Impact Area Review Team
Review Draft Agenda
Mr. Hugus referred to the response to Action Item #3 and asked when wells 00-1 and 00-2 would be sampled. Mr. Gregson replied that they might already have been sampled, and noted that he would get back to the team with a definitive answer.
Mr. Hugus also referred to the response to Action Item #1 and commented that, once again, it appears that an answer was not provided to the question of what the Department of Defense (DoD) is going to do to make up for lost water supplies on the Upper Cape. He also said that he doesnít think that the Environmental & Readiness Center (E&RC) at Camp Edwards has the authority or the resources to answer this question, and he would like to know why the IART canít seem to get an answer to this question. Mr. Murphy noted that last week LTC Brian Rogers told him that the E&RC had forwarded to the Pentagon the IARTís request for an answer to this question.
Mr. Hugus explained to members of the audience that several years ago the Pentagon used the phrase "to make the Cape whole" when describing its commitment to address the damage that pollution from the base had caused to the surrounding communities. He said that at that time, under Sherri Wasserman-Goodman, then Deputy Undersecretary of Defense for Environmental Security, the DoD effort to fulfill that commitment included formation of the Joint Program Office (JPO), which coordinated construction of the Upper Cape Cod Regional Water system, to produce 3 million gallons per day (mgd) of water supply. Mr. Hugus also said, however, that the DoD had promised 10 mgd and he wants to know about the other 7 mgd, especially now that more water supply has been lost because of the recent shutdown of wells in the Monument Beach wellfield.
Mr. Hugus expressed frustration that DoD has not provided an answer regarding its commitment. He also said that he would second the recommendation that Dr. Feigenbaum made at a previous IART meeting Ė that the U.S. Environmental Protection Agency (EPA) issue an administrative order that requires DoD to make up for the lost water supplies.
Mr. Walsh-Rogalski said that he believes that this was "the fifth request thatís gone unanswered." He also said that EPA thinks that itís now appropriate to begin looking at what it would take to put together such an order, since there hasnít been any kind of response and "there clearly isnít any plan to make the Cape whole."
Mr. Judge said that it might be a good idea for the IART to get a letter from Congressman Delahunt, who also is concerned about this issue. He also suggested that the IART draft a letter to EPA so it wouldnít appear that EPA were acting on its own. Mr. Judge added that he thinks itís a good idea to address the 7-mgd balance now, in order to prevent future water supply challenges.
Mr. Hugus noted that anything that the team would write in a letter has already been said at IART meetings, and would therefore be captured in meeting minutes. Mr. Judge said that he would withdraw his suggestion about a letter if everyone agrees that the meeting minutes do a sufficient job of expressing the teamís dismay over its "five attempts" at getting an answer from DoD.
Mr. Hugus requested that the topic of EPAís response to this issue be added to the next IART meeting agenda.
Mr. Schlesinger referred to Action Item #7, his request that consideration be given to forming a second team that focuses strictly on plume remediation, and asked who are the "Remedial Program Managers" mentioned in the response to this item. Mr. Gregson explained that Remedial Program Managers (RPMs) is a term borrowed from the Installation Restoration Program (IRP), and in this case the RPMs are Mr. Borci, Mr. Pinaud, and himself. Mr. Borci also explained that because there would be so much overlap between two IART groups, it is not feasible to have a second group at this time.
Mr. Dow noted that itís his understanding that the water supply issue is tied into the currently deadlocked Natural Resources Trustee Council (NRTC) process, in which case the Commonwealth of Massachusetts Ė not EPA Ė would be the natural resource trustee. Mr. Judge said that because some NRTC members are "declaring the mortars and things lying around on the ground as scrap metal and not as a pollutant concern," his opinion is that the Commonwealth should withdraw from the NRTC and file suit. He also said that he thinks that whatís already been spent on water supply is tied into the NRTC process Ė not what might need to be spent in the future.
Mr. Pinaud clarified that the Massachusetts Executive Office of Environmental Affairs (EOEA) is the groundwater trustee for the Commonwealth in the NRTC process, while the Massachusetts Department of Environmental Protection (DEP) has only an advisory role on the NRTC.
Mr. Walsh-Rogalski stated that there are several legal remedies. One, which belongs to the state, is to pursue a Natural Resource Damages (NRD) claim for groundwater under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). An alternative legal claim could be asserted under Section 1431 of the Safe Drinking Water Act (SDWA), which specifically provides that the administrator can require the replacement of water supplies when public drinking water supplies have been injured. Mr. Walsh-Rogalski said that EPA had been hoping that the National Guard or DoD would resolve this issue before it became necessary to issue an order, but his opinion is that "thereís a clear legal route to get the alternate water suppliesÖ"
Mr. Hugus asked Mr. Walsh-Rogalski to repeat the section number heíd mentioned. Mr. Walsh-Rogalski noted that heíd referred to Section 1431, the "Emergency Powers" provision of the SDWA, which was used in EPAís Administrative Orders #1, #2, and #3. He also said that Section 1431 gives broad authority to take such action as may be necessary when "thereís imminent and substantial endangerment because a contaminant has entered a source of public drinking water supply," and it specifically states, "including the provision of alternate water supplies," which is the more specific provision that would be used in this case.
Mr. Hugus said that he would urge EPA to work toward getting results for the residents of the Upper Cape. Mr. Walsh-Rogalski stated that he would ask the military to step forward first. If it doesnít, however, he thinks that the only option would be for EPA to issue an order, given that the NRD process has stalled.
Mr. Raymond explained that the updated information repository system will work as follows: two copies of each document will go to the U.S. Coast Guard (USCG) library on base; all documents that are out for public comment will be distributed to all the libraries; a copy of any document will go to whichever of the local libraries chooses to receive it Ė a decision that would be based on geographic location and historic patron requests; and, when a requested document is not held in a particular library, it will be made available there within two to three days via CLAMS distribution from the USCG library.
Mr. Raymond also reported that each of the local libraries has received two copies of an "information binder" that contains fact sheets, newsletters, frequently-asked questions and information about the MMR environmental cleanup programs, as well as general information about the military units operating on the base. One binder will always be located on the reference table, and the librarians will decide on the location of the other binder. He also noted that documents housed at the information repositories will be color-coded according to their source Ė whether itís the Groundwater Study Program, the IRP, the 102nd Fighter Wing, and so forth. Mr. Raymond further noted that the CLAMS fee has been paid and a local contractor is hooking up the USCG library computers and Intranet to that system.
Mr. Raymond noted that next steps include having Verizon complete a broadband cable installation at the USCG library, and having CLAMS personnel train the USCG library staff to use the CLAMS software. He also noted that he is developing a "standard operating procedure" document to ensure consistent operations associated with the information repository project. Mr. Raymond then made a point of noting that flexibility is the cornerstone of the information repository update.
Mr. Schlesinger inquired about the possibility that a document wouldnít be available to a user because it had already been loaned out. Mr. Raymond replied that this is a possibility. He also noted, however, that many documents are available on IRPís web site, and, he believes, on the Groundwater Study Programís web site as well.
Ms. Dolen of the Groundwater Study Program clarified that her office is in the process of digitizing its Administrative Record documents to be available on the web site. The digitizing process is about 85% complete and includes technical notes, feasibility studies, workplans, meeting minutes, and more. Ms. Dolen also noted that the link to the Administrative Record documents should be open by February or March 2003, as should links to the Geographic Information System (GIS) web site, the Archive Search Report web site, and the data management web site, all of which will be coordinated though the groundwaterprogram.org web site.
Mr. Raymond noted that the information repositories contain not only Administrative Record documents, but also other informational documents that help the user better understand the environmental programs at MMR.
Mr. Hugus said that the USCG library appears to be the main focus of this project. Mr. Raymond agreed, but also noted that the Bourne library has volunteered to accept all documents for at least the next year or so. Mr. Hugus inquired about public access to the USCG library. Mr. Raymond replied that the E&RC would issue one-day passes to members of the public who want to visit the USCG library.
Mr. Pinaud recommended that the IRP and Groundwater Study Program web sites include links to the CLAMS network. He also asked about individuals who donít have Internet access. Mr. Raymond replied that computers with Internet access are available to the public at the libraries. He also noted that the reference section of each library has a table set up for MMR materials, and the librarians are well versed in how to obtain MMR-related information.
Mr. Schlesinger suggested that the E&RC include a notice about the information repository update in the monthly calendar of events. Mr. Raymond replied that when the update is completed, a notice would be included in that mailing and in the regular E&RC advertisement in the Cape Cod Times. In addition, a news release would be issued.
Monument Beach Wellfield Recent Detects
Mr. Gregson then referred to the issue of sampling downgradient of the Monument Beach wellfield and noted that on the shoreline of Buzzards Bay the U.S. Geological Survey (USGS) has an existing well that was installed over 25 years ago to look at the saltwater/freshwater interface there. He said that the Groundwater Study Program is in the process of collecting samples from that well, which has three screens that should provide valuable information on downgradient water quality.
Mr. Hugus commented that drilling the next well near WS4P-4, based on the perchlorate detection at MW-233, doesnít seem logical to him. He said that this location appears to be north of where additional testing should be done. Mr. Gregson noted that there are perchlorate detections south of MW-233, while MW-219, which is north of MW-233, tested nondetect for perchlorate in four screens. He then explained that the WS4P-4 location was chosen in order "to split that difference" by going a little to the west and between MW-233 and MW-219 to try to define the northern extent of the contamination. Mr. Gregson also mentioned that his office is developing a workplan that includes about a dozen additional drilling locations throughout that area.
Mr. Hugus noted that water supply well #1, which is the only well in the Monument Beach wellfield that hasnít been shut down, is just a little bit south of well 01-1, where perchlorate was recently detected. Mr. Gregson agreed and said that water supply well #1 continues to be monitored on a weekly basis and has been testing nondetect. He also noted, however, that perchlorate has been detected in upgradient monitoring wells 213, 188, 97-5 and 02-9. Mr. Hugus suggested that the perchlorate detection at well 213 would make the prospects for water supply well #1 "not very good." Mr. Gregson acknowledged that well 213 is upgradient of that supply well; however, he also noted that perchlorate concentrations detected there were below the 1-ppb advice level that DEP provided to the Bourne Water District.
Mr. Schlesinger asked whether water that passes MW-233 would flow into the supply well zone of contribution (ZOC) depicted on the map. Mr. Gregson referred to the map and indicated that that water would not flow into that ZOC. Mr. Schlesinger also inquired about monitoring frequency for wells in the Monument Beach wellfield area. Mr. Gregson replied that most of the monitoring wells are sampled on a monthly basis; water supply well #1 is sampled on a weekly basis; and the three supply wells that are shut down either are or soon will be sampled on a biweekly basis.
Mr. Judge strongly recommended that the Groundwater Study Program install a monitoring well right away in the area south/southwest of MW-233, within the ZOC Ė and then concern itself with a northern well later on. Mr. Gregson said that the travel time between MW-233 and water supply well #1 is in the 5-to-10-year range, and there are monitoring wells upgradient of water supply well #1. Therefore, there is some time to obtain an understanding of groundwater quality in that area Ė although doing so is a priority. Mr. Judge made a point of noting that the team has had "a hard time with predictions of water flows and pollution before, especially when it comes to the Town of Bourne."
Mr. Judge also asked whether the downgradient USGS well shows signs of being compromised by saltwater intrusion. Mr. Gregson replied that the deepest screen is in saltwater, the next screen is in a brackish zone, and the top two screens are in freshwater. Mr. Judge noted that samples from the screen in the brackish zone could lead to a "diluted result."
Mr. Schlesinger asked why the ZOCs depicted on the map donít extend out farther, and why the two southern ZOCs appear to overlap each other. Mr. Gregson said that a raindrop that fell within one of the ZOCs would go down to the water table and ultimately make its way to the production well, while a raindrop that fell outside of the zones would not. He then explained that the ZOCs are not shown on the map as extending all the way to the production wells because the well screens are below the water table. Therefore, water that falls in the area between the ZOC depictions and the production wells would "just flow above the well screen." Mr. Gregson also clarified that the northern ZOC is for supply well #4, the longer southern ZOC is for supply well #3, the shorter southern ZOC is for supply well #1, and the ZOC for supply #6 falls outside of the map, on base.
Southeast Ranges Recent Unvalidated Detections
Mr. Gregson also reported that profile results from MW-239 show RDX in five intervals, at concentrations up to 4.8 ppb. He said that if these concentrations hold up in the well screens that are installed, the RDX contours would be pushed a little east of where they are depicted currently. He also noted that perchlorate was detected in three intervals at MW-239, at concentrations between 0.9 and 1.2 ppb Ė below the EPA level of 1.5 ppb.
Demo Area 1 Recent Unvalidated Detections
Timeline for Monitoring Well Installation and
Mr. Gregson noted that after the need for a well has been identified, a Record of Action (ROA), which is an environmental and cultural resources review thatís a legal requirement of the state, has to be prepared. The next step is to clear the site of unexploded ordnance (UXO) and prepare the access road. Mr. Gregson noted that UXO clearance for a particular well site can take anywhere from a few days to a couple of months, depending on the density of the UXO. He also noted that well installation usually takes a week or two, well development takes about a week, and well stabilization takes another week. Then, samples are collected and analyzed, and the data validation process takes up to four weeks. Mr. Gregson also mentioned that many times the decision to move from one well location to the next is streamlined by basing that decision on profile detections, rather than waiting for validated data from the well screens.
Mr. Schlesinger referred to the ROA process and asked whether thereís some way to shorten the timetable for review by the Natural Heritage Program (NHP) and State Historic Preservation Office (SHPO). Mr. Gregson replied that itís required by law that the NHP and the SHPO have 30 days to complete their review. Mr. Schlesinger questioned whether thereís some sort of graphic database that indicates areas where there might be issues of concern. Mr. Gregson noted that both endangered species and cultural resources issues have to be reviewed, and with respect to cultural resources, "itís really a site-by-site look at a specific areaÖ"
Mr. Schlesinger asked whether the 30-day review period is a state law or a federal law. Mr. Harding, a member of the Mashpee Wampanoag tribe and the Senior Management Board (SMB), replied that the law comes under the National Historic Preservation Act, which came into play in 1966, but hasnít been followed until recently.
Mr. Judge asked Mr. Harding to describe whatís actually done during the 30 days. Mr. Harding stated that thereís dual responsibility between the SHPO and the Tribal Historic Preservation Office (THPO). During the review period either the SHPO, which handles about 2000 cases during a 30-day period, or the THPO, which handles about 200 to 300 cases during a 30-day period, has to visit the site, investigate it, do the background work and research, and then go forward.
Ms. Wilson, the natural resources rehabilitation specialist with the Groundwater Study Program, noted that thereís an ongoing effort to put together a programmatic agreement among these organizations, whereby the Guardís own cultural resources manager would be allowed to conduct an internal review and make a recommendation either to move forward on a site or do an additional survey. She noted that a draft of this process has been started; however, itís a lengthy process that requires a lot of review and discussion, and itís expected that an agreement wouldnít be ready until February 2003 at the earliest. She also said that the agreement could reduce the review period from 30 days to about two days.
Mr. Schlesinger asked if any Groundwater Study Program well sites have been changed because of damage to cultural resources. Mr. Gregson replied that he isnít aware of any such cases. Mr. Schlesinger asked how many monitoring wells the program has. Mr. Gregson replied that it has 240 wells, but noted that a number of them were drilled before anyone was paying attention to cultural survey requirements.
Mr. Hugus said that heís worried that the Guard might use the timeline that Mr. Gregson showed as the reason for a five-month delay whenever the team asks for a new monitoring well. He also suggested that a way to shorten the ROA process would be "to get the whole area studied" around a plume so that monitoring wells could be installed right away, as needed.
Mr. Gregson clarified that the timeline he showed isnít a proposed timeline; rather, itís the timeline under which the cleanup program has been working for five years. He also noted that, as Ms. Wilson mentioned, the Guard has been looking at ways to potentially streamline the process. He noted, for example, that three monitoring wells for the Demo Area 1 plume are being worked through the process simultaneously.
Mr. Walsh-Rogalski questioned whether the ROA process is followed when property is to be used for training purposes. Mr. Gregson indicated that while he doesnít know too much about this subject, he does believe that such a process for training areas is undertaken. He also said, however, that the Guardís environmental manager has noted that damages caused by well pad construction and road building far outweigh any damage caused by training.
Mr. Walsh-Rogalski asked for confirmation that a cultural resources survey would be done prior to conducting training in a particular area. Because Mr. Gregson could not provide this specific information at the time, Mr. Judge asked Mr. Harding directly whether heís been involved in conducting this kind of survey for training areas. He also inquired about the source of funding provided to the Wampanoag tribe to conduct survey work. Mr. Harding replied that in December 2001 he left the position of Deputy Tribal Historic Preservation Officer with the Aquinnah Wampanoag tribe, and has since been working with the Mashpee Wampanoag tribe. He said that when he was in the THPO position, he personally investigated sites on the base. He also noted that Ramona Peters, whoís been working closely with Dr. Sue Goodfellow, has worked with the Wampanoag tribe investigating sites of major concern. Mr. Judge asked that Ms. Peters be invited to a future IART meeting to discuss this issue further.
Mr. LeBlanc showed a map depicting the overall Cape Cod groundwater flow system, which is composed of six different water table mounds that rise above sea level and are also referred to as groundwater cells or lenses. He noted that MMR lies atop the largest of the flow cells, which is known as the Sagamore lens. He also said that the flow cells are all bounded by the ocean and are separated by a variety of surface water features such as Bass River and Pilgrim Lake.
Mr. LeBlanc then displayed a figure entitled "Water Table on Western Cape Cod," noted that it shows most of the Sagamore lens, and explained that the water table mound rises above sea level to a maximum altitude of about 70 feet, right on the eastern/southeastern corner of MMR in an area known as the J Ranges. He also noted that groundwater flows radially from the top of the mound out toward discharge points along the coast and into streams and ponds to the south.
Mr. LeBlanc showed a figure entitled "Hydrologic Section of Western Cape Cod," which he described as a "north-to-south slice," with Cape Cod Bay to the north and Nantucket Sound to the south. He noted that the freshwater lens is truncated by bedrock at about 200 to 300 feet below sea level, beneath the western part of Cape Cod. He also pointed out the high point of the water table mound, and the freshwater/saltwater interface. He noted that the aerial recharge consists of an average of 26 inches per year of precipitation, which percolates down to the water table and then begins to move off toward the coast. Mr. LeBlanc further noted that some flow paths at the very top of the mound are quite vertical, while paths on the sides are mostly horizontal. He also mentioned that if the hydrologic section had been drawn to scale, without any horizontal or vertical exaggeration, the illustration would be about 170 feet long. He said that the tendency is to present a skewed view of vertical flow paths in maps associated with the cleanup program, including plume maps, when in fact the paths are "pretty much horizontal."
Mr. LeBlanc then stated that water levels on Western Cape Cod tend to rise and fall seasonally, and over longer spans of time associated with wet periods and dry periods. He displayed a two-panel slide and noted that the top panel shows a line graph representing precipitation measurements in inches per year from 1930 to 2000 at a weather station in Hatchville. He noted that the graph indicates that precipitation varies tremendously from year to year, and he pointed out the dip in the line that pertains to the drought of the 1960s. Mr. LeBlanc stated that the bottom panel, a line graph representing water level measurements taken since 1963 at a USGS observation well in East Sandwich, shows the response in water levels to precipitation. He also mentioned that measurements taken last month at the USGS well show water levels to be at a near historic low, similar to what was seen during the drought of the 1960s.
Mr. LeBlanc then stated that for nine months the USGS collected data from continuous recorders in place at three Groundwater Study Program monitoring wells located in the J Range area, north of Snake Pond. The northwestern well is located close to what appears to be the top of the mound, the central well is located on the MMR boundary, and the southeastern well is located near the wetland just north of Snake Pond. Mr. LeBlanc noted that changes in water levels in these three wells should provide some sense for how the mound might be shifting.
Mr. LeBlanc then showed a graph that traced water levels in the three wells from January to September 2002, and noted that, as expected, water levels were highest at the northwestern well, in the middle at the central well, and lowest at the southeastern well. He also said that levels at all three wells are going down because of the current drought situation. Mr. LeBlanc further noted that the northeastern and central wells switch positions at a point, and for a while the central well becomes the one with the highest water level. He said that this is pretty good evidence that the mound really does shift around, but added that because of a lack of historical water level data, groundwater models are needed in order to look at "how the mound might shift around with large amounts of climatic variation."
Mr. LeBlanc reported that some of his colleagues did a modeling exercise that looked at the actual precipitation records at the Hatchville station from 1931 to about 1999, and estimated the amount of recharge generated by that precipitation. He said that the estimate was that about 50% of the precipitation becomes recharge, and his colleagues were able to create an approximate record of how recharge might have varied over that period of time, and then apply that information in the regional groundwater flow model. Mr. LeBlanc noted that most flow modeling associated with work in the Impact Area has been steady-state modeling, but water levels have now actually been simulated to go up and down over time, in a realistic way, by varying the recharge each year. He also mentioned that real data from the few wells for which there are long-term records actually matched the simulations.
Mr. LeBlanc then showed a figure entitled "Water Table and Top of Mound for High, Low, and Average Conditions," which he apologetically described as a very confusing map. He pointed out the average water table levels, contoured in blue; the high water table levels, which modeling indicated occurred in 1955, contoured in red; and the low water table levels, which modeling indicated occurred in 1965, contoured in green. He also pointed out how the 40-foot contour lines moved back and forth as the mound would deflate, and then inflate with recharge.
Mr. LeBlanc then directed the groupís attention to the top of the simulated mound shown on the map, and noted that at the highest point it was 73 feet above sea level, and at the lowest point it was 61 feet above sea level Ė a 12-foot variation, with the mound going up and down in response to the simulated variation in recharge. He also noted that the mound moves back and forth along a line that trends roughly southeast to northwest and crosses through the J Range area. He pointed out that according to the modeling, during periods of low water levels the mound tends to shift to the southeast, which is consistent with the actual water level records that heíd discussed earlier. Mr. LeBlanc then said that the best explanation for why the mound shifts back and forth is the complex series of hydrologic boundaries, including the ponds and rivers that drain the aquifer to the south. He noted that a perfect mound would only go up and down in response to recharge, but with the complex interaction with streams and ponds, it actually also shifts back and forth.
Mr. LeBlanc went on to discuss how shifting of the mound affects contaminant transport. He showed a graphic entitled "Transient Particle Tracks, Impact Area, date shown through 1999," and pointed out the simulated water table contours from about 58 to 67 feet above sea level. He referred to the particle track starting points and explained that a tracer was put into the model at four different times along the path line Ė 1955, 1965, 1975, and 1985 Ė and then tracked forward to 1999. Several IART members indicated that they didnít think this graphic made sense. Mr. LeBlanc apologized for the confusion and said that it basically shows "the amount of travel between 1955 and 1999." He also said that in this area of relatively steep gradients to the northwest, "it doesnít matter when the spill occurred; they all track along the same lineÖ" Therefore, it could be concluded that a steady-state way of looking things would provide "a pretty good idea of where the plumes going."
Mr. LeBlanc then showed a graphic entitled "Transient Particle Tracks, J Ranges, date shown through 1999," and pointed out the particle tracks in the southern J Range area. He also pointed out the particle tracks originating from MW-58 and noted that theyíve hardly moved at all because theyíre at the perfect top of the mound, thereís no slope, and the water is not being pushed horizontally. Thereís very little horizontal gradient and very little horizontal movement; instead, the particles are moving downward in the aquifer system. Mr. LeBlanc noted that itís not a perfect vertical transport because the mound is moving around; however, some of the particles ultimately make their way down to the bottom of the aquifer. He also pointed out "blips" in the particle track lines from MW-58, which show how the mound shifted south or north of the particles, depending on water level conditions. Mr. LeBlanc stated that movement near the top of the mound is predominantly vertical, and very slow Ė measured in feet per year as opposed to feet per day.
Mr. LeBlanc then reviewed key points from his presentation as follows: the top of the water table mound shifts along a northwest to southeast line; the top of the mound tends to be the farthest to the southeast when water levels are at their lowest; the flow directions are generally constant away from the top of the mound; and the flow directions at the very top of the mound vary and are more vertical.
Mr. Gregson explained that what was shown on the J Ranges map was a snapshot of a limited number of wells near the top of the mound where data were collected for a synoptic water level measurement. He said that additional data from that particular sampling round are not available; therefore, itís not possible to extend those contours. He also noted that the regional contour map is based on another set of data with different water levels, and mixing the two data sets would not provide a consistent picture. He further noted that Mr. LeBlanc showed yet another data set with different water level measurements, as well as information derived from computer simulations. Mr. Gregson assured Mr. Schlesinger that the Groundwater Study Program is not trying to confuse the team, but is just trying to show data that present the most accurate information.
Mr. Schlesinger stated that since the Upper Cape is currently in a low water period, itís confusing to see a map that shows a 70-foot above sea level contour coming into Snake Pond. He said that he hopes for improvement on the quality of information upon which decisions would be made.
Mr. Walsh-Rogalski asked for confirmation that flow at the top of the mound is slow. Mr. LeBlanc confirmed that the rate of groundwater movement is slower at the top of the mound because itís moving primarily in a vertical direction.
Mr. Dow asked whether variations in the height of the top of the water table mound affect the degree of dispersion at the leading edge of a plume. Mr. LeBlanc replied that they probably donít because the rates of groundwater flow arenít significantly different for most of the aquifer. He added that he thinks that dispersion would occur if the source were located in a spot where "sometimes itís moving north and sometimes itís moving south," thereby causing the contamination to "smear." Away from that small area, however, the flow field would be more uniform. Mr. Dow questioned whether it would then be an artifact of chemical analysis and not dispersion that explains why contamination is sometimes found and sometimes not found near the leading edge of a plume. Mr. LeBlanc replied that it could be an artifact, but it also could be due to fingers of contamination extending out from the leading edge. He noted that those fingers are not seen when a few data points are smoothed out with contours.
Mr. Mullenix asked Mr. LeBlanc to discuss the meaning of the term sole-source aquifer. Mr. LeBlanc replied that this is a legal term created by EPA, and from a hydrologistís perspective it means that the aquifer, for all practical purposes, is the sole source of water for a hydrologic system. In the case of Cape Cod, the aquifer is cut off from the mainland by a saltwater canal that goes to bedrock; therefore, the sole source of water is the precipitation that falls on Cape Cod and recharges the aquifer. Mr. LeBlanc also noted that the concept that this is the only source of water for Cape Cod residents involves many legal regulations that give the aquifer special distinction and protection.
Dr. Feigenbaum asked about the long-term water level records that Mr. LeBlanc had discussed. Mr. LeBlanc replied that he had talked about records from well 253, which is south of Lawrence Pond, "on the ridge of the water table that heads off toward Barnstable." He noted that the well was installed in 1963 and has been measured ever since. He also said that well 253 and about ten other wells are the only ones providing a long-term record for Cape Cod.
Dr. Feigenbaum also asked whether the J Range wells, referred to by Mr. LeBlanc as northwestern, central, and southeastern, were chosen for continuous water level monitoring because they are at the top of the aquifer. Mr. LeBlanc replied that there arenít enough data from those three wells to know whether any one of them is at the top of the aquifer. He also noted that the reason the wells were selected for monitoring has to do with looking at how recharge arrives at the water table; they were not selected specifically for the purposes that were discussed this evening. Dr. Feigenbaum then asked how long the current drought has been ongoing. Mr. LeBlanc replied that he doesnít know offhand; however, it would be easy find out by looking up the appropriate hydrograph on the USGS web site.
Dr. Feigenbaum then questioned whether the 70-foot contour that goes into Snake Pond is perhaps a "phantom number." Mr. LeBlanc replied that his recollection is that water levels there have "gotten pretty close to 70 feet." He also said that the margin of error associated with a computer-generated contour could be the reason why itís shown as 70 feet. Mr. LeBlanc also mentioned that just a couple years ago the lakes were spilling over.
Mr. Hood inquired about the term lacustrine, which was noted in the legend for the "Water Table on Western Cape Cod" map that Mr. LeBlanc had shown. Mr. LeBlanc stated that this map shows geologic features called outwash, moraine, and lacustrine, which refers to lake deposits.
Mr. Schlesinger asked whether updated ZOCs are
generated continually. Mr. LeBlanc replied that while heís not the
right person to be asked this question, itís his understanding
that active modeling is done all the time, and he could only presume
that the ZOCs are being updated regularly.
Agenda Item #7. Review Action Items and Set
Future Meeting Date
Demolition Area 1 Update
Mr. Hill then reviewed the feasibility study process mandated under Administrative Order #3, as it applies to Demo Area 1. He reported that currently the Guard envisions completion of plume delineation by March 2003, after which the delineation effort would be summarized in a Groundwater Report Addendum thatís intended to satisfy the requirements of Phase II under the Massachusetts Contingency Plan (MCP). This document, which is expected to be available by summer 2003, would serve as the basis for a revised Draft Demo Area 1 Feasibility Study to evaluate comprehensive alternatives for cleanup of the larger Demo 1 plume. Mr. Hill said that if that document is received well, it should be finalized by fall 2003, and with appropriate public comment periods throughout, a remedy selection should be in place by summer 2004. If this effort results in a construction project thatís reasonable, design and construction of that remedy should be completed by spring 2006.
Mr. Hill then discussed the Demo Area 1 Rapid Response Action (RRA)/Release Abatement Measure (RAM), which was meant to satisfy both regulatory bodies Ė EPA and DEP. He stated that the Guard made a proposal to jumpstart cleanup of Demo Area 1 and identified a number of areas within the plume where extraction wells might be installed in order to accomplish that cleanup. In consultation with the regulators and the IART, the Guard agreed to pursue two of those locations Ė one in the area of Frank Perkins Road, and the other toward the toe of the plume. Since that time, the Guard has been busy conducting modeling activities and evaluating various treatment technologies.
Mr. Hill then stated that the Draft RRA/RAM plan for groundwater is expected to be completed by January 2003, and will include an IART briefing and a 15-day informal public comment period in February. If all goes well, the RRA/RAM plan should be completed in the spring, allowing for completion of design and construction by the end of the year. Mr. Hill also displayed the "Demo 1 Groundwater Operable Unit Schedule," which showed the RRA/RAM schedule and the feasibility study cleanup schedule side by side, and said that he thinks the team would agreed that there are some obvious benefits to starting remediation early at the Demo Area 1 plume.
Mr. Hill went on to discuss the Demo Area 1 source area by showing an aerial photograph and noting that the Guard conducted heavy demolition activities there for a number of years, including setting off explosive charges on various objects to blow them up, open burning, and open detonation. He also mentioned that from time to time the state police brought loads of fireworks to Demo Area 1 for burning as well. Mr. Hill stated that these activities resulted in the deposition of a fair amount of explosives, contamination, and other organic and inorganic compounds in the soil. He also noted that a lot of metal ended up flying around as a result of these activities, and a geophysical investigation identified several thousand magnetic anomalies within the Demo Area 1 source area.
Mr. Hill reported that over 600 soil samples were collected at the source area. He also stated that Demo Area 1 is an ongoing source of contamination to groundwater, and the Guard is required to conduct a feasibility study for the soil operable unit just as itís required to conduct a feasibility study for the groundwater operable unit.
Mr. Hill stated that the Guard also is proposing an RRA/RAM for the source area, the objective of which is to remove the source of contamination to groundwater. He noted that there are two benefits to the RRA/RAM for the source area. One is that it would remove the source and thereby stop the leaching and limit the duration of any downgradient pumping. The other is that it provides an opportunity to achieve site closure with a one-time excavation event, without going through a protracted feasibility study remedy selection process, which likely would result in the Guard conducting the same remedial action, but two to three years down the road.
Mr. Hill also displayed the "Demo 1 Soil Operable Unit Schedule," which showed the RRA/RAM schedule and the feasibility study cleanup schedule side by side, and said that the Guard thinks that it makes a lot of sense to get the soil cleanup done. He noted that the Draft RRA/RAM plan for soil is expected to be available by early February 2003, with an IART briefing and informal public comment period by late February. If all goes well, the RRA/RAM plan should be finalized by late spring 2003, with the execution of cleanup by the end of 2003.
Dr. Stahl noted that the RRA/RAM plan schedules show that work would begin on the groundwater operable unit before the soil operable unit, and he is concerned about where the treated water would be returned to the aquifer. Mr. Hill replied that this information would be contained in the RRA/RAM plan. He also noted that at this point the Guard is considering side-gradient infiltration galleries or reinjection wells.
Mr. Walsh-Rogalski asked whether itís conceivable that the RRA/RAM would "take care of the shooting match" if the toe of the plume were defined soon enough. Mr. Hill replied, "I guess thatís up to the whole group here, EPA in particular." He also said that the Demo Area 1 Feasibility Study is on the calendar and the Guard is "committed to completing all, and complying with all aspects of that." Mr. Walsh-Rogalski then asked whether the ZOC achieved by the RRA/RAM could reach the full extent of the plume. Mr. Hill indicated that this is a possibility, and noted that last yearís Draft Demo Area 1 Feasibility Study included alternatives where just one extraction well pumping at the toe ultimately would clean up the plume. He also noted, however, that he thinks that a more aggressive approach would be taken, starting with the RRA/RAM.
Mr. Hugus made a point of noting that it was 1997 when John Devillars appointed citizens to the IART, and if the team has to wait until 2006 "to see the end of action on Demo Area 1," there will have been nine years of citizen oversight associated with that plume. He said that as it turns out, the team members are continually "slaves to the bureaucratic process." Mr. Hugus also stated that if the plume can be taken care of completely on the abbreviated schedule, he thinks that it should be. Mr. Hill noted that the RRA/RAM schedule probably would not be as abbreviated if the Guard were trying to attack the entire plume. Mr. Hugus replied that in no way does he want to wait around until 2006 to close the book on the Demo Area 1 plume.
Mr. Judge asked who came up with the idea to do the RRA/RAM. Mr. Hill replied that it was a Guard proposal that was discussed at length with the regulators, and supported by the IART. Mr. Judge said that he wants to compliment the Guard on this endeavor. Dr. Feigenbaum stated that in fact there had been a rather strenuous effort on the part of the citizen IART members to have the Guard move quickly ahead with upstream extraction. Mr. Judge said that in that case his compliments go to whomever came up with the idea and to everyone whoís working on implementing it. He also said that he thinks that the 2006 timeline shouldnít even be a consideration.
Dr. Feigenbaum then inquired about the status of perchlorate treatment technologies. Mr. Hill mentioned that that there isnít a long history in the industry for treating perchlorate, and noted that one of the pilot studies the Guard conducted was on a fluidized bed reactor, which was seen as effective at treating perchlorate. He said that the fluidized bed reactor is one of the finalists for the treatment train. Dr. Feigenbaum asked whether Mr. Hill is confident that the fluidized bed reactor would effectively treat perchlorate at the levels being seen by the Groundwater Study Program. Mr. Hill replied that he is.
Dr. Feigenbaum said that he agrees with Mr. Walsh-Rogalski that it would be great if the entire plume could be addressed by the RRA/RAMís extraction wells at Frank Perkins Road and at the toe. He then noted that his concern is the possibility that the contamination west of Frank Perkins Road would be missed. He questioned whether it might be more efficient to capture that upstream, rather than wait for it to reach the toe. Mr. Hill replied that in the course of its investigation the Guard looked at that area, which is undeveloped and heavily forested. He added that while he canít provide an answer to Dr. Feigenbaumís question right now, this issue is part of what the Demo Area 1 Feasibility Study is expected to flush out.
Mr. Alsop stated that the administrative orders issued by EPA cover human health under the SDWA, but do not address ecological risk assessment issues or ecological receptors. He noted that an environmental risk characterization (ERC), which is MCP terminology, is being conducted at Camp Edwards, as opposed to an ecological risk assessment, which is CERCLA/Superfund terminology. He also explained that the plan was to do an ERC at Demo Area 1 as the first effort to evaluate potential effects to ecological receptors. He further noted that under the administrative orders, potential cleanup levels for Demo Area 1 are determined by evaluating potential risk to human health and impacts to groundwater. However, potential ecological risks are being evaluated under the MCP to ensure that any kind of remedial action proposed down the road for Demo Area 1 would address not only human health issues, but also ecological risk issues.
Mr. Alsop stated that the objective of the ERC is to evaluate potential impacts of site-related activities to valued ecological resources, such as threatened or endangered species Ė for example, northern harriers and sharp-shinned hawks. He noted that there are no federally listed threatened or endangered species at Demo Area 1, but there are state-listed threatened species, endangered species, and species of special concern. He also said that aside from these threatened or endangered species, the primary receptors considered in the ERC are populations of species that reside at or are being exposed to chemicals from Demo Area 1, examples of which are mice and foxes. In addition, the ERC looks at communities, which are assemblages of populations, and the interactions that are associated with them. In other words, the ERC looks at the pitch pine/scrub oak forest and all the creatures that inhabit it. It also looks at ecosystem functions, meaning predator/prey relationships and adverse effects on prey species that would prevent them from serving as a prey base for predators like foxes or hawks.
Mr. Alsop noted that the ERC workplan was developed in December 2001 and finalized in March 2002. This led to the Draft ERC Report that was reviewed by the agencies. Out of the comment resolution period, which lasted from May to July 2002, came the agenciesí requirement for additional field sampling. The Guard, EPA, and DEP developed a biota field sampling workplan on an expedited basis so that it could be reviewed, approved, and implemented this year.
Mr. Alsop then reported that the Draft ERC Report evaluated potential effects to six receptor species including the white-footed mouse, which has a very small home range and is likely to spend its entire life being exposed to contaminants at Demo Area 1, as well as the red fox and the red-tailed hawk, species that are less likely to spend their entire lives on Demo Area 1, which is only about 7.5 acres in size, and relatively small compared to their home ranges. However, these predators could possibly be exposed to chemicals that have the potential to bioaccumulate in prey species such as mice or shrews.
Mr. Alsop stated that exposure models were used to evaluate potential doses, and toxicity reference values (TRVs) were used to look at potential effects. In addition, all the data from the 600 soil samples taken from Demo Area 1 were used to evaluate potential concentrations of contaminants of concern. Mr. Alsop reported that the models used to characterize the potential ecological risk indicated that significant risks to ecological receptors at Demo Area 1 were unlikely. However, based on comments received from DEP and EPA, questions were raised about how conservative or realistic the models were, given that thereís not a lot of data for some of the chemicals at Demo Area 1, particularly the explosives. Therefore, the proposal was made to do field sampling to look at potential effects to native vegetation, and to look at bioaccumulation models used to evaluate contamination concentrations in plants, in soil invertebrates (earthworms, in this case), and in small mammals (shrews and mice in this case). Mr. Alsop also stated that an additional objective of the biota sampling effort is to collect data that can be used to characterize the same kinds of risks at other MMR sites, such as the Central Impact Area and the J Ranges.
Mr. Alsop then reported that on October 11, 2002 the small mammal collection effort was shut down because a sufficient amount of material had been collected to analyze for chemical concentrations in small mammals. He noted that plant samples also have been collected, and soil samples for chemical analysis and for bioaccumulation studies in earthworms should be collected soon. Mr. Alsop further noted that completed laboratory data analysis is expected back in January 2003, after which a draft formal report will be prepared and issued sometime in April 2003.
Mr. Dow said that heís aware of studies of polychaete worms in marine sediments that have shown that toxic contaminants bioaccumulate in the worms as sediments pass through their systems. He asked if similar studies have been conducted for earthworms moving through soil. Mr. Alsop replied that such studies are starting to become available. He also reported that heíd be involved with a 28-day bioaccumulation study where, in a laboratory situation, earthworms are added to soil from Demo Area 1. At the end of the 28 days, the concentration of contaminants in the earthworms will be compared to concentrations in the soil.
Mr. Dow also mentioned that heís aware of studies of marine sediments and the bioavailability of nitrotoluenes and other explosives that are liberated into the marine environment. He asked if similar studies have been conducted for terrestrial sediments, to look at the difference between the measured concentration and the bioavailable concentration. Mr. Alsop replied that the U.S. Army Center for Health Promotion and Preventive Medicine (CHPPM) did a number of literature surveys and found that thereís very little information available about the bioaccumulation and bioavailability of nitro-aromatics and explosive type compounds in terrestrial systems. He also said that this is one of the reasons why EPA and DEP requested that these studies be done at Demo Area 1.
Mr. Schlesinger asked whether moths and turtles were studied as receptors. Mr. Alsop replied that they were not, and explained that this is because thereís next to no information about their potential exposures, potential feeding habits, the amounts they eat, what they eat, where they eat, their metabolism, their physiology, and their potential toxicity. He said that very few, if any, toxicity tests have been applied to either moths or turtles. Mr. Alsop explained that when people are interested in a chemical they test it on rats in order to see what might happen to humans; people typically donít look for toxicity information for non-human receptors.
Mr. Schlesinger then asked if itís correct that the ERC is looking at potential risk resulting from an unplanned released of water taken up to the surface from depth. Mr. Alsop clarified that the ERC is only looking at potential effects to receptors from contaminants in soil. He also noted that groundwater is 60 feet below Demo Area 1, and so there are no potentially complete exposure pathways through ecological receptors at Demo Area 1 to groundwater. Mr. Schlesinger noted that the groundwater is going to be brought up for treatment, and he questioned whether the ERC has to take into consideration unplanned releases of that water. Mr. Alsop replied that it does not have to do so under the MCP.
Dr. Stahl indicated that heís concerned about the makeup of the soil used for the invertebrates study. Mr. Alsop stated that based on the workplan, which was reviewed by DEP and EPA, six locations that had high contaminant concentrations were selected, including a location with maximum concentrations of explosives, and another with maximum concentrations of metals. Dr. Stahl asked if the soil samples would be tested before the start of the study. Mr. Alsop replied that they would be tested concurrently with the earthworm bioassays.
Mr. Judge referred to the application of the Demo Area 1 model to other areas, and noted that a mouse in one location might be eating something quite different from a mouse in another location Ė for example, cranberries that might contain ethylene dibromide (EDB). Mr. Alsop replied that to the extent possible, the program would take advantage of available data. For instance, in addition to tissue from mice, analyses also will be done of tissues from shrews and meadow voles that were caught at Demo Area 1. Mr. Alsop noted that meadow voles, which are primarily herbivores, would be compared to mice, which are omnivores, as well as shrews, which are insectivores. He said that information about different feeding strategies within Demo Area 1 would be used to evaluate what additional information is needed about other scenarios where different habitats and different feeding strategies are involved.
Archive Search Report
Schooner Pass Community Supply Well
Mr. Gregson reminded the team that the Guard is taking direction on how to proceed on this issue from DEPís Drinking Water Program, whose requirement for quarterly sampling has not changed at this point. He also noted that there hasnít yet been a meeting with Schooner Pass residents and their water superintendent, but that is just a matter of scheduling, and a meeting is going to be arranged.
Mr. Minior said that he believes that it was RDX that was detected in the Schooner Pass well, not perchlorate. Mr. Hugus stated that this makes his point even stronger. He said that he thinks that it just isnít right that thereís RDX in a public drinking water well, even at concentrations below the health advisory, and he would urge the Guard to find an alternate water supply for Schooner Pass residents.
Mr. Schlesinger questioned how the quarterly sampling frequency was determined. Mr. Pinaud said that itís his understanding that once thereís a detection in a water supply, itís routine for DEP to require quarterly sampling. He also said that he believes that the Schooner Pass well does have a connection to the Bourne Water District, which could be used.
Mr. Walsh-Rogalski, who noted that to him the source of the RDX clearly appears to be the Impact Area and the training ranges, asked whether thereís any doubt in Mr. Gregsonís mind about the source of this RDX. Mr. Gregson replied that at this point thereís only one well with one detection, and that well is off post; therefore, he canít give a definitive answer.
Mr. Judge stated that he too is in favor of increased testing of the Schooner Pass well. He also said that he would encourage the Guard to meet with the residents of Schooner Pass as soon as possible.
Mr. Pinaud clarified that while DEP required quarterly testing, it did not limit the frequency of testing. He also said that itís his understanding that the Guardís offer to do monthly testing was turned down. Mr. Judge said that this sounds unusual, and he would like to see some record of an offer having been declined.
Mr. Hood stated that after last monthís IART meeting, he conducted a telephone survey in Connecticut of the Department of Environmental Protection, the Department of Public Health, and three water companies, including the Metropolitan District Commission, which is the largest water company in Connecticut. He reported that everyone he spoke with agreed that quarterly testing is a regulatory requirement. However, they also said that the recommended best practice would be to do weekly testing to establish a "baseline of the new contaminant showing up," and then depending on results, drop back to monthly testing. Mr. Hood concluded that the regulatory requirement and the recommended best practice are two entirely different things.
Mr. Hugus said that although Mr. Gregson wouldnít commit to the source being from the base, the IART was provided with about seven different aerial views with a particle back track going from the Schooner Pass well to the Impact Area. Therefore, he thinks that the Guard must believe that the source is from the base. Mr. Gregson reiterated that thereís only one well with one detection. He also said that the particle track does not go back to the Impact Area, but to a wooded area in the northwest part of the base, where there arenít any known disposal or source areas. He reiterated that based on the data he has, he couldnít give a definitive answer about the source.
Mr. Hugus said that he would then rephrase his question, and he asked if Mr. Gregson is behaving as if the Guard was not responsible toward Schooner Pass. Mr. Gregson replied that that is not the case, and noted that the Guard is investigating the source of RDX, which is a military explosive, and is proceeding in cooperation with the water supplier and with DEPís Drinking Water Program.
Mr. Hugus then stated that he doesnít think that the residents of Schooner Pass should be exposed to RDX in their water; that he thinks it is the Guardís responsibility to ensure that the Schooner Pass residents have an alternate water supply; and that he too would like to see some evidence that Schooner Pass turned down the Guardís offer to test do monthly testing.