Impact Area Review Team
Quashnet Valley Country Club
Mashpee, MA
May 28, 2002
6:00 – 9:00 p.m.

1. The Impact Area Review Team (IART) requests that a protocol for a health study that looks at potential perchlorate exposure in Bourne be provided to the team as soon as possible. The IART also requests that Massachusetts Department of Public Health (MDPH) epidemiologist Dr. Robert Knorr attend the June IART meeting along with Ms. Suzanne Condon of MDPH.
2. The Impact Area Groundwater Study Program (IAGWSP) office will provide the IART with web site addresses for information on nationwide perchlorate studies.
3. The IAGWSP will consider Mr. Cambareri’s recommendation to install a monitoring well west of water supply well #1 at the Monument Beach wellfield, and will report back to the team.
4. The IAGWP will provide the team with test results from monitoring conducted at Long Range Water Supply (LRWS) well 10.
5. IART members are asked to e-mail their comments on proposed Demolition Area 1 plume rapid response options to the IAGWSP by close of business, Friday, June 14, 2002.
6. The IART requests that future maps of the Southeast Corner of the Ranges include the depiction of the former H Range boundary.
7. The IAGWSP will look into the timeframe for updating the base-wide plume map to include plumes in the Southeast Corner of the Ranges, and will report back to the team.
8. The IAGWSP will provide an answer to David Dow’s question regarding how the $100-million contract awarded by the U.S. Army Corps of Engineers (USACE) for Impact Area cleanup work relates to the annual appropriation from Congress that the Guard seeks for cleanup activities.

MDPH Update on Health Study re: Potential Perchlorate Exposure in Bourne
Demo Area 1 Plume Treatment
Natural Resource Trustee Council Presentation (June)
Fate and Transport Presentation
Gun and Mortar Firing Positions Workplans
Munitions Management Plan
Chemical Spill 19 (CS-19) Remedial Investigation

Mr. Murphy convened the meeting at 6:00 p.m. and the IART members introduced themselves. Mr. Murphy then asked if there were any changes or additions to the March 26, 2002 IART meeting minutes or the April 23, 2002 IART meeting minutes. No changes or additions were recommended, and both sets of minutes were approved as written.

Mr. Gregson announced that last Wednesday morning the U.S. Army Corps of Engineers (USACE), which is conducting work at the Formerly Used Defense Site (FUDS) known as the former H Range, came across some unexploded ordnance (UXO) at the site, which is located in the Sandwich village of Forestdale, north of Snake Pond. He noted that although the IAGWSP office is not conducting the investigation, it assisted the USACE by providing a UXO safety specialist as well as community involvement support by contacting local selectmen and town officials.

Mr. Gregson noted that because the found items were located off post, it was decided that they should be blown in place as soon as possible. A 60-mm mortar and an 81-mm mortar were blown in place at 1:00 p.m. on the same day they were discovered. Other items, which were determined to be safe to move, have been transported to storage for destruction in the contained detonation chamber (CDC). Mr. Gregson also noted that USACE’s program manager at the site could be contacted for more details on the items that were discovered.

Mr. Schlesinger asked if the discovery occurred on Camp Good News property. Mr. Gregson replied that it did, and noted that it was part of a 10-acre site where the USACE is conducting an ordnance investigation and removal effort. Mr. Schlesinger asked if the IAGWSP’s air magnetometry survey had included that area. Mr. Gregson replied that he doesn’t think that the survey went that far over.

Mr. Murphy asked if there were any comments on the responses to action items from the April 23, 2002 IART meeting.

Mr. Hugus noted that the first action item was an IART request that MDPH look into possible health effects in Bourne from exposure to perchlorate, and the response to that item indicates that senior MDPH representatives will attend the next IART meeting to discuss details of a potential health study. Mr. Hugus asked if any MDPH personnel were present this evening to provide more information.

Mr. Williams of MDPH stated that Suzanne Condon, MDPH’s Assistant Commissioner for the Bureau of Environmental Health Assessment (BEHA), will be attending next month’s IART meeting, possibly along with additional senior staff. He also noted that MDPH has contacted Harvard School of Public Health for input on potential bio-monitoring endpoints in terms of data gathering with respect to perchlorate exposure, if it were to have occurred. In addition, MDPH is proposing to work with the University of Massachusetts Medical School and its newborn screening database to see whether there are any points there that could be examined in terms of potential perchlorate exposure opportunities. Mr. Williams said that Ms. Condon plans to discuss these efforts in greater detail at the next IART meeting.

Mr. Hugus indicated that he’s pleased that MDPH seems to recognize that concerns about health effects in Bourne are valid. He also stated, however, that it disturbs him that two months will have passed from the time that the IART requested a health study to the time that Ms. Condon addresses the team. He said that he thinks that work on the study should proceed in the interim, and he asked that MDPH provide the IART with any available health study protocols as soon as possible so that team members can review them and prepare for the discussion at the June meeting.

Mr. Schlesinger asked Mr. Williams to explain the term health endpoints. Mr. Williams explained that a health endpoint is something, such as hormone levels, which can be measured in order to develop an epidemiological study that would have statistical validity. Mr. Hugus suggested that, as discussed at the last IART meeting, a survey of physicians’ records on thyroid might be a good place to begin. Mr. Williams noted that Ms. Condon would address this issue at the June IART meeting.

Dr. Feigenbaum asked whether Mr. Williams anticipates that Harvard would have some preliminary work done at this point. Mr. Williams replied that he knows that Harvard has been contacted and more information will be available when Ms. Condon addresses the team.

Dr. Feigenbaum then said that he thinks it’s important that Ms. Condon be informed that in addition to perchlorate detections in the Monument Beach wellfield, perchlorate has been detected in the Landfill 1 (LF-1) plume at levels as high as 17 parts per billion (ppb). He also said that he thinks it’s important to note that the Air Force Center for Environmental Excellence (AFCEE) still has not agreed to monitor for perchlorate in the LF-1 plume, which "directly impacts" Bourne supply wells #2 and #5, nor has it agreed to use the lower detection limit of 0.35 ppb. Dr. Feigenbaum suggested that Ms. Condon consider weighing in on this issue on the side of the regulators in an effort to get AFCEE "to be a little more forthcoming about this."

Mr. Williams noted that it’s his understanding that AFCEE has conducted perchlorate monitoring adjacent to the supply wells, using the 0.35 ppb detection limit, and the results were nondetect. Mr. Minior added that AFCEE, the U.S. Environmental Protection Agency (EPA), and the Massachusetts Department of Environmental Protection (DEP) are in the midst of discussing where testing might be done in the LF-1 plume and what the detection limit would be. He said that a meeting is scheduled for June 4, 2002 to continue that discussion, but he has no additional information at this time. Dr. Feigenbaum asked whether it’s true that AFCEE still wants to use the higher detection limit. Mr. Minior replied that he believes that the most recent piece of correspondence from AFCEE indicated that it wants to use the 1.8 ppb detection limit. Mr. Pinaud clarified that at DEP’s request, AFCEE has tested sentinel wells and Bourne water supply wells in the vicinity of the LF-1 plume. Mr. Minior agreed.

Ms. Hayes asked Mr. Williams to discuss the pediatric aspect of the epidemiological study. Mr. Williams explained that there are two ongoing efforts. One is to work with the Harvard School of Public Health to identify bio-monitoring endpoints – which might be in children or adults. The other is to work with the University of Massachusetts Medical School’s existing newborn screening database, which, he believes, contains measurements for thyroid levels and hormone levels. Ms. Hayes asked if it’s correct that the plan is to tap into that database and then do comparative analysis. Mr. Williams replied that this is correct. Ms. Hayes asked whether Mr. Williams believes this is a viable approach that would produce significant data that could be transferred to the situation that appears to exist locally. Mr. Williams replied that he would have to defer this question to Ms. Condon. Ms. Hayes asked whether Ms. Condon is an epidemiologist. Mr. Williams replied that at the June IART meeting, Ms. Condon might be accompanied by Dr. Robert Knorr, an epidemiologist with MDPH.

Mr. Judge said that he would appreciate it if Dr. Knorr attended the June IART meeting, as he would like the opportunity to ask some questions of Dr. Knorr. He also mentioned that an Upper Cape childhood leukemia incidence study was conducted, and Dr. Knorr indicated that it was not statistically significant that the incidence of childhood leukemia on the Upper Cape was 19% higher than the rest of Massachusetts. Mr. Judge further noted that it’s come to his attention, and he thinks it’s important to consider, that while Cape Cod has some cancer rates that are "significantly higher" than the rest of Massachusetts, the state itself ranks amongst the top states in the country as far as high cancer rates.

Mr. Gregson displayed a map that showed historic perchlorate detections in the Bourne Water District’s Monument Beach wellfield. He pointed out locations where there had been perchlorate detections, including three of the four water supply wells, some of the sentinel wells, and far-field wells along the base boundary.

Mr. Gregson then displayed a map that showed current detections from the most recent sampling event. He noted that the three water supply wells that had perchlorate detections in March 2002 have been nondetect for perchlorate in the past seven weekly sampling rounds. The fourth water supply well has never had a detection of perchlorate. Sentinel wells 97-1, 97-2, and 97-5, where perchlorate was detected initially, currently are nondetect for perchlorate.

Mr. Gregson pointed out a new well, 02-13, which was installed upgradient of supply well #1. He reported that in the first sampling round perchlorate was detected at 0.97 ppb in the shallow screen there, and at 0.5 ppb in another screen. That well, which is being sampled on a weekly basis, was nondetect for perchlorate in the most recent sampling round. However, given its proximity to supply well #1, results from well 02-13 are being watched very closely. Mr. Gregson also reported that perchlorate was detected at 0.6 ppb in another new well, 02-4, which is located upgradient of Bourne water supply well #4. He further noted that profile sampling at monitoring well 213 (MW-213), a new far-field well located between wells 80 and 81, yielded perchlorate detections ranging from 0.38 ppb to 1.6 ppb. These concentrations are similar to those seen in well 80.

An unidentified audience member asked whether contaminant concentrations vary with rainfall levels. Mr. Gregson replied that variations with rainfall events are not seen.

Mr. Gregson then reported that the IAGWSP is in the process of completing well 02-7, which had a perchlorate detection just above the 1 ppb state advisory level in profile sampling. Well 02-15, which also is in the process of being completed, was nondetect for perchlorate in profile sampling. Mr. Gregson mentioned that MW-213 also is being completed.

Mr. Gregson referred to the map and noted that a picture is starting to develop of where the perchlorate is and where it isn’t. He pointed out nondetect areas to the south, to the north, and to the west. He also pointed out an area where there have been sporadic detections and nondetects, and said that a line of detections appears to run from well 1-88 through to well 80D.

Ms. Hayes inquired about the nature of the pattern of detections that, at the previous IART meeting, Mr. Gregson said seems to be developing in the center of the wellfield. Mr. Gregson said that the pattern has to do with the location of the detections. He also noted, however, that the cross-sections illustrate how the detections are related in terms of depth.

Mr. Gregson stated that cross-section A-A' is parallel to groundwater flow and runs from Bourne supply well #1 up through MW-80. Cross-section B-B' runs through the sentinel wells and over to some existing monitoring wells to the south. Cross-section C-C' is a north/south section that runs to the base boundary through the far-field wells, and cross section D-D' is a north/south section located just upgradient of supply wells #3 and #4.

Mr. Gregson showed cross-section A-A' and pointed out the supply wells; well 02-13, where there previously had been a detection that wasn’t repeated in the last two sampling rounds; well 1-88, which has had repeated detections between 0.4 and 0.5 ppb; well 02-05, which had a 6 ppb detection that is slightly deeper than the detections at well 1-88; well 02-09, which had a detection in the middle screen; and MW-80 at the base boundary, which had a detection of 0.9 ppb at the water table, but was nondetect in that screen during the first sampling event, and which has had repeated detections in screens M2 and M1. Mr. Gregson noted that the M1 screen at MW-80 has had detections above 1 ppb in the last three sampling rounds.

Mr. Gregson showed cross-section B-B' and noted that it goes through the sentry wells and ties in to cross-section A-A' at well 02-9. He pointed out that there was a detection of 0.4 ppb in well 02-08, and he noted that sentinel well 97-2 was clean in the last sampling round.

Mr. Gregson showed cross-section C-C', which ties in to cross-section A-A' at MW-80, and mentioned that the far-field wells were constructed with multiple screens. He also noted that profile detections at MW-213 ran from the C interval down to the F interval, with the maximum detection of 1.67 ppb having occurred in the D interval. Mr. Gregson said that sampling results from the screens that were set in MW-213 are expected to be available soon. He also noted that it appears that detections in MW-213 are a little bit shallower than those seen in MW-80.

Mr. Schlesinger referred to the shallow detection in MW-80 and asked what is known about how quickly perchlorate goes through the water table. Mr. Gregson stated that perchlorate dissolves at the surface, works its way down through the water table in a dissolved phase, and then moves at the same speed as groundwater flow. He said that the shallow detection at MW-80 is curious because it would indicate that there’s a nearby source area. If that detection proves to be real, an effort will be made to look for a close source area.

Ms. Hayes asked Mr. Gregson to discuss what is meant by a detached plume. Mr. Gregson explained that when a source area becomes depleted, the groundwater plume is considered to be detached because there’s no longer any source being added to it and the end of the plume is traveling with the water flow.

Mr. Gregson then showed cross-section D-D' and pointed out that there were detections in wells 02-4 and 02-3, that wells 02-1 and 02-2 have been nondetect, and that there was a detection at 0.5 ppb in sentinel well 00-7.

Mr. Hugus asked whether the Town of Bourne intends to turn off supply well #1, given the 0.97 ppb perchlorate detection that occurred in well 02-13, which functions as a sentry well for the supply well. Mr. Gregson replied that he couldn’t speak for the Town of Bourne. However, he did note that the town would make that kind of decision based on weekly sampling results for the supply wells and monitoring wells, which are being provided by the IAGWSP. Mr. Hugus asked if there was anyone from the Town of Bourne who could address this issue.

Mr. Mullennix stated that he is from the Town of Bourne and has some experience with perchlorate, particularly in the southwestern part of the country, where perchlorate has been an issue for some time. He said that Lake Mead and the whole Colorado River valley is contaminated with perchlorate due to the production of rocket fuel in that area. People in southern California and Las Vegas valley have been drinking perchlorate-laden water at 10 to 14 ppb on the average, probably for decades. Mr. Mullennix then suggested that IART members request that EPA provide them with some of the extensive studies that have been conducted regarding health implications associated with drinking water that’s contaminated with perchlorate.

Mr. Hugus asked whether Mr. Mullennix is a town official. Mr. Mullennix replied that he is not, but noted that he has a master’s degree in environmental engineering from the University of North Carolina School of Public Health and now works in the field of water resources engineering, which is his specialty. Mr. Hugus clarified that he’s interested in hearing from someone who actually speaks for the Town of Bourne. He also noted that the Bourne Water District found it prudent to shut down three of the supply wells in the Monument Beach wellfield because of much lower levels of perchlorate than those in the southwestern part of the country, and he believes that was the right thing to do. Mr. Mullennix said that he would suggest that a decision was made to shut down those wells because of the unknown factors regarding perchlorate at that time. He also explained that he simply is recommending that the IART take a look at the tremendous number of perchlorate studies that already have been done. Mr. Murphy asked if Mr. Marks of the Bourne Water District would like to reply to Mr. Hugus’s inquiry. Mr. Marks said that he would comment after Mr. Gregson finished his presentation.

Mr. Schlesinger asked whether the IAGWSP plans to continue investigating the perchlorate detections until areas of nondetect are found. Mr. Gregson replied that the IAGWSP is going to find the extent of the perchlorate contamination.

Ms. Hayes noted that information on many of the studies that Mr. Mullennix mentioned is available on the Internet. She said that she would provide web site addresses to anyone interested in reviewing the studies, which she found to be fascinating and well done.

Mr. Cambareri said that he would be interested in reviewing some of the perchlorate studies. He also noted that he’s curious about the type of treatment process that the water from Lake Mead undergoes before it gets to the public supply.

Mr. Cambareri then stated that the higher perchlorate concentrations are occurring in a far-field well, while a lower-concentration zone appears to exist closer to the wellfield. He said that this brings up the issue of how pumping in the wellfield has interacted with the flow of contamination through that area. Therefore, he thinks that it makes sense to install a "further far-field" well west of supply well #1 in order to get some information about how long the perchlorate has been in the groundwater.

Dr. Feigenbaum said that he’s surprised to hear that people are drinking water out of Lake Mead, which, he noted, is not even a reservoir in the normal sense of the word as recreational boating is allowed there. Mr. Mullennix noted that to the best of his knowledge, the Lake Mead water supply doesn’t have any type of extraordinary treatment associated with it. Rather, it has a standard water treatment system, which does not remove perchlorate. He also mentioned that downstream of the Hoover Dam, the Colorado River continues to flow, and there’s a world-renowned pipeline that runs the water 800 miles directly to the city of Los Angeles. And again, that water is not treated for perchlorate. Mr. Mullennix stated that today over 10% of the population in California is drinking perchlorate-laden water over 4 ppb, which is that state’s detection limit. He reiterated his recommendation that the IART review existing studies to learn about what are significantly higher levels of perchlorate than those being seen in the Bourne water supply.

Dr. Feigenbaum said that he thinks it’s a very difficult problem to do an epidemiologic study on 10% of the population of a state the size of California; whereas the perchlorate problem in Massachusetts is known to be limited to a relatively small and localized population. Mr. Mullennix replied that in fact the larger the population for that type of study, the more accurate the results will be. Dr. Feigenbaum indicated that he isn’t questioning that concept; however, if the sample size is the entire state, there really isn’t any control group. Mr. Murphy asked that this particular conversation cease so that others would have a chance to comment.

Mr. Borci clarified that the most comprehensive review of the perchlorate studies that were mentioned tonight is EPA’s draft reference dose document. He also noted that DEP’s interim drinking water advice for perchlorate was based on information contained in that document. Mr. Borci also explained that if a standard adult exposure is applied to the draft reference dose, the result is a 1 ppb drinking water standard. He said that this may or may not come to be, pending comments received, but it’s hoped that something will be finalized by this fall at the earliest.

Mr. Judge commented that Mr. Mullennix seems to be very educated on the subject of perchlorate and he would appreciate receiving any further information that Mr. Mullennix could provide. Mr. Mullennix replied that he would be happy to provide more information and he suggested that he and Mr. Judge talk during the break.

Mr. Hugus made a point of noting that it’s not known what levels of perchlorate existed in the Bourne wells in the past. It’s only known what levels exist there today.

Mr. Mullennix urged anyone who wants to learn more about perchlorate to read the EPA draft document, which he said is "really a very great piece of work." He also noted, however, that it is clearly marked a draft document. An unprecedented amount of comments on the document were received, and in fact the jury is still out on what the perchlorate drinking water level will be.

Mr. Gregson then finished up his presentation by discussing planned activities. He noted that based on new data from the Monument Beach wellfield and the ongoing effort to refine the model for backtracking, well BP-1 is going to be installed upgradient of well 80, where there have been consistent detections of perchlorate above 1 ppb. In addition, two monitoring wells are going to be installed upgradient of WS-4, which the Bourne Water District plans to use for water supply this summer. He noted that the travel time between the two upgradient wells and WS-4 is one to two years. Mr. Gregson also mentioned that there’s a plan to install two additional monitoring wells that will be located based on the results from BP-1 and other factors.

Mr. Marks, Superintendent of the Bourne Water District, stated that supply wells #3 and #4 were shut down before perchlorate was detected in them, and supply well #6 was shut down two days after a low level of perchlorate was detected there. Shortly thereafter, six locations in the distribution system were sampled, and all came back nondetect. Mr. Marks said that supply well #1, along with wells #2 and #5 in Cataumet, continues to run every day. He also noted that supply well #1 is being sampled weekly, and if there is a detection there, "we’ll do the same thing" and again sample the distribution system.

Mr. Marks also noted that a couple weeks ago at the technical meeting at the IAGWSP office – when the Bourne Water District announced it would no longer be attending those meetings – he had asked how many laboratories would be analyzing the samples. At that time, only one laboratory was analyzing the samples using the 0.35 ppb detection limit, but another laboratory was ready to come on line. Mr. Gregson informed him that that laboratory has come on line. He noted that the IAGWSP has been working with STL laboratory right along, and it has a laboratory in Georgia that’s been running some samples. He also said that Ceimic Lab has gotten a second machine to help with the load of samples that are being sent to that facility.

Mr. Marks noted that today it was requested that the Bourne Water District change the sampling schedules to a 5-day turnaround, except for the water supply wells, which would stay on a 2-day turnaround. He said that even a 5-day turnaround isn’t being met for a good percentage of the samples, and he hopes that this means that things are going to improve. Mr. Gregson said that with the addition of the laboratory in Georgia and the Ceimic Lab, he expects that turnaround times will get back to where they should be.

Mr. Marks then stated that, as Mr. Gregson mentioned, most of the wells have tested clean for seven weeks in a row, and the Bourne Water District is awaiting results from the eighth week of sampling. He said that at this time the intention of the Board of Water Commissioners is to keep the supply wells shut down. It’s expected that WS-4 will be up and running shortly, and work on the water main to connect to the Upper Cape Water Cooperative system is ongoing and should be ready to go by July 1, 2002. Until then, the Bourne Water District will run wells #1, #2, and #5. Mr. Marks also noted that the Sandwich connection is ready to go, if needed.

Mr. Judge made a point of noting that only about one month passed between the time that perchlorate was detected in sentry wells and then was detected in a supply well. He asked if the detection at well 02-13, which is upgradient of supply well #1, is a similar situation. Mr. Gregson replied that more data are available now, and he also noted that well 02-13 was nondetect for perchlorate in the last two sampling rounds. He said that the situations are similar, but not identical. Mr. Judge indicated that he thinks it’s extremely important to pay close attention to well 02-13, and he suggested that another sentry well in that area might be in order.

Mr. Gregson discussed recent sampling results for the Demo Area 1 plume. He noted that perchlorate was detected at 0.73 ppb in MW-74 and at 1.97 ppb in MW-32, two existing wells that were nondetect for perchlorate when the higher detection limit was being used. He referred to a figure depicting the Demo Area 1 plume area and noted the perchlorate part of the plume is quite a bit wider than the Royal Demolition Explosive (RDX) part. He also reported that at MW-211, which is located on Pew Road, profile samples showed perchlorate detections ranging from 0.4 ppb to 11 ppb in five intervals, from 170 to 210 feet below ground surface. Also detected there were low levels of RDX, 2,6-DNT, and 3-nitrotoluene; however, it’s not expected that those detections will be repeated – or the RDX should be at a low level – when the actual well sample results come back.

Mr. Gregson also reported that profile sampling at MW-214, which was installed in response to a perchlorate detection in MW-172, showed perchlorate at 0.59 ppb and was nondetect for explosives. He noted that the interpretation is that MW-214 is right on the edge of the perchlorate plume. Mr. Gregson then pointed out MW-221, a new well that tested nondetect for perchlorate and explosives. He noted that the plume outline hasn’t yet been redrawn so that MW-221 is outside of the boundary, which in fact seems to bend to the north. He said that it appears that the perchlorate is getting narrower at that spot.

Mr. Gregson reported that there are three proposed well locations to help define the downgradient extent of what is primarily perchlorate contamination west of Pew Road. Well D1P13 will be drilled first. If sampling results from that well are below the 1.5 ppb relative standard for perchlorate at the Massachusetts Military Reservation (MMR) or relevant standards for explosives, well D1P15 will be drilled to the north, and, it is hoped, that will provide a good understanding of the extent of perchlorate and RDX contamination. However, if a relatively high level of perchlorate is detected at D1P13, an additional well will be drilled along Fredrikson Road, which is just inside the base boundary, east of the Rod & Gun Club property.

Mr. Gregson then stated that because the extent of the perchlorate plume is much greater than was realized when the feasibility study process began, the technical team has been discussing the concept of taking an interim action to address the groundwater contamination as soon as possible. Three pump-and-treat options are being considered, and the goal is to conduct a quick action, while at the same time proceeding with the feasibility study and the overall plume cleanup design process under EPA’s administrative orders. The proposal is to conduct this activity under Rapid Response Action (RRA) guidelines, and under Release Abatement Measure (RAM) guidelines associated with Massachusetts Contingency Plan (MCP) regulations.

Mr. Gregson stated that Option A involves extraction at or near the toe of the perchlorate plume to eliminate or restrict further downgradient migration of contamination. He noted the concern that the plume appears to be approaching the base boundary and said that it’s thought that steps should be taken to stop the plume before it reaches that boundary, if possible.

Mr. Gregson stated that Option B involves cutting off the plume in the middle by installing an extraction well on Frank Perkins Road, at the heart of both the perchlorate and RDX contamination. He noted that the highest concentrations are located east of Frank Perkins Road, and this option would cut off and capture those concentrations, which are in the 100s to 200s ppb range. Mr. Gregson also noted that Option B wouldn’t address anything downgradient; that would continue to migrate until the overall plume treatment design was completed.

Mr. Gregson stated that Option C, which involves pumping along the plume axis east of Frank Perkins Road, would maximize and accelerate the removal of the highest concentrations of contamination. He noted that this option would require a number of extraction wells along the heart of the plume.

Mr. Gregson pointed out that Options B and C would be extracting both perchlorate and RDX at relatively high concentrations, which could mean a dual treatment type of scenario. He said that a field test currently is being conducted on the fluidized bed reactor to determine whether it can treat both perchlorate and RDX. Results from that test, which are expected over the next few months, could help with the implementation of an interim measure.

Mr. Gregson also explained that a fluidized bed reactor is a tank filled with either sand or activated carbon to which an organic material is added to provide a food source. Extracted groundwater would be pumped through the tank and the naturally occurring bacteria would use the perchlorate as an oxidizing source. Dr. Feigenbaum asked whether the same bacteria would take care of the RDX contamination. Mr. Gregson replied that the field test is expected to answer that question. He also said that the worst-case scenario is that RDX would prevent the system from treating the perchlorate. However, another option is a dual system whereby the groundwater first would be run through carbon to remove the RDX and then would be run through a fluidized bed reactor to remove the perchlorate. Mr. Gregson also noted that Option A would extract just low levels of perchlorate initially, but the system would have to be designed in anticipation that some level of RDX would reach that area in the future.

Mr. Gregson said that the IAGWSP is asking for the IART’s input on these options – input that could be provided this evening and/or over the next couple of weeks.

Mr. Schlesinger inquired about possible effects from reinjection. Mr. Gregson replied "if we were to extract from this location here," he believes that the idea would be to reinject off to the sides of the plume, rather than upgradient, in order to create some hydraulic control along the sides.

Mr. Hugus said that he’s glad to see that the regulators and the Guard are acknowledging the unofficial four-month deadline to begin discussing treatment, should the extent of the plume not be defined within that time period, which it has not. He also noted, however, that he is concerned that IART members’ advisory rights are being compromised because the team is being asked to provide advice based on just a 10-minute presentation and not enough information. He said that he thinks that the options need to be discussed more fully and much more information is needed before team members can make any kind of informed decisions.

Mr. Borci clarified that "this is conceptual in nature" and what the regulators and the Guard are asking is whether or not the IART agrees that it’s time take an interim action. He also noted that the feasibility study process will continue and will not be short-circuited by an interim action. The investigation into the full extent of the plume will continue so that the best remedy, which expands on the interim action, can be implemented later down the road. He also said that the team is being asked to identify the kind of additional information that it needs.

Mr. Pinaud assured the group that the regulators and the Guard are not withholding any information. Rather, they have been discussing some concepts and decided to present them to the IART tonight for some preliminary feedback. He also said that DEP’s position, as it relates to the MCP, is that the interim action should be consistent with the final remedy and that it shouldn’t worsen conditions. He then mentioned the issue of reinjecting the treated groundwater, and he noted that MW-221 is now considered to be outside of the plume area and modeling indicates that the plume is bending to the north. Mr. Pinaud said that DEP is in favor of expediting cleanup of the Demo Area 1 plume, but also believes that it’s important to be careful about how that cleanup is done.

Dr. Feigenbaum inquired about the possibility of overlapping the options that were presented tonight. Mr. Gregson replied that the idea is to install an extraction system that will address downgradient migration and/or start removing the mass of the plume, without short-circuiting the feasibility study process. Dr. Feigenbaum said that he thinks that the design of all three options should be moved forward simultaneously, with the schedule reflecting the state of knowledge about the areas of the plume. For example, although it might seem desirable to install an extraction system at the toe of the plume first, that might not necessarily be the best thing to do, given the current lack of information about the toe. On the other hand, there is plenty of existing information that could be used to design an axial system closer to the source of the plume. Dr. Feigenbaum reiterated that he thinks all three options should be undertaken.

Mr. Gregson suggested that at a certain point it would seem to make better sense to just proceed with the feasibility study and do 100% design. Dr. Feigenbaum countered, "Those are only words; whether you call it an interim design, an interim feasibility study, or a final feasibility study." He said that he thinks the team wants to see as much extraction as quickly as possible and he opposes the idea of having to choose just one of the options. He reiterated that he thinks that all three options should be moved forward in accordance with the state of knowledge of groundwater conditions and pollution in each of those three areas.

Dr. Feigenbaum also questioned whether resistance to pursuing all three options simultaneously has to do with a lack of resources or money. Mr. Gregson assured him that that is not the case. Dr. Feigenbaum said that if the IAGWSP is able to implement any one of the options, he thinks that it also should be able to implement them all simultaneously.

Ms. Hayes asked whether the technical team has prioritized the options. Mr. Gregson replied that he doesn’t think any group consensus on prioritization has been reached. Ms. Hayes also indicated that she thinks it’s wise to be cautious, given that there have been instances where taking an action has made things worse. She noted that she’s wondered whether all the recent perchlorate detections might be the result of "something going on that all of a sudden began to get that stuff moving."

Mr. Dow asked if the reaction with perchlorate in the fluidized bed reactor occurs under aerobic or anaerobic conditions. Mr. Gregson replied that it’s an anaerobic reaction. Mr. Dow then asked whether metals that are mobilized under anaerobic conditions in a fluidized bed reactor would clog up an activated carbon filter as the water becomes re-oxygenated. Mr. Gregson said that metals concerns typically are addressed with a green sand filtration process. Mr. Dow replied that he believes that that process has had mixed success. He also said that he thinks it’s important to consider the treatment system in a holistic fashion, including how metals – in addition to perchlorate and RDX – might be affected by the bacterial action and how that might affect the system.

Mr. Cambareri asked whether the long-range water supply (LRWS) wells were tested for perchlorate. Mr. Gregson replied that they were tested and results were nondetect for perchlorate. He also noted, however, that he believes that the screens on those wells are too shallow to intercept any contamination. Mr. Cambareri then asked if the particle tracks in the modeling are heading toward the LRWS wells. Mr. Gregson said that he would look for a figure that would help address this question.

Mr. Cambareri noted that he’s concerned about high flow rates in a fluidized bed reactor that’s part of an axial system, and he’s also concerned about whether it would be able to treat low concentrations of perchlorate as opposed to high concentrations. Mr. Borci said that systems in California are treating thousands of gallons per minute, and he anticipates that 500 gpm would be the requirement for a system at the Demo Area 1 plume. He also noted that systems in California are treating influent concentrations of 100 to 1000 ppb. Mr. Cambareri asked if those systems would be able to treat influent concentrations of 1 ppb successfully. Mr. Borci replied that the field test is looking at that, as well as how the presence of RDX might affect treatment.

Mr. Gregson then showed a map in response to Mr. Cambareri’s question about particle tracking, and said that the model has the plume "coming something like that, so it may be hitting 95-14, but probably not, and LRWS 10." He also pointed out where MW-213 and MW-211 are located on the map.

Mr. Schlesinger questioned how it would be possible to meet the MCP requirement that the interim action be consistent with the total system, when the toe of the plume is not yet defined. Mr. Pinaud said that he thinks the idea is to try to think ahead and ensure that whatever is done can be adapted to a final remedy. Ms. Garcia-Surette further explained that the MCP is designed such that an Interim Response Action (IRA) can be implemented without waiting several years to reach the feasibility stage and the implementation of a final remedy. She said that she believes that Mr. Pinaud’s point was that there’s a set scope associated with an IRA, and it’s important to look at the nature and extent of contamination and ensure that the IRA doesn’t cripple the ability to perform a good comprehensive response action. Ms. Garcia-Surette said that it’s DEP’s job to ensure that these two concepts are harmonized and that the overall goal of expedited aquifer restoration is not jeopardized.

Ms. Crocker said that she agrees with Ms. Hayes that it’s a good idea to proceed cautiously. She also noted that she is concerned about money being wasted and detrimental effects on the natural environment from "un-needed" wells. She said that it takes decades to restore the land, and she thinks that everything possible ought to be done to avoid hurting the natural habitat.

Mr. Gregson stated that the IAGWSP recognizes that every well pad is a large area that needs to be restored, and every plan for a new well is accompanied by a restoration plan for that area. He agreed that it does take time to return those areas to what they were before. Mr. Borci added that every effort is being made to install wells on existing roads and disturbed areas, and to build roads only when absolutely necessary in order to define the extent of a plume. He said that the program tries to balance the need for data, information gained through modeling, and protection of the habitat.

Ms. Crocker also inquired about what she described as "strip mining" the land, only to find "almost nothing but little pieces of metal." Mr. Borci noted that Ms. Crocker is referring to the investigation at the High Use Target Area. He then clarified that the excavation there involved only about one acre of land, and hundreds of UXO items were found. He explained that a very small area was excavated in order to minimize impact, and the idea is to extrapolate information gained from that effort out to the greater area, without stripping 2000 acres of land.

Dr. Feigenbaum returned to the topic of remediating the Demo Area 1 plume and suggested that it might make sense to define the plume as two or three operable units, which he thinks would satisfy the administrative process. He said that a different treatment strategy probably would be required for the high-concentration area, and he strongly believes that a lack of clarity at the toe should not be hindering action in that part of the plume.

Dr. Feigenbaum then referred to Mr. Pinaud’s comment that the interim action would have to be consistent with the final remedy and suggested that an interim action at the toe of the plume could very well turn out not to be consistent with the final remedy, given that the toe hasn’t yet been defined. He said that he thinks the way to proceed is to take immediate action at the higher-concentration areas while, at the same time, working aggressively to define the toe of the plume. Dr. Feigenbaum also noted that he’s interested in hearing EPA’s opinion on this issue.

Mr. Borci stated that an interim action was discussed in depth for the first time at the most recent technical meeting, and the group felt it was important to involve the IART sooner rather than later and find out what further information IART members wanted. He said that EPA agrees with the Guard and DEP that it’s time to take some type of action, but without short-circuiting the feasibility study and the public process.

Ms. Garcia-Surette inquired about a schedule for an interim action. Mr. Gregson replied that he doesn’t have information on the schedule yet, as it will depend on the type and size of action that’s taken. He added that he could only say that one or two wells with a portable treatment unit probably could be in place and operational within the next year.

Mr. Pinaud reiterated that DEP is very willing to look at a detailed proposal for interim action, but is concerned that the toe should be defined as quickly as possible and that a great deal of consideration should be given to where the treated water is reinjected.

Mr. Hugus denied the implication that the team is not being cautious with the environment, and noted that the issue of moving forward with treatment at the Demo Area 1 plume has been ongoing for a long time. He said that he is weighing in on the side of immediate treatment for the areas of the plume that already are well defined.

Ms. Hayes asked when the IAGWSP would like comments back from the team on the options that were presented tonight. Mr. Gregson replied that comments should be e-mailed to the IAGWSP office by June 14, 2002 so they can be reviewed and then discussed at the next IART meeting. Ms. Hayes asked if team members could request specific information to assist them in making a credible decision. Mr. Gregson replied that IART members could always contact the IAGWSP office for more information. Mr. Murphy noted that this process ordinarily involves distributing the request, and the information that’s provided in response, to all IART members.

Dr. Feigenbaum questioned why Mr. Pinaud is so concerned about where the water’s going to be reinjected. He remarked that he sees "a lot of foot-dragging" on the part of DEP and the other agencies. Ms. Garcia-Surette said that she thinks that diversity and differences of opinion are what make a good decision; every issue needs to be fleshed out. She said that with respect to expediting the restoration of the aquifer, the agencies owe it themselves and to the community "to ensure that we do the right thing."

MAJ Myer stated that ground-based geophysical survey work at the J-1, J-2, and J-3 Ranges was conducted in the spring of 2001, and tonight he will be providing an update on the polygon investigation that’s been done there to date. He also noted that this work supports the additional groundwater and soil delineation effort at the J-2 Range.

MAJ Myer showed a map of the J-2 Range area and noted that 35 polygons, or areas of anomalies, have been identified. Those 35 are considered critical in terms of supporting the additional delineation effort. As of today, investigation at 26 of the 35 polygons at the J-2 Range has been completed. MAJ Myer pointed out the polygons where burn and burial pits were found: J2-2, J2-6, J2-10, J2-32, and J2-33. He stated that over 10,500 ordnance/explosive (OE) related items have been removed from the polygons investigated to date.

MAJ Myer stated that 24 anomalies were identified at the J2-2 polygon, half of which have been investigated. He noted that, working with EPA and DEP, the IAGWSP has decided to stop work on this polygon for now in order to proceed with installing monitoring wells associated with the groundwater delineation effort.

MAJ Myer also reported that of the 10,500 items found at the J-2 Range polygons, 2246 are being stored in a safe holding area awaiting destruction in the CDC. Fifteen of the items, which were determined to be unsafe to move, were blown in place. The remaining items, which make up 4500 pounds of OE scrap and 1350 pounds of non-OE scrap, are awaiting further disposition for recycling. He noted that non-OE scrap includes items such as bumpers, refrigerators, banding wire, and so forth.

MAJ Myer also mentioned that soil samples were collected at the burn and burial pits in support of the soil delineation effort at the J-2 Range.

Mr. Schlesinger asked how many of the found items contain perchlorate. MAJ Myer replied that some of the initial soil sampling identified perchlorate in the soil, although he doesn’t know yet what those concentrations are. He also said that some of the items that were found, such as flares and rocket motors, very likely contain perchlorate, but he can’t provide a detailed analysis at this time. Mr. Schlesinger asked if these are presumed sources. MAJ Myer replied that more will be known when the actual soil sample results come back. He also said that items that contain explosives or propellant are more than likely to be a source of contamination.

Mr. Schlesinger said that it’s not clear to him whether the perchlorate that’s found would be the result of point sources or a non-point source. MAJ Myer replied that a large burial site where there had been a lot of burning activity from propellants would be a fairly definable source of contamination, as compared to individual items lying on the ground surface. He said that the polygons are being looked at as individual source areas, potentially. Mr. Schlesinger asked if the entire J-2 Range is considered a source. MAJ Myer replied that the operable unit itself is not, and that’s why the polygons are being evaluated.

Mr. Borci added that as far as a general non-point source of perchlorate, there are other wells with water table screens that don’t have perchlorate detections. He noted that MW-130 contains RDX and perchlorate, while surrounding wells don’t, which indicates that polygon J2-2 is a source of perchlorate and explosives to groundwater. Mr. Borci further noted that archive search report interviews have supported the idea that that polygon was an open detonation/open burn disposal area in the 1960s, before Demo Area 1 started to be used for that purpose around 1974. This has been confirmed by field work, and because of the seriousness of what’s been found, excavation is being halted at this time in order to install monitoring wells to define concentrations in that area. Mr. Borci explained that the idea is to "get the worst first and move the site forward in characterization."

MAJ Myer noted that there are nine polygons still to be done, including "this large polygon" where 12 of 24 polygons have been investigated. He said that after the monitoring wells are installed, the investigation will resume and be completed, and the results will support the soil and groundwater investigation and the remedy at the site.

Dr. Feigenbaum, as a teacher of mathematics, questioned why the areas are called polygons. MAJ Myer replied that in this situation the term has nothing to do with mathematics, but simply refers to an area of investigation where anomalies are grouped together.

Mr. Grant stated that his presentation tonight is an overview of information contained in a document called "J-1, J-3, and L Range Additional Delineation Report #1." The presentation also will include some information from "Additional Delineation Workplan #2," which was finalized in April 2002, while results from workplan #1 were still becoming available. Mr. Grant then showed an aerial photograph and pointed out the outlines depicting the J-1, J-2, J-3 and L Ranges. He noted that there’s a separate report and set of workplans for the J-2 Range.

Mr. Grant reported that soil was sampled at 88 locations distributed throughout the J-1, J-3, and L Ranges, and a total of 28 monitoring wells were installed. Three plume areas – the J-1 Interberm Area, the J-3 Range, and the Southern L Range – continue to be defined, and the plume consists mainly of a mixture of RDX, High Melting Explosive (HMX), and perchlorate.

Mr. Grant displayed figure B-4, which shows the current extent of perchlorate contamination, and figure B-3, which shows the current extent of RDX contamination. He explained that HMX contamination is generally coincident or smaller than the RDX contamination and therefore is not mapped separately. Also, HMX concentrations are for the most part below 10 ppb, while the health advisory for that compound is 400 ppb, and RDX concentrations being seen are well above the 2 ppb health advisory. Mr. Grant also pointed out the top of the mound and noted the radial flow out to the water table contours. He pointed out the J-1 Interberm Area plume, moving off to the northwest; the J-3 Range plume, moving directly south; and the L Range plume, moving a little bit to the southeast.

Mr. Grant reported that RDX concentrations in the J-1 Range Interberm plume are generally a little bit less than 10 ppb, and perchlorate concentrations there are a little less than 2 ppb. He explained that the location is called the interberm area because there’s a 1000-meter berm at the upgradient extent of contamination there and a 150-meter berm farther down.

Mr. Grant also noted that, in addition to RDX and perchlorate, some fairly high levels of benzene, along with some toluene, ethyl benzene, and xylene, have been detected in the two deepest screens at MW-187, and appear to have come from a source closer to the top of the mound. He clarified that this problem does not appear to be related to the petroleum-like material (PLM) detected during profiling at MW-164 and MW-168.

Mr. Grant stated that possible sources for contamination in the J-1 Interberm Area plume are the backstops, or berms, that were fired upon; a popper kettle; a burial trench located near MW-168; cook-off tests that were conducted in that location in the past; and general burning and disposal of excess or unused munitions. Mr. Grant reported that well CIP11 currently is being installed and installation of well CIP12 is about to begin. A total of six proposed wells in that area should provide better information about what’s coming out of the interberm area and moving off through the Central Impact Area. He noted that the southern part of that contamination is fairly similar to what’s being seen in the Central Impact Area; however, there’s also a northern component that’s expected to move farther north than the contamination coming out of the Central Impact Area.

Mr. Grant then stated that the J-3 Range plume is also a mixture of RDX, HMX, and perchlorate. He noted that as the RDX gets farther south it begins to go underneath Snake Pond, while the perchlorate doesn’t extend quite as far south.

Mr. Schlesinger requested that in the future the former H Range boundary be depicted on maps, to help in understanding that entire area. Mr. Grant pointed out where that range would be located on the map and agreed to make sure that that boundary is shown on future maps.

Mr. Dow asked whether the perchlorate contamination is at the same depth as the RDX contamination. Mr. Grant replied that he believes the two are at a similar depth. He also noted that the HMX appears to extend farther east than the RDX, and not much farther south than the J-3 wetland.

Mr. Grant then reported that maximum RDX concentrations in the J-3 Range plume are about 15 ppb and maximum HMX concentrations are about 8 ppb. In addition, trinitrotoluene (TNT), for which the health advisory is 2 ppb, was detected at 12 ppb. Perchlorate concentrations are as high as 311 ppb, which is comparable to perchlorate levels at the heart of the Demo Area 1 plume. He noted that the 311 ppb perchlorate detection was seen at MW-198. Mr. Grant also said that the origin of the RDX contamination appears to be in the vicinity of the J-3 Range detonation pit and burn area. He added that the "J-1, J-3, and L Range Additional Delineation Report #1" includes maps that show the locations of historical activities that occurred at the J-3 Range.

Mr. Hugus asked when the base-wide plume map would be updated to include the plumes in the Southeast Corner of the Ranges. He also asked for an explanation of the color coding on figures B-3 and B-4. Mr. Grant replied that for figure B-4, light pink represents perchlorate concentrations greater than nondetect up to 1.5 ppb, medium pink represents perchlorate concentrations of 1.5 to 10 ppb, and dark pink represents perchlorate concentrations greater than 10 ppb. For figure B-3, yellow represents RDX concentrations greater than nondetect up to 2 ppb, and brown represents RDX concentrations greater than 2 ppb.

Mr. Gregson stated that the next update of the base-wide plume map would include depictions of the plumes at the Southeast Corner of the Ranges. He said that he doesn’t know when that map is scheduled to be updated, but he will find out and report back to the team.

Mr. Hugus asked whether there have been any detections in private wells located off base and north of Snake Pond. Mr. Grant indicated that there have been no detections in private wells that were tested in that area.

Ms. Grillo inquired about the relative depths of the RDX and perchlorate plumes, which do not appear to be co-located. Mr. Grant said that the RDX plume appears to be moving farther east than the perchlorate plume, although the depths look fairly similar.

Mr. Schlesinger asked why the plumes don’t seem to go perpendicular to the groundwater contours. Mr. Grant replied that the exact plume shapes still are being refined. He also noted that the groundwater contours shown on the map represent a snapshot in time, and a great deal of variation can occur.

Dr. Feigenbaum said that he recalls that a few months ago perchlorate was detected at about 1 ppb in a residential well. Mr. Grant clarified that that perchlorate detection could not be verified; the well was resampled and came back nondetect, and it’s believed that the initial detection was a false positive.

Dr. Feigenbaum then stated that he thinks the regulators should start talking about these plumes in terms of enforceable milestones. He said that the plumes are headed toward residential areas and it would make sense to remediate them before they travel that far.

Mr. Grant noted that the Fuel Spill 12 (FS-12) plume treatment system might be capturing some of the contamination from this area. Dr. Feigenbaum suggested that the FS-12 system wouldn’t treat perchlorate. Mr. Grant replied that it’s possible that the system would handle low levels of perchlorate. He noted that the influent and effluent at the FS-12 treatment plant is being monitored for perchlorate; however, to date no perchlorate has entered or exited that system.

Mr. Borci mentioned enforceable milestones and noted that, as Mr. Grant mentioned, workplans pertaining to the Southeast Corner of the Ranges are being overlapped in order to move the investigation along as quickly as possible. He said that the work is being combined and condensed as much as possible. He also noted that it’s recognized that the contaminant levels being seen are fairly serious, especially for perchlorate – although they’ve only come to light within the past two months. Mr. Borci assured the team that EPA believes that there’s a need to move along as quickly as possible and get a handle on the plume before it gets too far. Mr. Pinaud stated that DEP agrees.

Mr. Dow asked whether the J-3 wetland has any hydraulic influence on either the RDX or the perchlorate plume. Mr. Grant replied that the RDX and HMX appear to be under-flowing the J-3 wetland. Mr. Dow asked if it’s thought that Snake Pond might have hydraulic influence on the perchlorate plume, which is off somewhat to the west. Mr. Grant replied that the depths of the RDX and perchlorate are similar, so it’s possible that the perchlorate would underflow the pond should it travel that far. He also noted that so far there are no perchlorate detections farther south than MW-59 and none in the monitoring well located on the sand spit in Snake Pond.

Mr. Schlesinger said that it appears that the outer bound of the RDX plume should have included the detection at MW-54. Mr. Grant replied that it’s hoped that two proposed wells, J3P19 and J3P22, are going to provide a better understanding of both the RDX and perchlorate in that area. He also said that he believes that the detection at MW-54 was isolated for some reason, but he doesn’t know what it was.

Ms. Dolen made a point of noting that the residential well where the false positive detection of perchlorate occurred is the only residential well in a wide range within the vicinity of that plume.

Mr. Grant continued his presentation by reporting that possible source areas for the J-3 Range plume include a detonation pit, a burn box, and the Minuteman propellant burn area. Another potential source area, in the southern part of the J-3 Range, is the melt/pour building, which could be a source area for HMX, and possibly for TNT. He noted that workplan #2 proposes installing 10 additional wells to the south and two wells to the north to help define the extent of the J-1 Interberm Area plume and the J-3 Range plume. Some of those wells already have been installed. Soil sampling continues at the J-3 Range and includes sampling and analysis for perchlorate. Results from that sampling, which should be available next month, are expected to provide a better sense of the source areas at the J-3 Range.

Mr. Grant then reported that the L Range plume is made up of two small sections referred to as western and eastern. The western is deeper and has RDX and HMX concentrations, with the maximum RDX concentration up to 9 ppb. The eastern has RDX concentrations up to 2.3 ppb. Given the depth of the western plume, it appears that the source area could be somewhere farther up in the L Range, or as far up as the J-1 Range. Therefore, a couple of wells have been proposed for that area. Also, a number of wells along the base boundary are proposed to help define the downgradient extent of the western and eastern "mini" plumes. Mr. Grant stated that it’s likely that these two plumes will be captured by the FS-12 treatment system.

Mr. Hugus asked whether there were any detections of nitroglycerine, which was detected in the J-3 wetland a few years ago. Mr. Grant said that he doesn’t believe there have been any nitroglycerine detections in groundwater.

Mr. Schlesinger confirmed that the maximum RDX concentration in the eastern plume is 2.3 ppb, and asked how many detections above the health advisory are needed to color an area brown (greater than health advisory) rather than yellow (greater than nondetect to 2 ppb). Mr. Grant replied that he thinks it takes two points, but there’s just a single point above the health advisory at this time. Mr. Schlesinger stated that the color-coding is important in terms of prioritizing the plumes and making good decisions. Mr. Grant acknowledged that Mr. Schlesinger had made a good point.

Mr. Grant then summarized the ongoing activities at the J-1, J-3, and L Ranges by noting that "Additional Delineation Workplan #2," which just came out in April, includes 111 soil samples, two borings, 25 well locations, and continued biweekly sampling at Snake Pond and monthly sampling of FS-12 treatment system influent and effluent. A report on these activities is expected to be issued sometime in September. Mr. Grant also reported that soil sampling at the J-2 Range is 75% complete and a total of six wells will be installed there. Results from this work are expected to be available in September also.

Mr. Hugus inquired about the range for which Textron is taking responsibility. Ms. Adams replied that Textron, a contractor that in the past used both the J-3 and J-1 Ranges, has undertaken some work at the J-3 Range under Administrative Order #5 (AO#5), but she’s not sure whether it’s doing anything at the J-1 Range. Mr. Hugus asked whether the IART would be privy to information learned by Textron’s contractor. Mr. Borci explained that to date Textron’s work consists of just removing some crushed drums and conducting some precondition sampling. This is all that Textron has agreed to do, and all that AO#5 required. As far as Textron’s position on dealing with any of the contamination at the ranges, those discussions haven’t been held. At this time the Guard is considered the responsible party to conduct an expedited investigation and cleanup.

Mr. Schlesinger asked Mr. Grant to identify the well in the eastern part of the L Range plume where the highest detection occurred. Mr. Grant replied that the 2.3 ppb detection occurred at MW-45. Mr. Schlesinger said that there don’t appear to be any wells downgradient of that location to see if there are any detections higher than 2.3 ppb. Mr. Grant replied that he believes that MW-140 was installed in that area to get a better understanding of what’s happening downgradient.

Mr. Wise, who works for the USACE on MMR in support of the Guard’s investigation and cleanup efforts, announced that USACE New England District awarded a Total Environmental Restoration Contract (TERC) to Environmental Chemical Corporation (ECC). He said that ECC was selected through a competitive process to perform multiple contracts or delivery orders throughout the New England states, with MMR as the primary site. He noted that eight firms competed for this contract, which is valued at up to $100 million over a 10-year time span. The firms were reviewed for their management skills, their technical abilities to perform environmental work, their past experience performing similar work throughout the country and this region, and their price – with management skills and technical skills the predominant factors considered.

Mr. Wise said that before the delivery order actually is awarded, a letter of qualifications will be submitted to EPA for its approval. Once EPA has given its approval, ECC will start to work at the Southeast Corner of the Ranges. Mr. Wise noted that ECC is familiar with MMR, as it’s been a contractor doing work here for about two years under the Installation Restoration Program (IRP).

Mr. Hugus inquired about the status of the contractor AMEC. Mr. Wise replied that AMEC would continue working on feasibility studies at other sites. He also explained that AMEC’s contract with the Massachusetts National Guard tends to be winding down; however, AMEC also has a nationwide contract with the National Guard, and the USACE has permission to use AMEC on that contract.

Mr. Hugus asked whether ECC has any subsidiaries. Mr. Wise replied that it does, and has proposed to use Jacobs Engineering for some groundwater-specific work. In addition, ECC might use a group of specialized subcontractors, which would be identified as each delivery order is negotiated. Mr. Wise also noted that under the TERC rules, ECC has to perform at least 51% of each delivery order’s work.

Mr. Hugus commented that he thinks it’s been an advantage that the IAGWSP has had some independence from the same contracting sources and companies that have been working for the IRP. He said that he thinks it’s been a good and healthy thing that a variety of contractors have been working at the base such that no single contractor dominated. Now, however, because Jacobs Engineering, the dominant contractor at the IRP, is becoming involved in IAGWSP work, the diversity that he believes is needed is being lost. Mr. Hugus also noted that this is the type of input that the USACE would have received had the citizens had been involved in this process, as they had requested to be a year ago, when the process began.

Mr. Wise stated that procurement was done primarily on technical value and merit, and local knowledge actually was considered a benefit. However, there’s nothing that says that Jacobs Engineering has to perform certain work. He also noted that AMEC probably will continue with Demo Area 1 and Central Impact Area work – at least in terms of the feasibility studies. It’s not known at this time who actually will design and implement the remedial actions.

Dr. Feigenbaum asked what type of work ECC performs for the IRP. Mr. Wise replied that it does some soil source removal and UXO clearance and avoidance. Dr. Feigenbaum remarked that the appearance is that only the ECC/Jacobs combination is able to get work at MMR. He also asked whether Jacobs Engineering was mentioned specifically in the contract. Mr. Wise explained that when a prime contractor puts together a TERC, it includes all aspects of environmental investigation, restoration, and design. Each competing contractor has to put together a consortium of subcontractors that are identified to show that it has the technical qualities to handle all projects from cradle to grave; however, he doesn’t know that this means that the prime contractor has "to use those same firms absolutely."

Dr. Feigenbaum stated that the IART has been working with AMEC for five years. A working relationship exists and many people are comfortable with and trust AMEC. Therefore, it seems inappropriate to him that the USACE wouldn’t have AMEC continue as the prime contractor. Mr. Wise replied that he doesn’t know why ECC was selected over AMEC. Dr. Feigenbaum asked if this means, for example, that a treatment system plan designed by one contractor would have to be blueprinted with sufficient specificity such that another contractor could pick it up and proceed with the implementation of that plan. Mr. Wise said that this is a possibility. He also noted that there are no specific set rules pertaining to that situation. Dr. Feigenbaum remarked, "It’s a very bad way to go."

MAJ Myer made a point of noting that EPA helped in the selection process in that it was part of the team that reviewed the technical aspects of all the contractors that bid on the TERC proposal.

Mr. Dow asked how the $100-million contract awarded by the USACE relates to the annual appropriation from Congress that the Guard seeks for cleanup activities. Mr. Murphy indicated that due to the late hour, an answer to this question would have to be provided as an action item response.

Ms. Adams said that she wants to clarify that it’s her understanding that EPA was not involved in the actual selection of ECC. Rather, EPA’s participation was limited to technical rating of the proposed contractors.

Mr. Gregson noted that the IAGWSP sees the value in continuing contractors on a per-site basis, and will keep that in mind when assigning work under the new contract.

The action items and future agenda items were reviewed as they appear at the beginning of these minutes.