Impact Area Review Team

River River Drops of rain on a leaf

Impact Area Review Team
First Church of Christ
Sandwich, MA
April 22, 2003
6:00 p.m. Ė 9:00 p.m.

Meeting Minutes





Hap Gonser




Ben Gregson



LTC Dave Cunha

HQ Camp Edwards


Marty Aker




Todd Borci



Bill Walsh-Rogalski



Margery Adams



Len Pinaud



Ellie Grillo



Dick Judge



Richard Hugus



Bob Mullennix



Judy Conron



Michael Butler



James Kinney



Evelyn Hayes



Janet Pepin




Tom Cambareri




Jim Stahl



Amine Dahmani








Jim Murphy








Tina Dolen



LTC Brian Rogers




Bill Sullivan




Mike Minior




Ed Wise




Ira Leighton



Susan Studlien



Jane Dolan



Bob Lim




Millie Garcia-Surette




Kevin Hood




David Dow

Sierra Club



Mark Harding

Mashpee Wampanoag


Minos Gordy



Patrick Skelly

Bourne resident


Jean Crocker




Minos Gordy



David Heislein




Kim Harriz


Jay Clausen



Rob Clemens



Mark Hutson



Kris Curley



Lori Boghdan



Jennifer Washburn



Jane Moran



Action Items:

  1. Mr. Kinney requests information on the number and cost of Impact Area Groundwater Study Program (IAGWSP) monitoring wells planned for the year.
  2. Mr. Gregson will report back to the Impact Area Review Team (IART) regarding the detection, if any, at monitoring well 240 (MW-240) in the Demolition Area 1 plume.
  3. Dr. Dahmani asks the IAGWSP to look into modeling/calculating worst-case scenarios with respect to contamination from the Demolition Area 1 plume, and the J Ranges contamination near Snake Pond.
  4. Mr. Judge requests that the IART be updated on efforts to recover money for cleanup from contractors that formerly utilized areas in the J Ranges.
  5. Mr. Kinney asks that the IAGWSP and the Installation Restoration Program (IRP) consider undertaking a study of potential effects on biota in Snake Pond from explosives, perchlorate, and ethylene dibromide (EDB) contamination.

Future Agenda Items:

Program Overview Continued, Central Impact Area

Handouts Distributed at Meeting:

  1. IAGWSP Reports with Comments Due through May 2003, as of 3/31/03
  2. Presentation handout: Investigation Update
  3. IAGWSP Data Tables
  4. Presentation handout: Fate-and-Transport Overview & Update
  5. Laboratory Fate and Transport Studies of High Explosives at the Massachusetts Military Reservation, Final Report
  6. Press Releases, Neighborhood Notices, and Media Coverage 3/25/03 Ė 4/18/03
  7. Impact Area Groundwater Study Program Update Ė April 2003

Agenda Item #1. Moment of Silence for Joel Feigenbaum

Mr. Murphy asked the IART members to observe a moment of silence to remember one of the teamís founding members, Dr. Joel Feigenbaum, who had died the week before.

Agenda Item #2. Discussion with Ira Leighton of EPA

Mr. Murphy introduced Ira Leighton, Deputy Regional Administrator for the U.S. Environmental Protection Agency (EPA), who was sent by Robert Varney, EPAís Regional Administrator, to meet with the IART.

Mr. Leighton said that itís a great pleasure for him to have this opportunity to address the IART members, many of whom he spoke with individually prior to the meeting. He noted that he is a career person with EPA, has been doing environmental work for over 32 years, and has dealt with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), the Resource Conservation and Recovery Act (RCRA), and other similar programs. He said that Mr. Varney believes that he (Mr. Leighton) could make a contribution at the Massachusetts Military Reservation (MMR) and give the project the senior-level attention that it deserves. Mr. Leighton said that he has a "certain amount of passion and desire to make a difference," which he thinks team members will observe for themselves over time.

Mr. Leighton then commended the IART for its hard work and commitment, and noted that heís come to learn that citizen involvement is a critical link "that allows us to do this job and do it well." He said that one important reason why MMR is a high priority for EPA is that it involves a sole-source aquifer. Also, drinking water is a high priority in this region, and this is demonstrated by the high value that the states and EPA place on pollution-prevention approaches pertaining to drinking water, and the proactive way that the states deal with protection of source waters.

Mr. Leighton stated that the work thatís done in government is only effective with the commitment of the citizensí time and energy "to getting the job done." He said that he is committed to working as hard and effectively as he can with all of the key partners, including the IART, the Department of Defense (DoD), and the state. He noted that he and Ed Kunce, who is the acting Commissioner of the Massachusetts Department of Environmental Protection (DEP), and Ray Fatz of the Army, all are committed to ensuring that what they do at a senior management level translates into effective results.

Mr. Leighton also announced that earlier today, at EPAís annual environmental merit awards ceremony at Faneuil Hall in Boston, EPA recognized the enormous contributions of Dr. Feigenbaum to Cape Cod by honoring him with a lifetime achievement award. He then read an excerpt from the speech that was made at the ceremony: "We honor Joel, a citizen activist, who was passionate about peopleís rights to clean air, clean water, and clean land, and who insisted the government honor that right. He spent his life as an exceptionally intelligent and effective advocate for government actions to protect public health. His decades of work as a citizen activist concerned with groundwater pollution from training and other practices at MMR were instrumental in getting the regional and national attention to this problem. His skill in getting government to work for the people came from his rare blend of intelligence, passion, energy, and willingness to sacrifice. The hundreds of thousands of Cape Cod residents and visitors whose land and water are measurably cleaner as a result of his tireless hard work owe a great debt of gratitude to him, as does EPA and other entities who have had the benefit of his advocacy." Mr. Leighton stated that Dr. Feigenbaum will be missed, but EPA is looking to leadership from the IART to move its efforts forward. He then opened the floor to any questions or comments from the team.

Mr. Hugus said that as Dr. Feigenbaumís good friend and as an IART member, he would like to thank EPA for giving Dr. Feigenbaum a lifetime achievement award. Mr. Hugus then urged EPA to stand strong and represent the citizens of Cape Cod with respect to recent DoD efforts to ask for exemptions from environmental regulations. He said that while he understands that the exemptions do not pertain to the Safe Drinking Water Act (SDWA), he worries that the SDWA could be threatened in the future. Mr. Hugus also urged EPA to stand strong with respect to the role of the military in the cleanup. He said that as a result of a recommendation that came out of a military audit of the program, the military seems to want to be "above the authority that EPA has over the cleanup." Mr. Hugus then thanked Mr. Leighton for coming to the meeting, and asked him to convey his thanks to Mr. Varney for having sent him.

Ms. Hayes asked Mr. Leighton to comment on the term "making the Cape whole." Mr. Leighton said that he expects there to be some reliance on the state, which has taken on a leadership role in assessing and evaluating work done to date Ė specifically, the water supply report. He said that EPA hopes to work with both Mr. Kunce and Mr. Fatz to make progress in determining a way forward, once thereís an assessment that everyone agrees is accurate. Mr. Leighton added that EPA thinks that the stateís efforts to review the water supply report and make its own determination regarding need is a very important first step. He then invited Ms. Garcia-Surette of DEP to comment.

Ms. Garcia-Surette stated that DEPís Water Supply Group in the Southeast Region, with the support of Boston, is working hand-in-hand with all the water superintendents and the communities, and itís her understanding that DoD also is meeting with the water superintendents. She said that the main issue is to ensure that all expectations are managed so that the term "making the Cape whole" can be better understood by everyone. Ms. Garcia-Surette also mentioned the Natural Resources Trustee Council (NRTC), which was established to assess damages to compensate for potential injuries to groundwater and other natural resources, from plumes in both the northern and southern parts of the base. She said that the NRTC process is moving along well, and the council is expected to be meeting next week. Ms. Garcia-Surette stated that she believes that the two efforts will bring about the change that everyone is anticipating, in an expedited fashion.

Ms. Hayes then inquired about the guidance document for perchlorate recently issued by EPA. Mr. Leighton noted that EPA Headquarters (HQ) issued a guidance document that identifies an appropriate cleanup range of 4 to 18 parts per billion (ppb), to be used while the National Academy of Sciences (NAS) is reviewing recent science related to perchlorate. He explained that this guidance would be relevant in choosing final remedies. He also invited Ms. Garcia-Surette to comment on the stateís view on perchlorate.

Ms. Garcia-Surette noted that if a standard for a particular chemical doesnít exist in DEPís cleanup regulation, the Massachusetts Contingency Plan (MCP), methods are available to help arrive at a cleanup standard. She said that DEP has identified perchlorate as warranting the need for promulgation of both a soil and groundwater standard. At the end of May 2003, DEPís Scientific Office of Research and Standards will be sponsoring a Scientific Advisory Board meeting, which will be open to the public, thereby providing the opportunity for everyone to understand where DEP is going with the promulgation of a perchlorate standard. Ms. Garcia-Surette also noted that DEP would provide the IART with a schedule associated with the promulgation of standards.

Mr. Judge mentioned putting an emphasis on the precautionary principle, and noted that in addition to the perchlorate issue, the NAS is involved with the issue of electromagnetic radiation at MMR, but is just recently becoming "informed by outside sources" rather than depending on a single source of information. Mr. Judge then urged EPA to "listen very intently" to the state, especially with respect to its knowledge and understanding about the NRTC, which he described as a council whose makeup includes many voting members who are responsible for the injuries to resources. He said that he thinks itís important for the NRTC to have clearly defined cleanup levels, and he noted that under CERCLA, munitions on the ground are considered just "scrap metal," not future pollutants. He added that to him "making the Cape whole" means ensuring that all injuries and potential injuries to resources are considered, and repairing or replacing those resources. Mr. Leighton replied that EPA works closely with DEP with respect to cleanup standards and detection methods. He also assured Mr. Judge that ongoing communication is effective and at the highest level, with ongoing conversations among himself, Mr. Kunce, and Mr. Fatz.

Mr. Mullennix asked if Mr. Leighton envisions a day when the National Guard will be able to resume regular training at the northern part of the base. Mr. Leighton replied that itís been EPAís position that the land on top of a sole-source aquifer is one of the least desirable places to conduct training. He also said, however, that he thinks that the military is the first point of decision-making with regard to that question. He noted that EPAís Administrative Orders (AOs) include provisions for the military to make a case for conducting training, if judged necessary and appropriate. To date, the military has chosen not to make that particular claim.

Ms. Garcia-Surette added that about two years ago the Commonwealth of Massachusetts and the Department of the Army entered into a Memorandum of Agreement (MOA) that looks at "just the protection of upper 15,000 acres, and training is happening currently." She said that Chapter 47 of the Acts of 2002 basically preserves the upper 15,000 acres, primarily because of the sole-source aquifer. Ms. Garcia-Surette also said that Mr. Mullennix could speak individually to LTC Brian Rogers about the MOA.

Mr. Kinney thanked EPA for honoring Dr. Feigenbaum, and suggested that honoring him also should involve continuing actions that lead to successful conclusions. He then said that on the IRP side of the cleanup, the statement has been made that contamination would be cleaned up to nondetectable levels, not just to maximum contaminant levels (MCLs). He noted that this is particularly important when dealing with a whole host of chemicals, which combined can create a "soup" that he considers unacceptable to Cape Codders, given the lack of science about synergistic effects. Mr. Kinney also disagreed that the military is first point of decision-making when it comes to resuming training on the northern part of the base. He said that he thinks that the first point of decision-making is the citizenry, because the military, EPA, and DEP "work for us." He then commented that he believes that "making the Cape whole" should include the specific requirement of treatment to nondetectable levels.

Mr. Cambareri also thanked EPA for recognizing the work of Dr. Feigenbaum, who he described as having been "a lightning rod for the community on this subject." Mr. Cambareri then said that to him the term "making the Cape whole" pertains to water supply, and this issue is now a concern of many groups, including DEP, the Environmental & Readiness Center (E&RC), the Upper Cape Water Supply Reserve, the Senior Management Board (SMB), and the Environmental Management Commission (EMC). He also mentioned that thereís some disagreement with findings in DoDís water supply report. Mr. Cambareri then stated that he thinks that the effort to find clean water supply in the Reserve should continue, and he believes that the IART, through the SDWA, should not only pursue site discovery in terms of contamination, but also in terms of clean areas. He also said that he thinks that EPA can provide the leadership needed to "make the Cape whole," by bringing together all the various groups heíd mentioned.

Mr. Leighton said that he thinks the work starts with an assessment of need, and the state is very much engaged in that at this point. He also thanked the IART members for the opportunity to meet with them, and said that he looks forward to working with them in the future.

Agenda Item #3. Welcome, Review Draft Agenda, Approval of 3/25/03 Meeting Minutes

Mr. Murphy announced that Mr. Varney selected three new IART members: Michael Butler, Judith Conron, and Robert Mullennix, who are in attendance at tonightís meeting. He then asked everyone else at the table to introduce and identify themselves for the new members, which they did, as follows: Mr. Borci, EPAís technical project coordinator for the IAGWSP; Mr. Walsh-Rogalski and Ms. Adams, EPA lawyers; Dr. Stahl, an adviser with the Technical Outreach in Support of Communities (TOSC) program, a scientific group providing technical support to citizen IART members; Mr. Hugus, Falmouth resident, past member of base cleanup teams associated with contamination at Otis Air Force Base, and founding IART member appointed by former EPA Regional Administrator, John Devillars; Mr. Gonser, program manager for the IAGWSP; Ms. Grillo, DEP employee for 16 years, most of them spent on MMR cleanup projects in both the northern and southern parts of the base; Mr. Pinaud, DEP remedial project manager; Mr. Aker, program manager and hydrologist for the Air Force Center For Environmental Excellence (AFCEE); Ms. Hayes, Yarmouth resident and former university professor, with family living in Bourne; Ms. Pepin, Falmouth resident; Mr. Judge, Sandwich resident and former selectman, interested in ensuring protection of the Cape; Mr. Gregson, technical program manager for the IAGWSP; LTC Cunha, deputy commander of the base, stationed on the Cape, and an IART member for the past two years; Dr. Dahmani, TOSC adviser from the University of Connecticut; Mr. Cambareri, Cape Cod Commission (CCC) water resource program manager, involved with groundwater work on Cape Cod for more than 20 years, familiar with towns surrounding the base, their planning and water supply needs and how they relate to the contamination being studied; Mr. Kinney, an original member of the IART, and former member of the Plume Management Team, back when the military was "far less inviting"; and Ms. Moran, CH2M HILL employee, writes meeting summaries for the IART, the PCT, and the SMB.

Mr. Murphy reviewed the meeting agenda and asked if there were any recommended changes or additions. Mr. Kinney noted that heís interested in seeing the forthcoming fiscal yearís budget for exploratory wells. Mr. Murphy acknowledged Mr. Kinneyís request for this information and said that he thought it could be provided at a future date.

Mr. Murphy then stated that basic IART groundrules include raising name-tents to be recognized, speaking one person at a time, and treating fellow team members civilly. He also noted that all IART members soon will be provided with an IART handbook that contains information on the purpose of the team, how it operates, and further details on groundrules.

Mr. Mullennix inquired about the non-citizen membersí responsibilities to the team. Mr. Murphy replied that this information would be included in the IART handbook, but he also invited the non-citizen members to provide brief answers to Mr. Mullennixís question. Mr. Gonser stated that his and Mr. Gregsonís role is to provide information about the cleanup project that the team needs and to answer any questions. Mr. Borci, speaking for the EPA team, noted that Ms. Adams and Mr. Walsh-Rogalski make up the legal component, while he, as the technical project coordinator, oversees the entire technical direction of the project. He also noted that others on the EPA team at MMR do not sit at the IART table, but are responsible for specific sites related to the cleanup. Mr. Pinaud stated that DEPís role is to provide regulatory oversight for compliance with the MCP. Ms. Grillo, the community involvement person for DEP, said that her focus is to understand the communityís concerns and informational needs and ensure that they are considered in decision-making pertaining to the cleanup project. Mr. Murphy said that his role with EPA is the same as Ms. Grilloís, as is Ms. Dolenís for the IAGWSP.

Mr. Murphy asked if there were any changes or additions to the March 25, 2003 IART meeting minutes. No changes were offered and the minutes were approved as written.

Mr. Murphy also told the new team members that between IART meetings they would be receiving numerous documents to review prior to the following meeting, and occasionally would be asked to comment on documents between meetings, via e-mails to the EPA, DEP, and IAGWSP project managers. Ms. Conron asked if responses to comments are shared with all team members. Mr. Borci replied that the process is meant to be transparent; therefore, all comments are open to all team members, sometimes in the form of an appendix to a final or draft document.

Mr. Gregson noted that the last IART mailing included a brief summary of documents recently distributed to team members for review, and the date that comments are due. He said that from now on this type of summary would be provided on a regular basis. Mr. Murphy added that copies of the summary are available at this meeting for new members. Dr. Dahmani reminded the new members that TOSC advisers are available to help them understand complicated technical documents.

Ms. Crocker stated that the February 25, 2003 IART meeting minutes indicate that she told Mr. Gonser something like, "he should feel appreciative of the assistance that he is getting from the upper echelons of the military officers in Washington," while in fact she had been addressing Mr. Walsh-Rogalski and Mr. Hugus regarding their criticism of the National Guard. Ms. Crocker said that she thinks this mistake was made because a personal conversation had developed, and she would encourage everyone to communicate through the facilitator in order to avoid further "bickering back and forth." Mr. Murphy noted that Ms. Crockerís correction to the February 25, 2003 IART minutes would be reflected in this document, the April 22, 2003 IART minutes.

Agenda Item #4. Investigations Update

Demolition Area 1 Recent Unvalidated Detections

Mr. Gregson showed a map of the Demolition Area 1 plume, and reported that MW-255, located on the northern edge of the plume, tested nondetect for explosives, but had a low-level perchlorate detection of 0.54 ppb. MW-258, located along the power line road, had low-level perchlorate detections in two well screens, at 0.41 ppb and 0.49 ppb. MW-248 and MW-252, which are south of MW-258, both tested nondetect for perchlorate. Mr. Gregson stated that based on results from these wells, the IAGWSP sent a letter to EPA and DEP stating that the extent of contamination at the Demolition Area 1 plume has been defined to the degree necessary to proceed with the feasibility study.


Mr. Hugus explained to the new IART members that the farthest extent of a plume is referred to as the toe, and for a long time now the team has been trying to define the Demolition Area 1 plume toe, which now appears to be farther west than is depicted, given the recent detection at MW-258. He also said that while heís glad the feasibility study can move forward, the detection at MW-258 indicates to him that the full plume shell still is yet to be defined. Mr. Gregson stated that monitoring would continue at that location. He also noted that detections of 0.41 and 0.49 are very close to the detection limit of 0.35 ppb, and given the geometry of the rest of the plume, the IAGWSP "feel pretty comfortable" that MW-258 is at the toe of the plume. He further noted that the plume depiction would be redrawn to encompass the detection at that well.

Mr. Pinaud mentioned that the regulators would be weighing in on a long-term monitoring program to be submitted by the IAGWSP in September. He said that IART members would be able to look at that monitoring program, which will include additional wells downgradient of and along the flanks of the plume. He also asked Mr. Gregson to discuss the IAGWSPís decision to change the location of a proposed reinjection well due to the detection at MW-255. Mr. Gregson explained that that reinjection well was to be located near MW-255, but instead will be installed to the north in order to ensure that the treated water is injected in an area beyond the extent of contamination. Profile samples will be taken during drilling, and if they come back nondetect, the reinjection well will be installed at the northern location.

Ms. Hayes asked if itís correct that MW-258 is now the toe of the plume. Mr. Gregson replied that it is, and stated that the nondetect contour line will wrap around that well in the updated plume depiction.

Mr. Judge said that heíd like to see some monitoring wells installed outside the nondetect contour line near MW-162 and MW-78, in order to ensure that the plume is not wider there than itís depicted. Mr. Gregson explained that the nondetect contour was defined based on the gradient and the dramatic drop in concentration levels from the center of the plume to those wells near the edge.

Mr. Dow said that it appears that MW-173, MW-240, and MW-258 are on a flow line, and asked whether there had been any recent detections at MW-240, which is shown as a nondetect well. Mr. Gregson replied that he couldnít recall if thereíd ever been a detection at MW-240. He also said that itís thought that the flow line runs from MW-175 out to MW-240. Mr. Dow asked whether modeling suggests that the plume might be hooking to the northwest, rather than proceeding straight downgradient. Mr. Gregson replied that the modeling suggests that the flow at that location is more to the west.

Mr. Dow then asked whether MW-258 is considered "the equilibrium profile" for the plume, given the moraine that exists to the west. Mr. Gregson replied that all of the wells in that location are in an area that what would be defined as moraine. He also said that while he would be happy to say that the plume has reached equilibrium and is no longer migrating downgradient, he has no information that would support that statement. He further noted that mass continues to be introduced to the groundwater from the upgradient perchlorate source area, which supports continued migration of the plume.

Dr. Dahmani asked whether the well-screen lengths are similar at every sampling point. Mr. Gregson replied that for the most part the screen lengths are all 10 feet. In rare instances, however, some 5-foot screens are used to collect isotope data for age dating. Dr. Dahmani noted that dilution factors could be significant when dealing with very low concentrations, so itís important that screen lengths are consistent. He also inquired about sampling protocols and quality assurance. Mr. Gregson replied that in this and in many cases at MMR, groundwater sampling is conducted by AMEC. He also noted that standard operating procedures (SOPs) for sampling, approved by EPA and DEP, were established in 1997, and that protocol continues to be followed.

Mr. Borci informed the new IART members that Demolition Area 1 is by far the strongest source area at the base. The main compounds in the Demolition Area 1 plume are RDX, an explosive, and perchlorate, a propellant. The map shows the extent of perchlorate contamination in pink and the extent of Royal Demolition Explosive (RDX) contamination in tan. Because contamination was continually being found farther downgradient than expected, the National Guard, EPA, and DEP agreed to implement an interim remedy that could be done quickly, while continuing to move forward with the somewhat more cumbersome process of a feasibility study to arrive at a long-term remedy. Mr. Borci stated that the interim remedy involves an extraction well at Frank Perkins Road, near the center of the plume, to prevent further migration of upgradient high-concentration contamination, and another extraction well toward the toe of the plume. He said that because concentrations have increased at MW-211, the approximate location of the original proposed toe extraction well, and because of the recent detection at MW-258, EPA, DEP, and the National Guard are working toward finalizing the exact location of the toe well.

Ms. Conron asked if plume depictions are updated whenever thereís a new detection. Mr. Gregson replied that plume depictions are not updated with every new sampling result. He also noted, however, that the Demolition Area 1 plume depiction will be updated to support the modeling effort associated with the feasibility study.

Mr. Mullennix inquired about the well near MW-258, identified as OW3-91. Mr. Gregson replied that OW3-91 is an old water table well with a screen that is not at a proper depth to be sampled for the plume investigation.

Mr. Mullennix also said that as a consumer of water from the Bourne Water District (BWD), heís interested in knowing whether the plan is to capture all the perchlorate-laden water at the toe of the plume, once itís defined, or just those concentrations above DEPís health advisory of 1 ppb. Mr. Gregson stated that, as was mentioned, the current proposal is to install an extraction well near MW-211, which would capture concentrations in the 3 to 6 ppb range. A key part of the feasibility study will be to determine whether additional wells are needed in that area to capture that portion of the plume. Mr. Gregson also made a point of noting that the BWD supply wells are not downgradient of the plume, but are located farther to the north. Mr. Mullennix asked if there are any drinking water wells downgradient of the plume. Mr. Gregson replied that none have been identified downgradient of that location.

Mr. Mullennix inquired about quality control associated with very low-level perchlorate detections such as 0.39 ppb and 0.41 ppb, and assurance that those low levels are not false positives. Mr. Gregson replied that with the low detection limits being used receive a tremendous amount of scrutiny on the part of the IAGWSP office, the U.S. Army Corps of Engineers (USACE), AMEC, and the laboratory itself, as well as the regulators. He also said that while he canít recall the specific quality control procedures at this time, he could provide that information.

Mr. Gordy, who identified himself as a member of Patriots Advocating Camp Edwardsí Restoration and Survival (PACERS), questioned how such low-level detections could be reconciled with EPAís recent memorandum, which pointed out how errors in testing can occur. He said that he doesnít have much confidence in those low detections, and indicated that heís skeptical about the closing of the BWD supply wells, which were shut down because of sporadic "supposed detections which the EPA says arenít valid."

Mr. Gregson stated that at this time the IAGWSP is working with a 1-ppb laboratory reporting limit and a 0.35-ppb method detection limit (MDL) for perchlorate. Values below 1 ppb are reported as estimated values because of the lower level of confidence in exact concentrations below 1 ppb; nevertheless, those concentrations above the MDL are believed to be real.

Mr. Borci said that he wants to clarify that thereís sufficient data to understand that an area of low-level perchlorate contamination exists at the BWD wellfield. That area is being monitored closely and concentrations above 1 ppb have not been seen. The supply wells themselves also are being monitored, and the three that were shut down had intermittent perchlorate detections, all below 1 ppb. The supply well thatís currently operating has never had a perchlorate detection.

Mr. Skelly disagreed that the plume outline should be changed so much that it encompasses MW-258, given that the pink contour "is set at a nominal 1.5 ppb," and the perchlorate level detected at MW-258 is only about one-third of that. He also said that ongoing improvements in technology continue to reduce detection limits, making it impossible to reach a nondetect cleanup goal. He then noted that a background chemistry exists, independent of humans.

Mr. Pinaud stated that the proposed interim action put forth by the IAGWSP sites the toe extraction well at Pew Road. However, DEPís preference is to attempt to achieve complete capture of the plume by siting that well farther west, at the power line road. He said that this issue has not yet been resolved.

Mr. Cambareri inquired about the status of MW-252. Mr. Gregson replied that MW-252, which is a new well, tested nondetect, but the result is still unvalidated.

Dr. Dahmani inquired about the action level associated with the feasibility study. Mr. Gregson replied that he doesnít know what action level will be used. Dr. Dahmani said that he assumes that the action level will be greater than 1 ppb, and he thinks it would be helpful to have the modelers calculate mass discharge beyond the toe extraction well in order to help determine whether or not there would be any real danger to a nearby water supply well. He said that if the plume were well defined three-dimensionally, the concentration of contaminant going through a certain cross-section of the plume could be determined, and based on that, predictions could be made about what might happen at a water supply well in the future. Mr. Gregson noted that one of the feasibility study alternatives would reduce concentrations to background.

Ms. Hayes inquired about the RDX contours. Mr. Gregson replied that the darker tan area represents the 2-ppb RDX contour, and the dark outline represents the nondetect RDX contour. He also mentioned that 2 ppb is the health advisory for RDX, and noted that the extent of RDX contamination is fairly well defined. Ms. Hayes asked which of the two compounds is being given top priority: RDX or perchlorate. Mr. Gregson replied that the interim action addresses both compounds equally.

Ms. Adams clarified for the new IART members that the AOs require that cleanup levels be attained throughout the entire aquifer. Therefore, contamination is a concern even if itís not yet on a path toward a known water supply well.

Mr. Judge said that potential water supply well sites southwest of the Demolition Area 1 plume were considered, but rejected, for the Upper Cape Regional Water Supply project. He suggested that the opportunity to site a well there was lost because of the plume.

Mr. Mullennix noted that the EPA memorandum states that no regions shall set any cleanup standard more stringent than the current health advisory for perchlorate, which is 4 to 18 ppb. He then said that itís his understanding that the feasibility study will require a more stringent standard, and he questioned whether permission for that has been obtained from EPA HQ. Mr. Walsh-Rogalski clarified that rather than dictate cleanup levels, the AOs lay out a number of different cleanup scenarios that must be evaluated in a feasibility study. Those scenarios involve different technologies and different cleanup levels, including cleanup to background, which is based on the MCP. He also said that EPA has always said that it will select the final remedy based on extant guidance at the moment of selection, at both the national and state level. Mr. Walsh-Rogalski also noted that the guidance states that cleanup goals should not be set above or below the 4 to 18 ppb range, but allows for a case to be made to EPA HQ.

Demolition Area 2 Recent Unvalidated Detections

Mr. Gregson showed a map of the Demolition Area 2 site, and noted that far fewer demolition activities occurred there than at Demolition Area 1. He then reviewed profile results from the four monitoring wells installed in that area, as follows: MW-259 showed an RDX detection at 1 ppb; MW-260 showed RDX detections ranging from 0.7 ppb to 0.8 ppb; MW-261 showed RDX detections ranging from 0.33 ppb to 1.4 ppb; and MW-262 showed an RDX detection at 1.4 ppb. Mr. Gregson noted that there had been some interference with the MW-261 and MW-262 profile sampling. He also said that any additional investigation in this area would be based on results from groundwater samples taken after the well screens have been set.


Mr. Cambareri asked when that sampling is expected to occur. Mr. Gregson replied that sampling results probably would be available by the next IART meeting.

Southeast Ranges Recent Unvalidated Detections

Mr. Gregson showed a map of the Southeast Ranges area, located in the southeast portion of MMR. He said that most of the activity that occurred there was related to defense contractor operations, such as weapons testing.

Mr. Gregson reported that at the J-3 Range, perchlorate was detected at 0.73 ppb in MW-237, a well installed to define the upgradient extent of contamination, which now is thought to be fairly well defined. At Disposal Area 2 in the J-2 Range, profile sampling showed perchlorate at concentrations ranging from 0.4 ppb to 2.6 ppb, RDX at 1.3 ppb and 6.2 ppb, and detections of trinitrotoluene (TNT) breakdown products 4A-DNT, 2,4-DANT, and 2-6-DNT. At the J-1 Range, in MW-265, a newly installed well located downgradient of the inter-berm area, profile sampling showed RDX at 0.17 ppb and 1.2 ppb, and perchlorate in four intervals at concentrations ranging from 4 ppb to 36.9 ppb. Mr. Gregson also mentioned that groundwater in that area flows north/northwest, and the suspected source area is off to the south.


Mr. Borci informed the new IART members that Disposal Area 2, which, unlike Demolition Area 1, is not a documented disposal area, appears to have been used by both the National Guard and defense contractors. He noted that thousands of munitions were pulled from pits at Disposal Area 2 and were destroyed or are awaiting destruction in a contained detonation chamber (CDC) brought to the site by the Army. He explained that the purpose of a CDC is to prevent contaminants from being released to the environment. Mr. Borci stated that approximately 10,000 to 20,000 items were found at the site in the past year and a half of the investigation.

Mr. Borci then noted that the J-1 Range is situated on top of the water table mound, from which groundwater flows out radially in all directions. Because of this, contamination there flows in opposite directions, making it "incredibly complex to try to identify, investigate, evaluate." He also said that J-3 Range contamination at MW-163 is believed to be coming from an open burn/open detonation (OB/OD) area used by defense contractors over the years. The J-3 Range also had been used as a mortar impact area. Possible multiple sources from historical activities that go as far back as the 1930s make for a very complicated investigation of the site.

Mr. Hugus said that heíd like Mr. Leighton to know that the IART has spent about four of its six years of existence trying to define the Southeast Ranges contamination. He expressed concern and frustration that currently there is no plan for stopping the J-3 Range plume that "flows partly into and under Snake Pond," a pond thatís used for recreation. He also said that this is a complicated area because of Fuel Spill 12 (FS-12), another "major plume" thatís nearby, and is being addressed by the IRP. Mr. Hugus further remarked that he would resign from the IART if something werenít done to stop the plume by the seventh year of his membership on the team.

Mr. Judge stated that at a future IART meeting heíd like to hear more about DoDís efforts to recover cleanup monies from Textron, one of the contractors that operated at the Southeast Ranges. He also asked whether the local water commissioners had been informed of detections within zones of contribution (ZOCs) for the Upper Cape Water Supply wells. Mr. Gonser replied that the commissioners receive monthly reports and are notified of any detections in the ZOCs, which, he mentioned, are at "the tail end." Mr. Judge also asked for confirmation of the concentration range associated with the contour line around MW-166. Ms. Harriz of AMEC replied that the light pink color there indicates a range of 1.5 ppb to 10 ppb, but she believes that the actual range there is from 1.5 ppb to 2 ppb.

Dr. Stahl inquired about DNT concentrations at the Southeast Ranges and at Demolition Area 2. Mr. Gregson replied that DNT concentrations at the Southeast Ranges ranged from 0.3 ppb to 2 ppb, and MW-259 in Demolition Area 2, 2,6-DNT was detected in a profile sample at 0.26 ppb.

Mr. Borci said that Mr. Gonser seemed to indicate that because the detection at MW-234 is at the tail end of a ZOC, itís not of much concern. Mr. Borci stated that EPA disagrees with that position, and while glad the contaminant concentrations in MW-234 are low, EPA is concerned about that general area. He said that the source area there is 30 to 40 years old, and itís not known how far that contamination has migrated downgradient. He further noted, however, that there havenít been any detections of Southeast Ranges contaminants in the far-field wells, which are located in front of the water supply wells to act as an early warning system.

Ms. Crocker noted that the Air Force was responsible for the fuel pipeline break that is the source of the FS-12 plume. She also recommended against playing a "blame game," since not only the Army, but also many different parties, including the state police, share responsibility for the contamination at MMR.

Mr. Walsh-Rogalski referred to Mr. Judgeís comment about Textron, and clarified that other contractors, beside Textron, also bear responsibility for contamination at the Southeast Ranges. Unfortunately, Textron has been singled out because itís the most recent, most visible, and most high profile of the contractors due to its voluntary efforts so far. Textron came forward and took responsibility for one cleanup, and has volunteered to do a second cleanup. Mr. Walsh-Rogalski said that he hopes that the Army pursues the other contractors as well, and noted that Atlantic Research Corporation is one of them. Ms. Adams added that corporate successors of Atlantic Research, AVCO, Hesse Eastern, and other contractors also operated at the Southeast Ranges. Mr. Judge suggested that all the contractors should be pursued. Mr. Walsh-Rogalski agreed.

Dr. Dahmani recommended taking a three-dimensional cross section of the J-3 Range plume, determining the mass discharge of contaminants going through that cross-section, calculating the final concentration of contaminant that would enter Snake Pond, and comparing that to the health advisory. Mr. Hugus stated that the dilution factor would be a problem with this exercise, and said that the precise area of upwelling is "a different story." He said that he thinks Dr. Dahmaniís idea is good, but would need to be refined with respect to exposure. Dr. Dahmani said that determining the mass discharge would be a starting point from which a worst-case scenario could be calculated.

Mr. Gregson noted that samples, which are analyzed for explosives and perchlorate, are collected from Snake Pond every two weeks during the summer months. Last year there were no detections of either compound, and the first results from this yearís program should be available before Memorial Day weekend. Dr. Dahmani noted that his point is that determining the potential contamination in the pond would help answer the question of what should be done about the plume. He said that this information could provide "some comfort or raise some concerns related to Snake Pond."

Mr. Minior, the Deputy Remedial Program Manager for AFCEE, noted that the IRP works in conjunction with the Sandwich Board of Health to collect Snake Pond samples that are analyzed for EDB and some volatile organic compounds (VOCs). He also said that on an annual basis the Massachusetts Department of Public Health (MDPH) reviews all available data relating to the pond, from both the IRP and the IAGWSP, and every year has issued the statement that the pond is safe for recreational use. The MDPH is now reviewing current data and is expected to issue another statement about the pond in time for Memorial Day weekend. Mr. Minior also noted that, in consultation with the regulatory agencies, postings regarding the condition of the pond are put on public display at the pond.

Mr. Kinney commented that heís in favor of Dr. Dahmaniís recommendation and Mr. Hugusís suggestion to refine it with respect to locations where upwelling occurs. He also said that he thinks the public should be provided with more information about the pond than a simple statement that "tiny amounts of chemicals in a large body of water" cannot be detected. He then asked whether there are any plans to sample the fish and plants in the pond, and study them in terms of possible effects from contaminants related to both the IAGWSP and the IRP. Mr. Gregson replied that the IAGWSP doesnít have any proposals in place to do that type of sampling, but has done sediment sampling at Snake Pond in the past. Mr. Minior noted that the IRP also has no such current plans. Mr. Kinney said that heíd like noted as an action item his request that the IAGWSP and the IRP consider undertaking a study of potential effects on biota in Snake Pond from explosives, perchlorate, and EDB contamination.

Dr. Stahl asked Mr. Gregson to describe the type of sampling the IAGWSP plans to do at Snake Pond this summer. Mr. Gregson replied that the program involves collecting surface water samples from the beach areas of the pond and having them analyzed for explosives and perchlorate.

Mr. Dow asked if thereís been any study of enzyme biomarkers in the Snake Pond fish, which would indicate whether the fish had been exposed to perchlorate or RDX. Mr. Gregson replied that the IAGWSP has not conducted studies of this type.

Mr. Gordy noted that health advisory limits are based on lifetime exposure, while children who swim in a pond are unlikely to drink the water, and very unlikely to drink it over a lifetime.

Agenda Item #5. Fate and Transport Presentation

Mr. Gregson introduced Jay Clausen of AMEC, and noted that Mr. Clausen has been working on the groundwater program for more than four years.

Mr. Clausen stated that in the case of northern MMR, the concern is explosive compounds and perchlorate, which are deposited on the ground surface as solids. He then began discussing the "fate" part of "fate and transport" by noting that dissolution is the mechanism involved when a solid is deposited on the ground surface and then comes in contact with water. Once a compound is in solution, it can move into the unsaturated zone of the soil and undergo a number of different soil interactions, including adsorption, which is the sorption of a compound out of solution onto a soil particulate. The rate of adsorption is affected by attenuation processes and by partition coefficients. Partitioning can occur from the liquid phase into the vapor phase or from the liquid phase onto a solid particular. A partition coefficient pertains to how strongly something is sorbed onto or desorbed off of a soil.

Mr. Clausen then stated that volatilization is when a compound goes into the gas phase and either migrates through the soil or, if shallow enough, volatilizes out of the soil and back into the atmosphere. He also noted that a number of transformation processes could take place. One is biodegradation, when microorganisms in the soil break down a compound either with oxygen present, which is aerobic biodegradation, or without oxygen present, which is anaerobic biodegradation. Another transformation process is abiotic, a chemical reaction that occurs with the compound as it interacts either with the soil or with the water chemistry in the soil pores. Photodegradation is another transformation process, whereby ultraviolet light causes compounds to break down.

Mr. Clausen began discussing the "transport" part of "fate and transport" by noting that a key process is filtration, when precipitation falls to the ground and moves down to the water table. He also noted that some precipitation might evaporate, depending on the temperature of the soil and the atmosphere, the level of humidity, and other factors. Also, the makeup of the soil, i.e. the proportions of clay, sand, or silt, affects the site hydrogeology. Mr. Clausen stated that advection, which is basically flow, is one mechanism that can transport a contaminant away from the location where it was introduced. He noted that another mechanism is dispersion, which he described as "a water molecule that kind of ping-pongs off of the soil particles," thereby spreading out vertically, laterally, or longitudinally. Diffusion is the mechanism where a compound diffuses into a soil pore, or, in some cases, into groundwater regions called dead-end pores, after which the compound doesnít move any farther. The last transport mechanism is simple dilution, the mixing of the compound with clean water.

Mr. Clausen then showed a slide of the conceptual site model for Camp Edwards. He noted that MMRís unsaturated zone, which, unlike the aquifer, has no continuous water, spans 100 to 120 feet. Bedrock is approximately 300 to 400 feet below ground surface, depending on the location. Mr. Clausen explained that when a compound has sufficient mass, it can overcome the fate processes, move through the unsaturated zone to the water table, and begin to migrate. Recharge, which is clean water being deposited on top of the contaminant, pushes the plumes deeper into the aquifer system. He also mentioned that groundwater ultimately flows to the Cape Cod Canal or out to the ocean.

Mr. Clausen reported that the following were identified as contaminants of concern (COCs) in soil: RDX, High Melting Explosive (HMX), TNT, 2A-DNT, 4A-DNT, 2,4-DNT, nitroglycerine (NG), and perchlorate. With the exception of NG, the same compounds were identified as COCs in groundwater. The identification of these COCs was based on investigation activities at Demolition Area 1 and the Central Impact Area. Other sites havenít progressed far enough to go through the formal process of developing COCs.

Mr. Clausen then discussed testing conducted by the University of Texas to identify important physical and chemical properties of the compounds, to be used in modeling and to help define the conceptual site model. The experiments were conducted in 2000 and a draft report was issued in 2001. The work began with the measurement of soil physical properties, which was followed by a series of batch experiments. The batch experiments looked at the sorption of various compounds onto MMR soil, desorption off of MMR soil, biological degradation rates, and dissolution kinetics. Column experiments were then conducted in order to either support or refute the batch experiment results.

Mr. Clausen noted that soil physical property measurements included bulk density, pH, cation exchange capacity, moisture content, organic content, and particle size. These parameters affect or control how quickly a compound moves through the soil. The values that were obtained are basically consistent with the IRP data collected to date, but the IAGWSP wanted some specific data from its sites. The results were used in the unsaturated zone model for some locations, and in the conceptual site model.

Mr. Clausen explained that the batch sorption experiments, whose purpose is to look at how strongly compounds adsorb onto the soil and how easily they move through it, involved placing site soil and contaminants in beakers, and periodically taking liquid samples to be analyzed. It was concluded that temperature had no effect on the partitioning coefficient, or Kd. The only compound that appeared to be affected by concentration was 2,4-DNT, and the observation was that the higher the concentration of 2,4-DNT, the lower the Kd. A Kd value of 1 is considered to indicate little to no sorption, while greater values indicate some degree of sorption. Experiments were conducted using surface soil from the site, as well as some deep soil, at 100 feet.

Mr. Clausen noted that the Kd for RDX in surface soil was less than 1, and even lower for the deep soil. He explained that the Kd for deep soil is consistently lower because of the lack of organic carbon present in deep soil. He also reported that the Kd for TNT was slightly higher than that for RDX, the Kd for 2,4-DNT was even higher, and the Kd for NG was "a mixed bag" that even showed a result of zero in deep soil, which theoretically isnít possible. Mr. Clausen explained that the EPA method for explosives analysis isnít particularly good for NG, and no really good method exists. He also said that the batch experiments indicated that RDX doesnít sorb to soil to any significant degree, TNT and 2,4-DNT sorb to some degree, and NG was "wishy-washy" in terms of results.

Mr. Clausen stated that batch experiments that looked at aerobic biodegradation involved measuring levels of nitrogen, oxygen, and carbon dioxide (CO2). He noted that when microorganisms are present in soil, thereís a general increase of CO2 and decrease of oxygen over time as the microorganisms consume the oxygen and produce CO2. These measurements showed no indication of biological breakdown of RDX, which is consistent with literature. Also, no RDX degradation products were seen. Batch experiments pertaining to anaerobic biodegradation, which involved looking at the same measurements, produced similar results, but with slightly "noisier" data. Again, no RDX degradation products were seen.

Mr. Clausen also reported that RDX dissolution rate experiments showed varied results, depending on how the experiment was constructed. These experiments were done using pure RDX; C-4, which has some plastic mixed into it; and Composition B, which is a mixture of RDX and TNT. Dissolution rates were different, depending on the exact compound and the concentrations.

Mr. Clausen explained that data from the batch experiments were used to determine the column size for the column experiments, which involved setting up two identical columns to "act as controls with each other," and looking at HMX, RDX, TNT, NG, 2,4-DNT, and 2,6-DNT. He showed a table entitled "Relative Soil Adsorption," and noted that it contains information pertaining to influent and effluent concentrations for both "Column 1" and "Duplicate Column 2." He noted that influent and effluent concentrations of RDX and HMX were essentially the same, although effluent concentration values were somewhat higher due to the analytical precision of the analysis. For TNT, NG, and the DNTs, however, the influent concentrations were higher. No TNT degradation products were seen; therefore, it was inferred that the decreasing concentration coming out of the column was largely a function of sorption of the contaminant onto the soil. Mr. Clausen noted that data collected over time were used to develop the Kd numbers, which are fairly similar to those seen in the batch experiments. Overall it was determined that the sorption capacity of the soils for RDX and HMX is pretty low, the soil has a better capacity to adsorb TNT, and NG and the DNTs are intermediate in terms of their sorption onto the soils at Camp Edwards.

Mr. Clausen stated that the purpose of the fate and transport study was to obtain site-specific information about how compounds move through the soil at MMR. The results of the study provide input terms for the models, help in understanding the fate and transport processes, and help in interpreting data from soil and groundwater samples. Mr. Clausen then reviewed the findings of the studies. He noted that RDX, HMX, and perchlorate move rapidly through the unsaturated zone and the aquifer, and the key process that controls their initial movement is dissolution from the solid to the liquid phase. The other key processes pertaining to these compounds are dispersion, dilution, and diffusion. The study also suggests that the DNTs, NG, and TNT adsorb fairly strongly onto the soils at the site, and undergo rapid transformation, particularly biological degradation. Also, TNT is especially susceptible to ultraviolet light degradation.


Mr. Walsh-Rogalski questioned why unexploded ordnance (UXO), including low-order rounds and cracked duds, werenít represented in the conceptual site model. He also asked whether disposal and OB/OD are meant to represent two different sources. Mr. Clausen replied that they are. He also said that it was just an oversight that UXO werenít included, as they would be valid mechanisms for the conceptual site model. Mr. Walsh-Rogalski said that he would prefer that Mr. Clausen include UXO in the conceptual site model for future presentations.

Dr. Stahl inquired whether any study was done of other COCs at MMR, such as some pesticides and polycyclic aromatic hydrocarbons (PAHs). Mr. Clausen clarified that those compounds are not COCs at Demolition Area 1 and the Central Impact Area. Rather, they were contaminants of potential concern (COPCs), which were evaluated in the risk assessment process, but were not identified as COCs.

Dr. Stahl said that he agrees that the Kd in deep soil is lower because of less organic carbon, and then asked whether the high-clay lenses at Demolition Area 1 were factored in to the fate and transport evaluation. Mr. Clausen replied that to the extent that some clay-rich areas were included in soil samples taken from Demolition Area 1 would be represented in the data. He also noted, however, that clayís only impact would be to slow down flow; there wouldnít be a higher degree of organic carbon in the clay. Dr. Stahl suggested that compounds such as TNT and NG, which do adsorb, would interact with the clay. Mr. Clausen said that in addition to the parameters that heíd mentioned earlier, the study also looked at extractable iron, as thereís some indication that iron can affect a compound like TNT. He noted that different types of clay contain different quantities of iron. Dr. Stahl inquired about iron levels, sulfates, and nitrates in the soil. Mr. Clausen replied that he doesnít recall the exact numbers offhand, but they were in the thousands to tens of thousands parts per million. Dr. Stahl asked whether any analysis was done to determine if there was conversion of nitrates to nitrites, or sulfates to sulfites. Mr. Clausen replied that that specific analysis was not done.

Mr. Judge asked Mr. Clausen to describe the degree of confidence associated with the study results pertaining to biodegradation and adsorption. Mr. Clausen indicated that the level of confidence is "pretty good" that no biological activity is occurring with respect to RDX. While some RDX degradation products have been seen at a location in Demolition Area 1, they havenít been seen elsewhere. Mr. Clausen also noted that the adsorption numbers seen at the site are quite a bit lower than those seen in the literature. This is attributed to the lack of organic material in the sandy MMR soil, however, and therefore thereís a good degree of confidence that the numbers are representative of site conditions. Because the site soil is relatively inert, once in solution, compounds like RDX, HMX, and perchlorate move right through the soil, with little or no adsorption.

Mr. Judge also mentioned the phenomenon of wicking, whereby contaminants can travel back up from the soil and be released above ground. He said that he thinks that the possibility of wicking happening on Cape Cod will be explored, and asked if itís correct that the fate and transport experiments were "one-directional." Mr. Clausen replied, "in the column experiments, yes."

Mr. Dow asked whether dissolved organic carbon was considered as a possible transport mechanism for contaminants that had moved into a dissolved state. Mr. Clausen replied that only total organic carbon was measured, not dissolved organic carbon. Mr. Dow noted that he read about a study of marine sediments amended with TNT and 2,4-DNT, which compared concentrations that were measured chemically versus those measured to be bioavailable. He said that the study found dissolved organic carbon to be quite important in terms of "immobilizing stuff from being adsorbed into things bioavailable." He suggested that this would be something to consider when developing the model.

Dr. Dahmani inquired about the soils used in the study. Mr. Clausen replied that the study involved composite samples, made up of three or four samples each, from the gun and mortar positions, Demolition Area 1, and the Central Impact Area. Dr. Dahmani asked whether the samples were representative of the site. Mr. Clausen replied that they were. Dr. Dahmani asked if the University of Texas performed all the work. Mr. Clausen replied that the University of Texas did all the laboratory work, and Texas Agricultural & Mechanical (Texas A&M) did some of the confirmation analysis.

Dr. Dahmani also inquired about the difficulties associated with using the SESOIL model to handle dissolution kinetics. Mr. Clausen replied that it was necessary to do some calculations outside of the model, and then put that information into the model. He noted that currently an unsaturated zone model that will handle dissolution doesnít exist. Dr. Dahmani said that the SESOIL model cannot handle the uneven distribution of contaminants, which he thinks is "quite a problem." Mr. Clausen said that typically the maximum observed concentration is put into the model. He also said that with SESOIL, the IAGWSP is trying to determine the location of COCs that have the potential to leach from the soil to the water table. In terms of the unsaturated zone modeling, SESOIL is being used to look at cleanup numbers. Dr. Dahmani suggested that because of the limitations of the model, it could only look at worst-case scenarios. Mr. Clausen agreed that there is some uncertainty.

Mr. Mullennix asked if itís correct that the DNTs, NG, and TNT naturally biodegrade in the environment, and therefore high levels of those constituents arenít seen. Mr. Clausen replied that this is correct.

Mr. Cambareri inquired about the next step for the IAGWSP in terms of looking at dissolution rates, and whether something "more quantitative" would be done. Mr. Clausen replied that there is no specific plan for the IAGWSP to undertake another study at this time. He also noted, however, that the Water Ways Experiment Station, which is run by the USACE, recently issued reports on studies that looked at different parameters that affect dissolution rates, including temperature, particle size, and other variables. The IAGWSP will be reviewing those reports in detail and working that information into the conceptual site model.

Mr. Cambareri also asked whether particulate-facilitated transport was considered. Mr. Clausen replied that it was not, and noted that he hasnít seen anything about facilitated transport of explosives in the literature. Mr. Cambareri said that he thinks this is something to explore.

Ms. Crocker inquired about the implications of the study results in terms of the cleanup process. Mr. Clausen replied that now, rather than relying on the literature, actual site data can be put into the model, thereby providing greater confidence that the model is representative of site conditions at Camp Edwards.

Dr. Stahl suggested that movement of particulates through the soil would depend on the pore volume, pore space, and the size of the particle. Mr. Cambareri mentioned the micro-sphere study conducted in a plume in the southern part of the base, where injected micro-spheres of particulates were shown to travel "quite well" through the pore spaces of the aquifer. Dr. Stahl said that whether or not migration occurs would depend on the particle size. Mr. Cambareri replied that with an explosive, it would depend on the particulate size thatís generated whether it would move through the soil. Dr. Stahl noted that a micro-sphere has a significant boundary layer to hold it together, whereas an explosive particulate probably would "dissolve quicker than it would be traveling." Mr. Cambareri said that he thinks it would depend on the size of the particle.

Dr. Stahl said that itís unlikely that the soil samples used in the experiments were exposed to significant levels of explosives. He then asked if the study looked at adaptation of the microbes to the explosives, or at any co-metabolism type of events. Mr. Clausen replied that it had not, and added, "These were just quick and dirty experiments to see whether or not degradation was occurring."

Dr. Stahl then commented that the fate and transport study report included a striking graph pertaining to the column studies, which showed "the condition or the concentration of the plume going back to basically zero" after flushing. He said that it would be good to include that graph in the presentation because it helps explain the concept of soil adsorption. Dr. Stahl also inquired about the preparation of the water used in the column experiments. Mr. Clausen replied that uncontaminated water from Camp Edwards was pumped through columns containing MMR site soil and RDX from an Army ammunition plant. He said that the water may not have been exactly the same as whatís at the site, but that is how the experiments were conducted.

Agenda Item #6. Agenda Planning and Review Action Items

Mr. Murphy said that due to the late hour, he would forego the review of tonightís action items. He also noted that an orientation schedule for new IART members is being developed. Mr. Murphy then said that earlier heíd neglected to ask LTC Cunha and Mr. Cambareri to describe their roles on the team, and would ask them to do so at the next meeting. He also introduced Susan Studlien, acting director of EPAís Office of Site Remediation and Restoration, whom he had forgotten to introduce earlier in the meeting.

LTC Cunha commented that not all good ideas should become action items, as they are costly in terms of dollars, time, and resources, which are taken away from other projects. He said that he thinks there needs to be a system for determining what should become an action item. He noted, for example, that the same action items pertaining to Snake Pond are discussed every spring, and yet the responses are never accepted. LTC Cunha suggested that it might make sense to add to a future IART meeting agenda the topic of how to determine action items. Mr. Murphy acknowledged LTC Cunhaís recommendation, but also noted that action items captured at IART meetings are reviewed by the project managers, who determine whether they should be addressed in some way. He also mentioned that additional copies of the fate and transport study report are available. Ms. Crocker suggested that coming to consensus in terms of what are appropriate action items could save time, money, and repetition.

Agenda Item #7: Adjourn

Mr. Murphy announced that the IART would meet next on May 27, 2003 at Christ the King Church in Mashpee. He then adjourned the meeting at 9:12 p.m.

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