Cambareri said that heís read that particle tracks have been traced back as far as 8000 feet. He asked how many years that would be in travel time. Mr. Gregson replied that he thinks it would be somewhere between 10 and 20 years.

Mr. Cambareri suggested that some thought be given to the possibility that the perchlorate detections might be the trailing edge of a contaminant plume. He said that he thinks it would be prudent to take a look at areas farther out from MMR, and do some more investigation thatís "out of the box."

Ms. Crocker asked if itís known whether the concentrations of perchlorate that are being detected are harmful to human health. Mr. Gregson replied that he doesnít know the answer to that and has been asking the same question. He noted that EPA currently is working on establishing a national drinking water standard for perchlorate, but the timing on that is off for the purposes of this study. He also mentioned again that the IAGWSP is using a level of 1.5 ppb for perchlorate in its feasibility studies.

Mr. Cambareri said that he thinks that the fact sheet, "Environmental Matters Ė Perchlorate" needs to be updated and revised in order to better educate the public. Mr. Gregson noted that a revised version was just completed today. He also mentioned that an EPA fact sheet on perchlorate, dated March 2002, was distributed to team members earlier this evening. Dr. Feigenbaum asked who was responsible for the "Environmental Matters Ė Perchlorate" fact sheet, which he considers to be a fatuous document. Mr. Gregson replied that the IAGWSP office puts out that fact sheet, which is first reviewed by EPA and DEP.

Mr. Schlesinger noted that EPAís fact sheet includes a statement that perchlorate is both a naturally-occurring and manmade chemical. Mr. Gregson said that he is not aware of any naturally-occurring sources of perchlorate on Cape Cod. Mr. Borci explained that the fact sheet was put together by EPA Region 9, which includes California, where there are many ongoing perchlorate issues. He said that thereís a Chilean fertilizer thatís been found to contain some low level of perchlorate; however, itís never been proven that perchlorate from this source has made it into the groundwater. Ms. Pepin asked Mr. Borci to provide her with a reference to that Chilean fertilizer at some point in the future. Mr. Borci agreed to do so.

Mr. Dow mentioned that the Environmental Working Group, which is located in California, has concluded that to protect childrenís health the MCL for perchlorate should be 0.4 to 0.5 ppb. He noted that the report is published on the Environmental Working Groupís web site, and he agreed to provide that web site address to Mr. Murphy, who would distribute it to the team.

Mr. Hugus indicated that he is concerned that the JPO, which in his view is a direct representative of the Pentagon, is about to leave MMR at the same time that the Town of Bourne is losing what he understands to be 70% of its water supply due to the closing of production wells affected by perchlorate contamination. He also mentioned that two other Bourne production wells are threatened by the LF-1 plume. Mr. Hugus said that his understanding is that the JPO was sent to MMR by Ms. Goodman, then Assistant Secretary of Defense for Environmental Security, to make good on water supplies lost on the Upper Cape due to pollution from the base. He noted that the Upper Cape Water Cooperative set up by the JPO will provide 3 million gallons of water a day; however, the original agreement was for at least 8 million gallons a day. Mr. Hugus said that he thinks itís unfair for the JPO to hand over its responsibilities to the Massachusetts National Guard, which doesnít have the same resources as the Pentagon. He also remarked that before the JPO leaves, the residents of Cape Cod should insist that the Department of Defense (DoD) enter into a legally binding agreement to make good on its commitment to replace water supplies that have been lost.

LTC Rogers noted that he works for Mr. Fatz, the Deputy Assistant Secretary of the Army for Environment, Safety and Occupational Health. He then stated that the JPO began transitioning its work to the E&RC last July. He also clarified that the JPO charter signed by Ms. Goodman indicated that the JPO was not intended to be a permanent office, but was to remain in place until the environmental restoration programs on MMR had reached maturity. LTC Rogers further clarified that the E&RC is in fact funded by the Pentagon, not by the Massachusetts National Guard, and the Pentagon will be represented through the E&RC. He said that the Pentagon is committed to cleaning up and taking care of the environment at MMR. He also noted that Hap Gonser, who had handled water issues at the JPO, is moving over to become a member of the E&RC.

Mr. Hugus asked why a transition is being made if the E&RC will be doing the same things that JPO did. LTC Rogers explained that the IRP is reaching maturity; at some point all the treatment systems will be running and the Air Force will no longer be at MMR, thereby eliminating the need for the JPO. He noted that the Army is in charge of the IAGWSP, the main cleanup program that will remain once AFCEEís gone. He also said that oversight of the IRP treatment systems would likely become the responsibility of the U.S. Army Corps of Engineers.

Mr. Hugus asked if LTC Rogers could give his assurance that there will be a legally binding agreement from the Pentagon to replace water supplies that have been contaminated by the base. LTC Rogers replied that he could not make that promise; rather, the Board of Directors at the Pentagon, which is chaired by Mr. Woodley at DoD, would make that kind of decision. He also stated, however, that there is commitment and funding from the Pentagon to do what needs to be done to clean up the water supply on the Cape. Mr. Hugus maintained that he would like to see a legally binding agreement from the Pentagon, and added that the people of Bourne are entitled to replacement for wells lost because of base pollution. LTC Rogers noted that his office has been working closely with the Town of Bourne to ensure that it does have a water supply that meets its needs.

Dr. Feigenbaum said that he commends the Bourne Water Commissioners Ė and Mr. Marks in particular Ė for taking a proactive stance and closing production wells, without getting involved in polemics about what level of hazard is truly hazardous. Dr. Feigenbaum asked if LTC Rogers is located on Cape Cod. LTC Rogers replied that he is not located here, but is on MMR on a weekly or biweekly basis. He also noted that his e-mail address is available on the meeting sign-in sheet.

Dr. Feigenbaum questioned whether EPA has the authority under the SDWA to order the Army or Army Guard to compensate the Town of Bourne or any other town, which might be similarly affected by contaminants coming from the Impact Area. Mr. Walsh-Rogalski replied that under the SDWA, EPA has authority to order the Army or the Army National Guard to find replacement water supplies. Whether EPA has authority to order compensation is a legal question that he hasnít thoroughly researched yet.

Mr. Walsh-Rogalski said that he hears LTC Rogers saying that the Pentagon is committed to making the Cape communities 100% whole. He then asked if itís correct that this is what LTC Rogers is saying. LTC Rogers replied that what he is saying is that "weíre going to work within our powers to take care of the water supply." Mr. Walsh-Rogalski said that to make the communities whole would not mean wellhead treatment, but would entail finding alternative supplies if needed and bringing the communities back to 100% capacity. He then said that he would request that the Pentagon provide a clear answer to the question of whether or not it intends to make the communities 100% whole, as, he believes, Ms. Goodman promised to do. Mr. Hugus clarified that it was Tad McCall of the Pentagon who first used the phrase "make the Cape whole." LTC Rogers said that be believes the phrase also has another meaning Ė restoring the aquifer underneath MMR, which is what the IRP and IAGWSP are doing.

Mr. Cambareri asked if the DoD plans to install a distribution line from the Upper Cape Water Cooperative system to the Town of Bourne, and do so quickly. LTC Rogers replied that there are several options to replace the water supply, and itís up to the Bourne water commissioners to decided what they want to have in place. Mr. Cambareri asked how Bourne would be hooked up to the Cooperativeís system by this summer, if thatís what the commissioners decide they want to do.

Mr. Gill stated that AFCEE had a legally binding agreement with the Town of Bourne to provide money to the town to find replacement for wells 2 and 5, which are threatened by the LF-1 plume. He said that tomorrow he will be meeting with the Bourne Water District to discuss ways that AFCEE can be flexible so that Bourne can use that agreement and that specific amount of money to best address its present needs. Among the options to consider is a connection to the Upper Cape Water Cooperative system, but the time it would take to do that would depend on when that decision is made, when contracts could be put in place, and so forth. Mr. Cambareri said that he would hope that the military would find a way to move that project forward quickly. He added that it would be "a straight shot down Connery Avenue to Bourne."

Ms. Crocker said that she believes that the Natural Resource Trustee Council (NRTC) would have the final word on compensation issues, and she thinks it would be good if the NRTC met on the Cape again rather soon. Ms. Crocker also commended the IRP and the IAGWSP and their contractors, as well as the leaders in the Town of Bourne, for doing a wonderful job of dealing with the recent problems.

Dr. Feigenbaum asked if itís correct that Bourne wells 2 and 5 are still running. Mr. Marks, Superintendent of Bourne Water District, replied that wells 2 and 5 are running, but at reduced rates. He also clarified that well stations 3 and 4, which are now shut off, account for 25 to 30% of the townís water, not 70%. He said that currently the Bourne Water District is working on an emergency hookup to Sandwich at a maximum of 300 gallons per minute, and is looking into the possibility of temporarily using WS-4, one of the wells that was installed as part of the Upper Cape Water Supply project. However, a water main hookup to the Upper Cape Water Cooperative system is the big issue, yet thereís a problem about whether the "green" or "blue" will pay that bill. Mr. Marks said that tomorrow Mr. Gill is going to recommend that the Bourne Water District take some money from wells 2 and 5 replacement and use it to install the water main, which is the easiest way to get that done. He also remarked that the water main should already have been started, and how thatís funded Ė whether in part by the jail thatís to be built on base or by the "green" or the "blue" Ė should not have to be the Bourne Water Districtís problem or concern. Mr. Marks also noted that in the last month the Bourne Water District probably has spent about $40,000 on engineering costs, and he would like to know who is going to pay those bills.

Mr. Marks said that he thinks the most important thing is to get a water main installed immediately, and if the Board of Water Commissioners agrees, he will take the funds from the wells 2 and 5 replacement to get that job started. He also stated that the Bourne Water District and the Board of Water Commissioners is only asking to be whole again Ė to get back to the six sources that were expected to take the town through to 2020, after which a connection to the Cooperativeís system might have been needed.

Dr. Feigenbaum stated that although itís very noble of AFCEE to allow money that was supposed to be earmarked for replacement for wells 2 and 5 to be used to pay for contamination caused by the Army, it is not a coherent way to do business. He said that he thinks that money should be kept in reserve for wells 2 and 5 replacement, and new "green" monies, from the Army, should be used for the water main. He added that this is the first time that the Army side is being asked to come up with money to pay any town for lost water, and therefore itís an important test case.

Dr. Feigenbaum also remarked this is not a good way to start out what is being billed as a "seamless shift of responsibility" from the JPO to the E&RC. He said that at least with the JPO there was someone sitting above the different colors Ė now, however, thereís a possibility that the services will be looking out for their own interests, rather than working together. Dr. Feigenbaum further noted that LTC Rogersís statement that remedying the condition of the groundwater under MMR constitutes making the Upper Cape whole is not an accurate characterization of what has happened or of whatís been promised. He noted, for example, that most of AFCEEís work doesnít pertain to the aquifer under MMR, but to that part of the aquifer that affects the surrounding communitiesí drinking water and surface water bodies. Dr. Feigenbaum said that that he had thought that the commitment was to restore all of the Upper Capeís drinking water and protect its surface water bodies Ė not just take care of what lies between the borders of MMR.

Mr. Gill clarified that the IRP cleanup is joint funded between the Army (about 40%) and the Air Force (about 60%). While AFCEE is acting as an agent for both the Army and the Air Force in its agreement with the Bourne Water District, the money involved is not all Air Force money.

Dr. Feigenbaum asked what would happen in the event that wells 2 and 5 have to go off line, and the replacement moneyís already been spent. LTC Rogers explained that the thought behind using that money now was to ensure that Bourne has the water it needs for the summer; it still needs to be determined how to ensure that Bourneís long-term needs will be met, which was the focus of earlier meetings today. He gave his assurance that no one is trying to shift responsibility from one program to another; rather, everyone is working together to take care of the immediate need and look at a long-term solution. LTC Rogers also said that he realizes that a great deal of contamination has traveled off base, and his statement about the aquifer just under MMR was a misrepresentation. He said that knows that cleaning up the water under MMR is only part of what needs to be done to make the Cape whole.

Mr. Hugus said that there seems to be a set of legal problems pertaining to the question of whether the Army or the Air Force should pay for Bourneís lost water supply. He added that he thinks this is an Army responsibility, being administered under the SDWA, and he doesnít want to see that change. He said that he would like to know more about those legal issues and why theyíre proving to be so difficult to resolve.

Mr. Walsh-Rogalski stated that when the Bourne wells first were clearly threatened, there was some discussion as to whom should do the work. EPA believed that the National Guard Bureau (NGB) should do the drilling because it had drill rigs at the ready and the lab capacity to detect perchlorate at low levels. With respect to connecting to the Water Cooperative system, EPA looked to AFCEE, whom, because of its experience in providing towns with water line hookups and the like, had the legal instruments in place to do that. Mr. Walsh-Rogalski said that the NGB has been very responsive to the immediate need and AFCEE has been very responsive to the next order need. He also said that the outstanding compensation issues are somewhat legally complicated. He added that with respect to Bourne residents getting water immediately, things are progressing as they should be; but with respect to making the community whole and determining the color of the money, things still need to be hammered out. Mr. Hugus remarked that the $40,000 in engineering costs that Mr. Marks mentioned should not be allowed to be a burden on the town.

Ms. Hayes noted that she is relatively new to the IART, and had requested to join the team because her family has lived in Bourne for over 30 years. She also said that she can understand being confused by the aphorism "making the Cape whole" and suggested that it should be delineated more precisely. Ms. Hayes also said that she thinks LTC Rogers has been very courteous and helpful.

Mr. Murphy announced the start of a 10-minute break. He also noted that the agenda item "Status of Water Quality in the Northeast Corner of Camp Edwards," which was scheduled for tonight, will probably have to be postponed to the April IART meeting.

Recent Detections Ė Demo Area 1

Mr. Gregson reported a detection of perchlorate at 1.55 ppb in MW-162, which is located along the southern edge of the Demo Area 1 plume. He said that this was a significant finding because itís the southernmost detection of perchlorate on that edge of the plume and will mean revising the plume width by more than 100 feet, to the south. He also reported what was an unexpected detection of perchlorate in the middle screen at MW-173, one of the three wells drilled along Pew Road to define the downgradient extent of contamination. The concentration of that detection was 0.6 ppb, and resampling yielded a perchlorate concentration of 0.7 ppb. Mr. Gregson noted that this was the westernmost perchlorate detection seen in the Demo Area 1 plume.

Mr. Gregson stated that his office has been working with the regulators to determine next steps in response to these detections. Some wells to the north will be sampled to ensure that the plume width there has been established, and the D1P9 well location, which is 600 feet west of Frank Perkins Road, will be drilled. Based on results from that well, future steps, including an additional well location south of MW-173, will be decided.

Dr. Stahl stated that, as team members have been saying for about a year, the Demo Area 1 plume does in fact seem to be tending to the south a little more than had been depicted. He then asked if southern wells such as MW-139 and MW-172 will be tested for perchlorate. Mr. Gregson replied that it does make sense to drill a well south of MW-173 and to look at sampling other southern wells.

Mr. Hugus remarked that it appears to him that the promised four-month timeframe to define the Demo Area 1 plume is going to have to be extended. He noted that at the last IART meeting team members raised the question about starting treatment at the 100 ppb contour area of the Demo 1 Area plume in order to begin getting as much mass out as soon as possible. He then asked how EPA and the Guard feel about their commitment to a four-month timeframe now that more contamination has been found.

Mr. Borci stated that despite this new information, the plan is to still try to meet that four-month goal to define the plume. He also noted that, as he said at the last IART meeting, treating the higher concentrations in the center of the plume wonít speed overall remediation; it wonít collapse the edges any faster. Mr. Borci also said that once the plume is defined, if it becomes necessary to put together some new alternatives that involve spot treatment that will be done.

Mr. Gregson said that he would echo Mr. Borciís comments. He also said that he is particularly concerned about defining the extent of contamination because there may be other actions to be taken in response to the perchlorate issue, separate from the Royal Demolition Explosive (RDX) in the core of the plume.

Mr. Hugus commented that heís very skeptical about four months being enough time to define the extent of contamination.

Mr. Schlesinger asked why D1P9 appears so far north on the figure. Mr. Gregson explained that D1P9ís location is depicted incorrectly on the figure, and should in fact appear right at the dash of the label for MW-165. Mr. Schlesinger asked if there are plans to drill wells along Fredrikson Road to look for the toe of perchlorate. Mr. Gregson replied that a decision to drill wells along Fredrikson Road would be based on what is seen in the well to be drilled south of MW-173.

Dr. Feigenbaum stated that he doesnít think that the leading edges of RDX and perchlorate will be characterized in the foreseeable future Ė and certainly not in the next four months. He said that this is why he thinks the process to remove the high-concentration part of the plume should begin, and added that in this way the program would gain experience designing and building workable treatment systems for RDX and perchlorate. Dr. Feigenbaum noted that the startup date keeps moving farther away, and he, Mr. Hugus, and others are urging the Guard to get moving on a treatment system right away.

Mr. Pinaud said that he doesnít think that the perchlorate detection at MW-173 has changed DEPís opinion, as expressed in its comment letter on the feasibility study. He said that in order to expedite remediation, itís necessary to expedite finding where the plume ends; the sooner thatís done, the sooner it can be determined how to clean it up.

Dr. Feigenbaum noted that a much different strategy was used for the Chemical Spill 10 (CS-10) plume, which is being cleaned up in parts by about four different treatment systems. He said that the process to find the leading edge of the Demo Area 1 plume will take a long time. He added that he doesnít think itís necessary to clean up the plume in one fell swoop with one comprehensive design and added that that is not the way things have worked in other plumes. Mr. Pinaud said that he too wants to see an expedited schedule; however, the plume needs to be well characterized before it can be cleaned up.

Mr. Cambareri asked if existing wells LRWS-1 and 95-14, which are west of MW-173, have been tested for perchlorate. Mr. Gregson replied that they have not. Mr. Cambareri said that he thinks they should be tested right away. Mr. Gregson agreed to see that those wells are sampled.

Mr. Schlesinger asked how the toe of the plume would be defined in this case. Mr. Pinaud replied that his understanding is that the IART defines plumes to nondetect, and he thinks that defining the toe of perchlorate at the Demo Area 1 plume would be consistent with the way things are done throughout the Impact Area.

Recent Detections Ė Southeast Ranges

Mr. Gregson reported that in MW-193, which is located upgradient of the melt/pour building, RDX was detected at 0.36 ppb and perchlorate was detected at 0.71 ppb in the shallow screen, and in the intermediate screen perchlorate was detected at 7 ppb and High Melting Explosive (HMX) also was detected. In the shallow/intermediate screen of MW-197, RDX was detected at 0.31 ppb, HMX was detected at 7 ppb, and perchlorate was detected at 34 ppb. In the next deeper screen of that well, perchlorate was detected at 1.5 ppb. Also, in MW-198, which is downgradient of the detonation pit area in the J-3 Range, perchlorate was detected at 311 ppb in the intermediate well screen. In the next deeper screen of that well perchlorate was detected at 41 ppb and RDX was detected at 14.7 ppb.

Mr. Schlesinger inquired about the specific depths of the well screens. Mr. Gregson replied that the 311 ppb perchlorate detection was in a screen 40 to 50 feet below water table, and the next deeper screen, where the 41 ppb perchlorate detection occurred, was 75 to 85 below water table. Mr. Schlesinger then asked about particle tracking. Mr. Colby of AMEC reported that some preliminary backtracks run from MW-198 and MW-197 terminate quite close to the two wells in the detonation pit area. It seems likely that the perchlorate detections seen in those two northern wells are associated with the recent detections. Mr. Schlesinger asked if more wells are going to be drilled. Mr. Gregson replied that as part of the investigation work at the J-1, J-3, J-2, and L Ranges, about 24 additional wells are going to be installed.

Mr. Hugus said that he believes it was indicated in a Weekly Progress Report that the perchlorate detection at Snake Pond is related to perchlorate detections in the northern wells. Mr. Colby clarified that the most recent plume map for perchlorate shows those detections as disconnected. However, he suspects that as more information becomes available, some connection might be found between the northern perchlorate detections and the ones at MW-54, which is fairly close to the north end of Snake Pond. Mr. Colby added that he thinks it would be a bigger stretch to find out that the single perchlorate detection in the drive-point sample in Snake Pond is connected.

Mr. Hugus asked why the 311 ppb detection of perchlorate occurs in the middle of a line of perchlorate detections. Mr. Gregson said that it might be because the source area has depleted and higher concentrations have migrated to the south with the plume. Mr. Hugus said that he thinks this is a very serious issue, which should be at the top of next monthís IART agenda.

Mr. Borci noted that the 311 ppb perchlorate detection at the Southeast Ranges is similar to the 300 ppb perchlorate detection at Demo Area 1, and it might have a similar source Ė the detonation pit. He also mentioned a Minuteman missile test site near the detonation pit, and noted that Minuteman missile propellant contained perchlorate. Mr. Borci said that itís hoped that data from the 24 new wells will lead to a better understanding of contaminant flow and contours.

Dr. Feigenbaum asked if itís correct that itís being suggested that a perchlorate source area might actually "dissolve" because itís soluble and the high concentration area would move down. Mr. Borci indicated that this is correct, and Mr. Gregson added that perchlorate is a salt so itís very soluble. Dr. Feigenbaum then asked if a timeline for completion of the Southeast Ranges remedial investigation has been drawn. Mr. Gregson replied that there is a schedule for upcoming work, but he doesnít know off the top of his head what the specific points on the timeline are. He also noted that the Southeast Ranges investigation isnít as far along as the Demo Area 1 investigation. Dr. Feigenbaum asked how the RDX plume "coming down into Snake Pond" relates to the perchlorate contamination in that area. Mr. Gregson replied that, "they pretty much overlay." He also noted that he would see that a schedule for the Southeast Ranges investigation is made available to the team for the next IART meeting.

Mr. Dow asked if a fate and transport study for perchlorate is in the works. Mr. Gregson replied that it is not, but is something that could be considered. He also noted that a function of perchlorateís rapid dissolution is that it definitely has a quicker transport time through the unsaturated zone than do RDX and HMX. Mr. Dow inquired about a completion date for the RDX/HMX fate and transport study. Mr. Gregson replied that it has already been completed, distributed to the team, and made available to the public. He also said that he would see that Mr. Dow receives a copy of that study.

Recent Detections Ė Central Impact Area

Mr. Gregson stated that there was an RDX detection at 4.14 ppb in MW-201, which is downgradient of CS-19. A particle backtrack from that location goes back to an area between CS-19 and Turpentine Road.

Mr. Gregson noted that the remaining detections heíll be discussing occurred in profile samples. At MW-203, on Burgoyne Road, RDX was detected at 1.1 ppb. At MW-204, detections in profile samples ranged from 0.27 to 0.42 ppb. At MW-206, which is located in the upper target area of the former Anti-tank Gravity Range, RDX was detected at below-health advisory levels ranging from 0.3 to 1.9 ppb. At MW-207, which is located downgradient of MW-23 where there have been historical detections of RDX at less than 10 ppb, RDX was detected in profile samples at levels from 1.4 to 23 ppb. At MW-208, located on Wood Road, RDX was detected at 0.99 ppb. Mr. Gregson noted that 3-nitrotoluene also was detected in a profile sample from MW-208, but that detection is not expected to hold up in a regular well sample.

Mr. Hugus said that it appears to make sense to integrate the little "finger plume" near MW-207 with the whole Central Impact Area plume. Mr. Gregson assured him that the plume shells will be refined based on new information.

Mr. Cambareri suggested that some consideration be given to installing a set of far-field wells along Burgoyne Road, given the situation with water supply and the need to evaluate a secure clean area.

MW-187 Update

Mr. Gregson noted that at the last IART meeting he had reported above-MCL detections of benzene and chloromethane in the deep screen of MW-187 at the J-1 Range, as well as detections of other petroleum-related VOCs such as toluene, xylene, and ethyl benzene, and semi-volatile organic compounds (SVOCs) such as naphthalene. He reported that the second sampling round at that well showed similar results, but also included a detection of methyl tertiary butyl ether (MTBE) at 30 ppb, which is above the MCL of 20 ppb. Mr. Gregson stated that fingerprint results point to a source indicative of multiple fuel types; however, the lab maintains that there are some inconclusive results.

Mr. Gregson stated that next steps in this area include installing a downgradient well, Central Impact Area Plume well 11 (CIAP-11); looking at particle tracking from MW-187; and installing a number of additional wells as part of the J Range investigation and profiling them to bedrock.

At this time, Mr. Murphy stated that the meeting needs to come to an end. Mr. Gregson noted that the final slide of his presentation just lists two upcoming reports. (Those reports were "Draft 2002 Long-Term Groundwater Monitoring Plan," submission date March 29, 2002; and "Draft Demo 1 Area Ecological Risk Characterization Report," submission date April 5, 2002.)

Agenda Item #5. Open Discussions/Other Issues

Mr. Schlesinger asked that the citizen team members decide on a time to meet with TOSC representatives from the University of Connecticut. A meeting was set for 5:00 p.m. on April 23, 2002, at the Bourne Best Western Ė just before the next IART meeting. Mr. Murphy indicated that he would see to arranging that meeting. It was also noted that a reminder about the meeting should be included in the IART mailing memo.

Ms. Dolen announced that, also at 5:00 p.m. on April 23, 2002 at the Bourne Best Western, the IAGWSP office will be hosting an open house for the citizens of Bourne to discuss Bourne water issues.

Agenda Item #6. Agenda Planning & Review Action Items

Due to the late hour, Mr. Murphy decided to forego the review of action items and future agenda items.

Agenda Item #7.

Mr. Murphy thanked everyone for coming and adjourned the meeting at 9:00 p.m.

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