Impact Area Review Team

River River Drops of rain on a leaf

Impact Area Review Team
Falmouth Holiday Inn
December 9, 2003
6:00 - 9:00 p.m.

Meeting Minutes

Members: Organization: Telephone: E-Mail:
Hap Gonser IAGWSP 508-968-5107 Kent.gonser@ma.ngb.army.mil
Ben Gregson IAGWSP 508-968-5821 Ben.gregson@ma.ngb.army.mil
Marty Aker AFCEE/MMR 508-968-4670 Marty.aker@mmr.brooks.af.mil
Todd Borci US EPA 617-918-1358 Borci.todd@epa.gov
Margery Adams US EPA 617-918-1733 Adams.margery@epa.gov
Bill Walsh-Rogalski US EPA 617-918-1035  
Len Pinaud MA DEP 508-946-2871 Leonard.pinaud@state.ma.us
Ellie Grillo MA DEP 508-546-2866 Ellie.grillo@state.ma.us
Amine Dahmani UConn/TOSC 860-486-2781 adahmani@eri.uconn.edu
Tom Cambareri IART/CCC 508-362-3828  
Peter Schlesinger IART/Sandwich 508-888-0262 Pschles@adelphia.net
Richard Hugus IART/ABC/Falmouth 508-540-6034 Rhugus@cape.com
Janet Pepin IART/Falmouth 508-548-8182  
Michael Butler IART/Bourne 508-564-6972 Michael.butler9@verizon.net
Bob Mullennix IART/Bourne 508-759-8319 Robert.mullennix@verizon.net
Judy Conron IART/Bourne 508-759-1559 Conron@gis.net
Dick Judge IART/At Large    
 
Facilitator: Organization: Telephone: E-Mail:
Meghan Cassidy (sitting in for Jim Murphy) US EPA 617-918-1387 Cassidy.meghan@epa.gov
 
Attendees: Organization: Telephone: E-Mail:
John McDonagh IAGWSP 508-968-5636 John.mcdonagh@ma.ngb.army.mil
Kris Curley IAGWSP 508-968-5626 Kristina.curley@ma.ngb.army.mil
Pamela Richardson IAGWSP 508-968-5630 Pamela.richardson@ma.ngb.army.mil
Lori Boghdan IAWGSP 508-968-5635 Lori.boghdan@ma.ngb.army.mil
Paul Nixon IAGWSP    
Mike Minior AFCEE/MMR 508-968-4670  
Bill Sullivan E&RC 508-968-5147  
Bob Lim US EPA 617-918-1392  
Dave Williams MDPH/EPHC 781-774-6612 dave.williams@state.ma.us
Kevin Hood UConn/TOSC 860-486-2546  
David Dow Sierra Club 508-540-7142  
Martin Greene Bourne firefighter 508-759-9178 Martyg7936@aol.com
Edward Steinberg 508-563-7747 stingered@verizon.net
Pat Skelly Citizen 508-524-3948 patskelly@earthlink.net
Rick Carr STL 781-455-0653 rcarr@stl-inc.com
Bob Paine ECC 508-279-2870  
Jim Quin Ellis Environmental Group 720-963-9346 James.quin@ellisenv.com
Jane Moran Portage Environmental 508-759-9114 Jmoran@portageenv.com

Action Items:

  1. EPA requested that the IAGWSP assemble any available literature pertaining to the potential for perchlorate to bio-accumulate.
  2. Mr. Cambareri recommended that groundwater recharge areas to bogs be added to the cranberry bog map.
  3. Mr. Murphy will coordinate with TOSC members to poll IART members regarding potential topics for educational presentations at future meetings.
  4. Mr. Schlesinger asked for an updated team membership list.
  5. Mr. Pinaud recommended that representatives from either the Natural Heritage and Endangered Species Program, or other experts in this field who work for the Guard, be invited to a future IART meeting to discuss the issue of threatened species at the Central Impact Area.
  6. In response to Mr. Butler's request, Mr. Pinaud agreed to provide information on the Noman's Island cleanup, which is being addressed by DEP's Boston office.
  7. Mr. Schlesinger asked for a cost calculation for providing treated water to the town of Bourne versus the cost of cleaning up the Central Impact Area.
  8. Dr. Dahmani asked for the planned retention time to treat RDX in the thermal desorption process.
  9. Mr. Pinaud agreed to provide information regarding DEP emissions standards associated with thermal desorption technology.
  10. Mr. Borci asked to be provided with copies of any written correspondence reflecting the IAGWSP's recommendation to provide a town water hookup for the Foretop Road residence in Bourne.

Future Agenda Items:

  • Massachusetts Department of Public Health Update
  • Gun and Mortar Firing Positions Workplan
  • Zones of Contribution
  • Mass Flux Approach to Assessing Potential Threat to Snake Pond

Handouts Distributed at Meeting:

  1. Responses to Action Items from the October 28, 2003 IART Meeting
  2. Map: Cranberry Bogs in the Vicinity of the Massachusetts Military Reservation
  3. Presentation handout: Rapid Response Action Plan for Central Impact Area Soil
  4. IAGWSP fact sheet: Central Impact Area
  5. Presentation handout: Remediation & Investigation Update
  6. Data tables
  7. UXO Discoveries/Dispositions Since 10/28/03 IART (Ending 12/3/03)
  8. News Releases, Neighborhood Notices and Media Coverage - 10/29/03 - 12/5/03

Agenda Item #1. Welcome, Review Agenda, Approval of October 28, 2003 IART Minutes

Ms. Cassidy, who was filling in for Jim Murphy, convened the meeting at 6:07 p.m. and the Impact Area Review Team (IART) members introduced themselves. Ms. Cassidy reviewed the agenda, and then asked if there were any changes or additions to the October 28, 2003 IART meeting minutes. No changes were offered and the minutes were approved as written.

Agenda Item #2. Late-Breaking News and Responses to Action Items

Ms. Cassidy confirmed that there was no late-breaking news to report, and asked if there were any comments on responses to action items from the October 28, 2003 IART meeting. Ms. Conron said that she'd expected the Impact Area Groundwater Study Program (IAGWSP) to provide a more detailed budget than the one attached to the Responses to Action Items document.

Mr. Gonser said that one reason for this is that only a limited amount of detail could be shown because the work hasn't been contracted yet. He also noted that the numbers themselves are general numbers that show the IAGWSP's priorities, which are Demolition Area 1 (Demo 1), the Southeast Ranges, the Central Impact Area, and a group of other sites. As the year progresses and more information becomes available, the IART's input would be sought with respect to moving monies around to priority projects. Mr. Schlesinger asked if it's correct that the IAGWSP can re-budget as needed. Mr. Gonser confirmed that there's some flexibility to move money among the projects. The budget that was presented is an estimate, which is expected to change as investigations move forward and the regulators and citizens provide their input. He also noted that some of last year's money, which wasn't needed for other programs, is being used to pay for the Central Impact Area Rapid Response Action (RRA) and the J-2 and J-3 Range RRAs.

Agenda Item #3. Open Discussion

Cranberry Bog Locations Surrounding MMR

Mr. Gregson said that "Cranberry Bogs in the Vicinity of the Massachusetts Military Reservation" map was provided in response to an IART member's request. He noted that the map shows active bogs, inactive and unknown status bogs, plume information, and distance lines around the Massachusetts Military Reservation (MMR) at one mile, two miles, and three miles.

Mr. Judge said that he's concerned about the potential for cranberry bogs near MMR to be tainted by perchlorate in the water system, including water used during routine flooding of the bogs. He indicated that he knows of perchlorate being found in leafy vegetables and in cow's milk. He also said that despite assurances that it wouldn't happen, ethylene dibromide (EDB) contamination from the base was detected in town cranberry bogs, and he wants to be certain that any perchlorate issues pertaining to the bogs are addressed beforehand. Mr. Judge also asked the U.S. Environmental Protection Agency (EPA) about the possibility of conducting a study (similar to a past EDB study) that looks at whether perchlorate can penetrate the skin of cranberries, and determines perchlorate levels in water that would warrant the shutdown of a bog.

Mr. Borci stated that the testing to which Mr. Judge referred was conducted when EDB plumes were upwelling into cranberry bogs, and tonight's cranberry map is the proactive step to see if perchlorate contamination in the bogs is a possibility. From the standpoint of health, crops, and environmental protection issues, the effort to determine what exists downgradient of each plume and single detection is ongoing, and if the need arises, a risk assessment would be conducted.

Mr. Judge stated that information on the map foreshadows what could happen in terms of perchlorate contamination getting into the bogs. He said that, unlike what happened with the EDB contamination, he thinks there should be readily available answers to questions that might arise if that situation were to occur. He then repeated his request that EPA conduct perchlorate testing on cranberries in order to be prepared ahead of time for potential future problems at the bogs. Mr. Schlesinger added that he'd like both EPA and the Massachusetts Department of Public Health (MDPH) to investigate whether perchlorate can bio-accumulate in cranberries. Ms. Cassidy noted that the MDPH representative at this meeting could convey this request to his office.

Mr. Hugus noted that while the map shows no contact between the Fuel Spill 28 (FS-28) plume and the downgradient bog, that plume definitely contributed to EDB contamination to that bog. He also noted that the perchlorate contamination detected in the Monument Beach wellfield in Bourne is not depicted on the cranberry map. Mr. Hugus then stated that he too thinks that a study of perchlorate's ability to contaminate cranberries is important.

Mr. Borci requested that the IAGWSP pull together the available literature on bioaccumulation for perchlorate. Mr. Gregson agreed to do so.

Ms. Pepin questioned whether there's an active cranberry bog on the northern shore of Snake Pond. Mr. Gregson replied that there is not. Mr. Cambareri suggested that the map would be more useful if it included the groundwater recharge areas to the cranberry bogs. Mr. Dow recommended that consideration be given to whether nitrates and phosphates, which are used to fertilizer cranberries, would have an effect on the potential uptake of perchlorate in cranberries.

IART Process Check-in/Groundrules

Ms. Cassidy noted that yesterday Mr. Murphy sent out an e-mail stating that Mr. Judge will be staying on as an active IART member, in an at-large capacity. She also said that EPA will be seeking additional IART members from Sandwich, and that the agency has decided to "grandfather" current members in terms of their residency and consider the situation should it arise with new members.

Mr. Judge said that he had received phone calls from EPA "expressing their dismay" about the impression left by the controversy over his continued membership on the team. He said that he accepted EPA's sentiments, but with one request - that EPA recognize the efforts of the volunteer citizen IART members, perhaps by awarding each member a plaque to acknowledge his or her work on the team. Mr. Judge noted that he also requested that EPA issue a news release about the work of the citizen team members. He said that EPA was receptive to his requests and he is thankful for that. Ms. Cassidy noted that Bob Varney of EPA contacted Mr. Murphy about acknowledging citizen team members, and Mr. Murphy will be addressing that issue soon.

Ms. Pepin asked what prompted the discussion about Mr. Judge's membership, especially given that in the past an individual moved to another state and remained a team member for quite some time thereafter. Ms. Cassidy indicated that while Mr. Murphy could provide a more complete answer, it's her understanding that Mr. Judge contacted Mr. Murphy early in the summer to explain that he was relocating. Some internal discussion followed with regard to that situation and whether there would be a transition period. Ms. Cassidy then asked if Mr. Judge wanted to comment. Mr. Judge declined to comment, but did confirm that he had contacted EPA to inform the agency of his change of address. Ms. Pepin explained that she wants to know if the situation would be repeated if another team member relocates. Ms. Cassidy reiterated that EPA has decided to "grandfather" current team members; therefore, it would be acceptable for current members to continue active participation with the group should their residency change.

Ms. Grillo stated that the Massachusetts Department of Environmental Protection (DEP) is very pleased with EPA's decision. She also asked whether Mr. Murphy's e-mail had been sent to the entire team. Ms. Cassidy replied that it had. Mr. Judge asked Ms. Cassidy to read Mr. Murphy's message for the record. Ms. Cassidy read, "Greetings to all. This is to let you know that I will not be able to attend the IART meeting tomorrow evening due to a family related health matter. Meghan Cassidy, EPA's MMR team leader, will facilitate the meeting in my absence. I did want to inform team members that the issue of Dick Judge's membership on the team has been resolved and that Dick will continue to serve as a dedicated and valued team member. Thank you for your strong expression of support for Dick. Happy Holidays to you and your families. Jim."

Mr. Hugus said that he's glad Mr. Judge will be staying on as an IART member. He also suggested that EPA's acknowledgement of citizen team members include Dick Prince and Joel Feigenbaum, two members who have passed away, as well as Paul Zanis, a former member who had a great deal of firsthand knowledge about the military's activities on Camp Edwards. Mr. Hugus stated that Mr. Zanis's decision to move away from the area in part had to do with an unannounced "National Guard raid on his house" to look for ordnance and weaponry, an event that he thinks was related to Mr. Zanis's work on the IART.

Mr. Judge stated that following the controversy over his continued membership on the IART, someone informed him that Lt. Col. Epright of Air Force Space Command, a spokesman for the PAVE PAWS facility, had said that he (Mr. Judge) "was being kicked off all kinds of boards." Mr. Judge said that he intends to write a letter to Lt. Col. Epright regarding that remark, and thought it appropriate to mention this situation tonight so it would go on the record.

Mr. Schlesinger noted that he's very pleased with the efforts put forth by the IART's Total Outreach Services for Communities (TOSC) representatives. He further noted, however, that he'd like the TOSC representatives to provide brief technical training sessions, during IART meetings, to help the citizens become better, more educated team members.

Mr. Judge said that he thinks it's a great idea to have training sessions at IART meetings because doing so would ultimately save time at future meetings. Mr. Hugus noted that Ms. Conron (who had to leave the meeting early to attend a public hearing on the Bourne landfill) asked him to relate to the team that she agrees with Mr. Schlesinger's recommendation. He also said that the team should ask the TOSC advisers if they are interested in making a presentation so time could be set aside on a future agenda.

Mr. Mullennix said that, as a point of order, the IART groundrules state that each member shall express his or her own views rather than speaking for others at the table. Ms. Cassidy acknowledged Mr. Mullennix's comment and noted that she saw Ms. Conron ask Mr. Hugus to pass along that information to the team.

Dr. Dahmani, a TOSC adviser, said that he believes that making short presentations to the IART would help team members understand technical issues and thereby improve the overall process. He also said that active IART members like Mr. Judge play an important role in representing the community at large, and educating the team would help in understanding environmental problems and solutions, both of which are complicated. Dr. Dahmani said that if EPA and the IART make the request, he thinks that the TOSC advisers could provide 15- to 20-minute training sessions, to be followed by a question-and-answer period.

Ms. Grillo said that she thinks TOSC presentations are a good idea, and questioned whether there are specific topics of interest to the team. Mr. Judge suggested that the TOSC advisers poll team members on topic ideas so that the process can begin within the next couple IART meetings. Mr. Borci said that he would ask Mr. Murphy to coordinate with the TOSC advisers to ensure that all team members are polled so that a presentation can be made at a near future meeting.

Mr. Schlesinger noted he'd be interested in having the TOSC advisers cover the basic topic of acronyms and terminology (for example, "thermal desorption") used throughout the program. Dr. Dahmani said that he would circulate a list of possible topics. He also mentioned that team members outside of the TOSC could make educational presentations as well - for example, the regulators could educate the team on the process and how they interact with the military. Ms. Cassidy noted that Mr. Murphy would coordinate with the TOSC advisers to poll team members on possible topics, after which the project managers would schedule appropriate presentations into future agendas.

Ms. Cassidy also said that comments on the IART groundrules, which were recently sent out to team members as a reminder, can be sent to Mr. Murphy. Ms. Pepin noted that she's glad to see that a mission statement was added to the groundrules. Ms. Grillo questioned whether the groundrules would be updated to address the residency issue for new members. Ms. Cassidy said that she doesn't anticipate that the groundrules would be updated in this way. She also reiterated that EPA plans to recruit more members from Sandwich.

Mr. Schlesinger said that he'd like to have a list of IART members and their current status, whether active or inactive. Ms. Cassidy replied that she'd ask Mr. Murphy to see to it that such a list is provided to the team.

Agenda Item #4. Rapid Response Actions for Central Impact Area Soil

Mr. Gregson showed an aerial photograph of the Central Impact Area and stated that tonight begins the informal public comment period on the Central Impact Area RRA for soil. He noted that the contaminants of concern (COC) in Central Impact area soil are RDX, HMX, PETN, perchlorate, TNT, and TNT breakdown products 2A-DNT and 4A-DNT. The COCs in Central Impact Area groundwater are RDX, 4A-DNT, HMX, and perchlorate, and it's assumed that the soil contamination is the cause of the groundwater contamination. Mr. Gregson said that the RRA is intended to remove soil contaminants, thereby removing the source of contaminant leaching to the groundwater. If the RRA is successful at the two selected target areas, this type of remediation could be done at other targets in the Central Impact Area.

Mr. Gregson showed photographs of the two targets: Target 23, an old boiler located on the south side of Tank Alley, which runs east/west from the center of the Impact Area out toward the J-1 Range; and Target 42, an old tank located on the east side of Turpentine Road, which runs north/south through the center of the Impact Area. He noted that a workplan for the focused investigation of these target areas was submitted in June 2003 and approved by the regulators. That work is ongoing and is expected to provide valuable information as the RRA soil removal is being finalized.

Mr. Gregson stated that the focused investigation includes soil sampling, with the primary purpose of determining whether contaminant concentrations decrease with greater distance from the center target location. He noted that wipe samples would be taken from unexploded ordnance (UXO) that are discovered, and perchlorate testing would be done on soils near any LITR rounds (low-intensity training rounds) that are discovered. The focused investigation also includes UXO surveys to determine whether there are any rounds that have broken open, thereby exposing explosive filler to the environment and causing a more concentrated source of contamination leaching to groundwater. In addition, the focused investigation includes the installation of lysimeters, which are a device used to collect rainwater as it infiltrates through the soil. That water will be tested to see whether explosive contamination is leaching through the soil. Mr. Gregson noted that the lysimeters will be kept in place after completion of the RRA in order to see whether there's a decrease in contaminant concentrations as they move through the soil.

Mr. Gregson then displayed a figure depicting the Impact Area and pointed out the air magnetometer data, the soil sampling grids, Turpentine Road, Tank Alley, the RDX plume, the purple boundary line that designates the Central Impact Area soil operable unit, Target 23, and Target 42. Mr. Borci asked Mr. Gregson to mention the size of the soil operable unit as compared to the entire Impact Area. Mr. Gregson replied that the Impact Area itself encompasses about 2,200 acres, while the operable unit boundary encompasses about 340 acres. He also noted that Targets 23 and 42 were selected because they are somewhat isolated from other targets and because relatively high levels of RDX and other COCs were detected there.

Mr. Hugus remarked that the vegetative growth seen in the aerial photograph at the beginning of Mr. Gregson's presentation indicates to him that the damage being done to Camp Edwards has been stopped as a result of the ongoing study. He said that when the study began about seven years ago, that area looked "sort of like a moonscape." He then stated that Target 23, the boiler, appears to be intact, as though it were never hit. Mr. Gregson assured him that the boiler appears in better condition in the photograph than it does in reality.

Mr. Hugus then asked whether the only soil work the IAGWSP plans to do at the Impact Area is within the operable unit designated by the purple boundary line shown on the map. Mr. Gregson replied that the current focus on this area is based on air magnetometry (air mag) data, soil sampling, aerial photography that revealed a high density of cratering there, and the groundwater plumes that point back to it. This does not mean, however, that nothing will ever be found outside of that boundary line.

Mr. Hugus also asked if it isn't correct that the most "serious target area" exists "right down Turpentine Road, south of Five Corners." Mr. Gregson replied that that is one of them, but then pointed to locations along Tank Alley and Turpentine Road and mentioned a SCAR (sub-caliber aerial rocket) range. He said that the area where the High-Use Target Area (HUTA) investigation was conducted was thought to be one of the most used areas and everything that's been done since then has supported that conclusion.

Mr. Hugus commented that while the operable unit looks manageable on the map, it's going to be very difficult to deal with the huge number of potential source areas there, given how much land actually is involved. Mr. Gregson agreed that there are many considerations to take into account in terms of cleaning up 340 acres of land, and the focused work at the two target areas should provide helpful information in that regard. He also mentioned the concern that land at the Central Impact Area is considered some of the most valuable habitat for state-threatened species. He added that the IAGWSP believes that the feasibility study process, conducted in a public forum, is the best way to carefully consider each concern while looking at the cleanup alternatives.

Mr. Schlesinger mentioned a pattern of air mag data on the map and asked if it was a function of the processing or if it represents actual magnetic debris. Mr. Gregson noted that there's a grain to the anomalies going from northwest to southeast, which was the direction of the air mag flights. He said that the pattern Mr. Schlesinger mentioned might be the result of processing or it might be real magnetic anomalies. Mr. Borci clarified that field investigation in that area showed nothing unique, and so it's thought that the resulting pattern was the function of a particular flight where an instrument might have been left on or off, or some setting was wrong. He also pointed out the pattern along the western edge of the Impact Area where the helicopter turned around.

Mr. Schlesinger then noted that the map in the Central Impact Area fact sheet shows only Targets 23 and 42, which he believes could lead the public to come to an inaccurate conclusion. Mr. Gregson explained that the fact sheet focuses on the two targets that will be cleaned up as part of the RRA. However, the fact sheet does indicate that these are only two of a number of target areas in the Central Impact Area.

Mr. Judge called for the military to secure funding immediately to move any endangered species away from the Central Impact Area so that remediation work there can begin as soon as possible. He said that he doesn't want to see the military use the habitat there as an excuse for delays. He also said that a local resident told him of the past practice of bringing propellant bags from guns on Navy ships to the Impact Area, stacking them into huge piles, and lighting them on fire. Mr. Judge noted that this means that there could be highly-contaminated areas that couldn't be identified by magnetometer, but which might lack vegetative growth. Mr. Gregson questioned whether the individual Mr. Judge mentioned might be willing to be interviewed. Mr. Judge replied that he doesn't think so, as that individual is the one whose house "was raided," but he is willing to call him to see if he can roughly identify the location where bag burning occurred. Mr. Judge then said that other people are also aware of the bag burning, but he believes that there should be an increased effort to find the missing records that document activities such as disposal and propellant bag burning that occurred on the base.

Mr. Butler said that he thinks that the state-listed species are secondary to the need for cleanup at the Central Impact Area.

Dr. Dahmani inquired about the purpose behind installing lysimeters. Mr. Gregson replied that RDX has been measured in shallow soil and in groundwater, but there've been a lot of nondetects in between. The lysimeters will be used to see if RDX can be detected in pore water samples, rather than bulk soil samples, and it's also hoped that they'll provide the opportunity to determine any change in concentrations before and after the cleanup action. He also noted that the depth of the lysimeters would be three feet, five feet, and nine feet, and the depths and locations are included in the focused investigation workplan.

Mr. Gregson stated that the first step in the Central Impact Area RRA is clearance of munitions and related items. This will be followed by excavation of soil at a two-foot depth and a 50-foot radius around the target areas, which is based on earlier excavation work at Mortar Target 9 and the armored personnel carrier in the Impact Area. The extent of excavation will be fine tuned according to information that comes out of the focused investigation, but the current estimate is for approximately 600 cubic yards of soil to be removed from each target area. The excavated soil will either be treated on site at the thermal desorption unit, or removed to an off-site disposal facility if the unit is no longer at the base or if the soil is deemed unsuitable for thermal desorption treatment. Post-excavation sampling will be conducted and the lysimeters will continue to be monitored in order to assess the effectiveness of the RRA and whether this type of focused soil removal should be done at other targets in the Impact Area.

Mr. Gregson stated that the public comment period runs through December 24, 2003, and comments can be submitted via the web site or by contacting Bill Gallagher by telephone or e-mail. He also noted that the RRA plan is being finalized while the focused investigation, which is expected to be completed by spring 2004, is being conducted. Once the investigation is completed, soil removal work will begin.

Mr. Schlesinger expressed concern about the depth of excavation. Mr. Gregson replied that excavation work at Mortar Target 9 and the armored personnel carrier, and sampling at the HUTA, indicates that most of the contamination exists in the first foot of soil. He also explained that the purpose of the excavation is to remove the higher-concentration particulate material that remains in the soil around the targets, not the dissolved contaminants working their way into the groundwater. Mr. Schlesinger said that the estimated excavation depth at the target areas is based on sites where contaminant concentrations were lower. Mr. Gregson clarified that in fact higher concentrations had existed at Mortar Target 9. He also noted that deeper soil samples, up to about 10 feet, will be collected as part of the focused investigation to help guide the RRA soil removal, and if necessary, the excavation could go deeper.

Mr. Pinaud recommended that prior to the start of the Central Impact Area feasibility study process, the IAGWSP arrange for Natural Heritage and Endangered Species Program experts, and similar experts who work for the Army the National Guard Bureau, to come to a future IART meeting to discuss issues relating to the state-listed species at the Central Impact Area. Mr. Gregson replied that he thinks this is a good idea.

Mr. Walsh-Rogalski questioned whether future soil work at the Central Impact Area would be done two target areas at a time or in larger groupings. Mr. Gonser explained that the IAGWSP had money available from last year to pursue the work at the two initial target areas, which should provide a good test for conducting future work. He said that he anticipates undertaking "a bigger package next time," once the IAGWSP learns what it can from the two sites.

Mr. Hugus inquired about the percentage of total contaminated soil in the Impact Area represented by the soil at Targets 22 and 43. Mr. Gregson replied that he doesn't know, but it's a small percentage. Mr. Hugus commented that the total amount of contaminated soil is "boggling" and inquired about the acreage contained in the 50-foot radius around Target 23, for example. Mr. Gregson replied that the 50-foot radius encompasses 7,500 square feet, or about 1/6 of an acre. He described the soil removal work at the targets as "a hotspot removal type activity." Mr. Hugus said that he thinks some sort of comprehensive plan is needed to deal with the contaminated soil at the target areas, and asked whether the entire 50-foot radius would be excavated. Mr. Gregson replied that information from the focused investigation would guide the actual extent of excavation. He also said that what is learned from the RRAs should answer some questions as the feasibility study process moves forward and the ultimate cleanup remedy for the entire Central Impact Area is determined.

Mr. Hugus said that he doesn't think the soil work should necessarily be limited to the 340-acre operable unit, since the entire 2,200 acres is a potential operable unit. He also said that he thinks that efforts to address the Central Impact Area groundwater plume should be moving forward simultaneously with the soil work.

Mr. Judge agreed with Mr. Hugus's final remark. He also noted that the Central Impact Area fact sheet states that "work in the Central Impact Area will also help determine future cleanup activities in the Central Impact Area," and asked whether the statement should have referred to the Impact Area as a whole. Mr. Gonser explained that the statement has to do with work at the two target areas providing information that's relevant to cleanup of the Central Impact Area; however, anything that is learned from the work at the target areas will be helpful in cleaning up the entire Impact Area or any other area that requires cleanup.

Mr. Judge then expressed concern about setting precedent with respect to limited excavation depths. He said that he thinks it's important to be flexible, given the various contaminants and contaminant concentrations throughout the Impact Area. Mr. Gonser agreed.

Dr. Dahmani asked whether the plan is to conduct soil sampling during the excavation work and then excavate deeper as needed. Mr. Gregson replied that the IAGWSP will work with the regulators to establish a cleanup goal for the Central Impact Area, and, based on soil sampling, will continue excavation until that goal is reached. Dr. Dahmani then inquired about the establishment of soil cleanup levels for RRAs. Mr. Pinaud said that this is a rather complicated issue, and noted that cleanup standards were negotiated for excavation work at Demo 1, but not yet for the RRA at the Central Impact Area. He also mentioned that in spring 2004 DEP will be promulgating cleanup standards for explosives and propellants, but state standards don't exist currently. Mr. Borci noted that EPA had commented that some type of cleanup level was needed, and had recommended 120 ppb for RDX and 250 for TNT, which are the same levels used for previous RRAs. He also explained that while no specific level is listed for perchlorate, it's believed that by cleaning up to those specified levels for RDX and TNT, perchlorate would be cleaned up to nondetect, and if not, that would be discussed.

Mr. Butler recommended conducting research into excavation depths at cleanup sites where the U.S. Fish and Wildlife Service (USFWS) was involved, at Noman's Island, Fort Devens, and Fort Meade. Mr. Gonser agreed to look into obtaining that information, but also noted that those sites involved UXO removal as opposed to soil removal. Mr. Pinaud added that he could provide information on the Noman's Island cleanup, which is being handled out of DEP's Boston office.

Mr. Borci noted that groundwater protection is a key issue at MMR sites, which might not be the case at the sites Mr. Butler had mentioned. He also reminded the group that once the particulate that's distributed over the surface comes into contact with rainwater, it goes into solution and no longer has an affinity for soil. It passes through the soil column without leaving any trace that can be detected using the current methods, and this is why the cleanup work is a combination of a soil remedy and a groundwater remedy.

Mr. Schlesinger noted that the fiscal year 2004 (FY'04) budget includes $10.3 million programmed for cleanup work in the Central Impact Area. He then said that he'd like to see a cost calculation for providing treated water to the town of Bourne over the next 75 years versus the cost of cleaning up the Central Impact Area.

Mr. Judge referred to Mr. Borci's remarks about contaminants passing through the soil, and noted that he's concerned about buried items that could be a source of future groundwater contamination. Mr. Borci explained that he had been talking about the chemical compounds issue only, not the UXO issue. He also said that UXO, which can be viewed as an additional contaminant, will be addressed in the feasibility studies. He noted that the Munitions Survey Project work that occurred in the Impact Area was done to inform that part of the study. Mr. Gregson added that the HUTA investigation showed that, like contaminants, UXO are generally found within the first couple of feet of soil. Mr. Judge replied, "Unless they were previously buried," and Mr. Gregson acknowledged that possibility.

Mr. Skelly, a citizen of Bourne, said that he thinks that to "do your strip clean, and then do your tests and go further as you need," is a rational approach to conducting the soil excavation work at the Central Impact Area.

Mr. Hugus stated that even if it were possible to do so, he doesn't think that resources should be put into calculating the cost to treat Bourne's water for 75 years versus the cost to clean up the Central Impact Area. Rather, he believes the priority should be to determine the most intelligent way to address the "vast" contamination problem there, and do the cleanup.

Mr. Judge agreed that a good system is needed to treat contamination at the Central Impact Area. He also mentioned that there had been resistance to using the contained detonation chamber at the base because it would set a precedent. Mr. Judge said that he thinks that use of a portable system, such as the thermal desorption unit, should begin soon. He added that he doesn't care about setting precedent, but does care about getting the area remediated as quickly as possible.

Mr. Cambareri stated that he agrees that the purpose of the IAGWSP should be to clean up the MMR, which, through legislation, has been recognized as the Upper Cape Water Supply Reserve for the future. He said that he also agrees that there should be a logical way to go about achieving cleanup of the Central Impact Area. He then noted that he attended a conference on training ranges at the University of Massachusetts and saw a researcher's presentation on fate and transport. Mr. Cambareri said that he'd like to see a fate and transport presentation at the IART by that level of researcher, who's doing work nationally, given that this is a very complicated issue and the IART is going to need all the information it can get.

Agenda Item #5. Remediation and Investigation Update

Demolition Area 1

Mr. Nixon stated that the anomaly clearance phase of the Demo 1 RRA for soil is almost complete and full-scale excavation should be starting fairly soon. He noted that anomaly clearance was shut down over the weekend because of the snowstorm, but is expected to resume tomorrow.

Mr. Nixon reported that for the purpose of soil excavation, each of the 100' x 100' grids designated at Demo 1 for anomaly clearance is being broken down into quadrants known as northeast, northwest, southeast, and southwest. On November 21, 2003 excavation at two "test patch" areas began in order to ensure that all quality control procedures were in place and effective. He noted that before and after shots taken at the 1-foot excavation area through the outer perimeter of Demo 1 showed that an exact 1-foot excavation was achieved, which was "quite a success." Mr. Nixon also mentioned that, as discussed in detail at previous meetings, the excavated soil will be screened, treated in the thermal desorption unit, and returned to Demo 1.

Mr. Nixon noted that he had some unvalidated test results from the perchlorate treatability study being conducted at a laboratory in Colorado. For test runs using soil with perchlorate concentrations of 100 parts per million (ppm), at a temperature of 650 F, and with a 10-minute retention time, 99.9% destruction of perchlorate was achieved. Test runs using soil with perchlorate concentrations of 100 ppb are ongoing. The first 100-ppb runs, which used a higher temperature, showed that perchlorate was destroyed to below-detectable levels. Results from 100-ppb runs using the lower temperature of 650 F are not yet available, but should be in by the end of the week.

Mr. Nixon also reported that a period-of-performance test would be done using the most contaminated soil that can be found at Demo 1. The soil would be tested before and after being run through the thermal desorption unit in order to prove that the system works and that the emissions are within DEP criteria. He noted that DEP is currently working on the IAGWSP's permit application package, which will be in place prior to treatment of soils.

Mr. Schlesinger inquired about the volume of the soil sample tested at 650 F with a 10-minute retention time. Mr. Nixon replied that the sample volume was fairly small, given that only two 5-gallon buckets were sent to the lab and only a portion of it has been used to date. Mr. Schlesinger asked if it's correct that the 100-ppm soil was tested at 650 F with a 10-minute retention time. Mr. Nixon confirmed that this is correct. Mr. Schlesinger then asked whether the retention time would be scaled down for the 100-ppb soil. Mr. Nixon said that he believes the retention times are all at 10 minutes, and added that the variable on the lower-concentration tests is temperature - a 650 F run, a 900 F run, and a 1,150 F run. He noted that the two higher-temperature runs both showed perchlorate destroyed to below detectable levels. Mr. Nixon further noted that a lab report with all results and conclusions should be available in about two weeks.

Mr. Schlesinger expressed concern about the amount of time it would take to process the Demo 1 soil, given the 10-minute retention time. Mr. Nixon explained that while the kiln in the laboratory is very small, the thermal desorption unit in the field has an enormous iron rotating drum that's roughly 20 feet long and 10 feet tall. Mr. Schlesinger asked how much soil the drum would hold at one time. Mr. Nixon explained that there would be a continuous feed of soil into the drum. He also noted that the period-of-performance testing would confirm the temperature and retention time required to clean the soil to below acceptable levels.

Ms. Pepin requested that the IAGWSP provide the IART members with the treatability study results when they become available. Mr. Nixon replied that the lab report, which he believes is expected on December 18, 2003, will summarize all the data and conclusions, including the data that he discussed tonight.

Dr. Dahmani inquired about the retention time for RDX. Mr. Nixon replied that he doesn't know, and noted that RDX was not a subject of the treatability study, and the lab samples, which came from locations on the base, didn't contain RDX. He also noted that the same thermal desorption system has successfully treated RDX-contaminated soil at other sites, including the Kansas City Army Ammunitions Plant. Dr. Dahmani asked whether the Demo 1 soil would have to be heated for a longer time period because of the perchlorate. Mr. Nixon replied no, and said that it looks like the perchlorate is not going to be a problem. Dr. Dahmani also asked whether the lab samples had to be spiked. Mr. Nixon replied that they did, and noted that it hadn't been possible to find samples that contained even 100 ppb of perchlorate for the low-concentration runs.

Dr. Dahmani then inquired about the timeframe for startup of the thermal desorption unit. Mr. Nixon replied that because UXO clearance has taken longer than expected, the projected startup date has moved from January 6, 2004 to the end of January or beginning of February. Dr. Dahmani questioned whether the preference is to run the system during the dry season. Mr. Nixon replied that one reason for choosing thermal desorption technology was because it can be used during winter; however, if the soil is a little bit drier, it would take less propane to reach the required temperature. Dr. Dahmani also asked about any plans for a pilot-scale test. Mr. Nixon noted that because the technology already has been proven for explosives contaminants, a pilot-scale test isn't needed. He also explained that the period-of-performance test will be a full-scale test, which will look at emissions, after which the IAGWSP will apply for final approval of its permit. Dr. Dahmani asked whether the thermal desorption process would be considered incineration by DEP, and would have the same standards. Mr. Pinaud said that he would find out the answer to this question.

Ms. Cassidy recommended moving on to discuss the Demo 1 RRA for groundwater. Mr. Gonser updated the team on the Military Construction (MILCON) issue associated with the Demo 1 treatment plant at Frank Perkins Road. He reported that the Army prepared legislative language for FY'05, which was forwarded to the Office of the Secretary of Defense, where it's currently being reviewed. He also reported that the congressional delegation was not successful in getting any kind of language put into the FY'04 appropriations bill. Another consideration was a category of funding called unspecified minor construction, for which the legal limit is $3 million. Although the IAGWSP was able to get the cost down to just below that amount, given the legal limit, it was thought too risky to start the project without the certainty of being able to complete it for under $3 million. Another possibility was to do a National Environmental Policy Act (NEPA) study in order to get the MILCON funding, but that didn't look promising.

Mr. Gonser stated that to get the project moving in a timely fashion, the IAGWSP decided to procure prepackaged treatment facilities that would do the identical job that the building would have done. This will be a temporary fix and the IAGWSP will try to move the feasibility study process along more quickly in order to reach a final solution sooner. Mr. Gonser explained that while the temporary system will do exactly what's needed, it probably will be more costly to operate for long periods of time.

Mr. Judge said that he's surprised that the congressional delegation's effort was unsuccessful, given Senator Kennedy's senior membership on the Senate Armed Services Committee. He said that he'd like to see any correspondence between the Army and the senators regarding this issue. Mr. Gonser explained that the delegation was asked to add on to existing legislation. He said that he believes that a good effort was made; however, the problem was timing. By the time the delegation became engaged in this issue, most bills were well on their way, if not already passed, and it was too late in the process. Mr. Gonser also said that he believes that the communication with the congressional delegation came from the regulators and Mr. Schlesinger. He noted that he didn't send "any particular written requirement" because he cannot do that.

Mr. Schlesinger stated that the request was made to Congressman Delahunt, not to Senator Kennedy. Mr. Judge suggested that the request be transferred to Senator Kennedy since Congressman Delahunt is not on the Senate Armed Services Committee and doesn't have full Department of Defense (DoD) clearance. Mr. Walsh-Rogalski said that he spoke about this issue with Congressman Delahunt's office, after which the Congressman immediately contacted Senator Kennedy's office. This was in the closing days of the DoD appropriation process, however, and word came back that it was too late. Mr. Walsh-Rogalski assured Mr. Judge that Senator Kennedy's office was directly involved and did whatever could be done. Mr. Schlesinger clarified that he made the request as soon as he possibly could, the night of the last IART meeting. Mr. Judge said that he can't accept that the MILCON issue came up so late in the game. He said that he thinks it should have been addressed long ago, before it became a problem.

Ms. Pepin asked when EPA was informed of the MILCON issue. Mr. Walsh-Rogalski replied "contemporaneously," a day or two before it was discussed at the IART meeting in September or October. Ms. Pepin asked if EPA considers the IAGWSP's solution acceptable. Mr. Walsh-Rogalski replied that EPA is "trying to make the best of the situation" As other possibilities, such as legislation for FY'04, petered out, it became necessary to look at other solutions, and it appears that the temporary treatment system "offers potential." Ms. Pepin asked if there was any written communication between EPA and Congressman Delahunt's office. Mr. Walsh-Rogalski confirmed that there was not.

Ms. Grillo inquired about other future projects that might be affected by the MILCON issue, and efforts to prevent the problem from reoccurring. Mr. Gonser explained that any construction project over $750,000 would be affected, making MILCON a potential long-term problem that the IAGWSP is trying to solve through a long-term legislative fix.

Mr. Schlesinger asked that the IART citizen members be informed in a timely manner of any future requests to be made of the congressional delegation. Mr. Judge asked EPA to take a leadership role with respect to this issue, rather than allowing the onus to be on the citizens to contact the congressional delegation about each upcoming project. Mr. Walsh-Rogalski replied that the prohibition on lobbying for legislation applies to all federal employees below the political level, which includes everyone at the IART table. He said that EPA is doing what it can, without participating in lobbying, with respect to letting Congressman Delahunt know about the importance of the issue. Mr. Gonser clarified that the IAGWSP doesn't anticipate having to rely on citizens to initiate legislative action for each upcoming building project. Rather, it's pursuing a long-term fix for what is essentially a national problem, given the groups that aren't working under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).

Mr. Judge expressed dissatisfaction with the IAGWSP's course of action. He then questioned whether EPA could issue an order that funds be made available so that treatment facilities could be built on schedule. Mr. Walsh-Rogalski explained that the issue at hand has to do with how the military spends money, and EPA "can't make that rule disappear." He said that a legislative fix that's written so that it addresses the problem from this time forward is the best remedy. The question is whether that fix can be instituted between now and the next appropriations bill to cover upcoming projects.

Mr. Hugus stated that solving this problem is not the citizens' or EPA's responsibility, but that of the National Guard and DoD. He said that DoD "doesn't spend much on environmental restoration" because that isn't its priority, and he thinks its priority needs to be changed. He also suggested that EPA could help the situation by enforcing project deadlines by imposing fines, which is something he thinks DoD would understand.

Mr. Mullennix acknowledged that past military operations caused environmental contamination, but stated that the present-day military pays a lot of attention to the environment and is spending a great deal of money on cleanups throughout the country. He said that he takes exception to any comment that the military isn't spending money on cleanup projects. Mr. Mullennix also said that he applauds EPA and the military for coming to agreement on the temporary Demo 1 system so that effort can move forward.

Mr. Nixon noted that the temporary treatment facility is based on containers (like those seen on ships and trucks) retrofitted with insulation and a series of vessels to filter water. He also said that construction of the original well and pipeline layout design is under way. He described the temporary facility as three containers, located right next to each other, and noted that 220 gallons of groundwater per minute would be piped to and split among the three containers. The filter media has not yet been decided, but will likely be either granular activated carbon (GAC), ion exchange resin, or a combination of the two. Mr. Nixon also noted that the temporary facility would be situated right next to the planned treatment plant location, as there's a fairly good chance that that plant eventually will be constructed.

Mr. Nixon reported that influent concentrations of perchlorate at the Frank Perkins Road system are expected to be in the range of 15 to 25 parts per billion (ppb), and at the Pew Road system they're expected to be about 2 ppb. He also noted that the innovative technology evaluation (ITE) at the Pew Road system, which will look at GAC and two types of ion exchange resins, is slated to begin in January and be completed around July 2004. Results of the ITE study will help dictate the design of future systems to treat low-end levels of perchlorate.

Mr. Gonser clarified that the prepackaged system at Frank Perkins Road is really no different than the original design. The same amount of water will be treated there, at the same pumping rate and cleanup efficiency, but instead of being in a big building, it will be in three containers. He also noted that the system probably will be in place sooner than the building would have been. Mr. Nixon agreed that the end result would be the same - 98% capture of the plume, with the water distributed outside the contaminated plume area.

Mr. Judge inquired about the difference in cost between the prepackaged system and the original treatment building, and noted that he thinks the IART should have some say on how any savings are spent. Mr. Nixon replied that the cost difference, which he thinks is about three or four million dollars, has already been reprogrammed to other projects. Mr. Gonser disagreed with the cost difference Mr. Nixon mentioned, and explained that the operation and maintenance costs for the prepackaged system probably would be higher, although he doesn't think an actual cost analysis has been done. He also noted that the intention is to use the prepackaged system only until it can be replaced with a treatment building. He said that he doesn't think it would be accurate to say that a prepackaged system is being used in order to save money. Mr. Judge remarked that the situation is worse than he'd imagined and he is disappointed that EPA is accepting it. He said that he'd prefer that EPA not accept it, begin levying fines, and "collect the cash to do it right."

Mr. Nixon noted that an advantage of the containerized unit is that later it can be transported to other sites on the base for "hotspot" treatment. Mr. Judge said that if these units are that portable, the IAGWSP should be ordering hundreds of them so it can "start treating a lot more different sites now" and get "a much greater bang for our buck." Mr. Nixon replied that the IAGWSP is thinking along the same lines, in that it wants to have that flexibility to conduct rapid response actions, but perhaps not at the speed Mr. Judge would like.

Dr. Dahmani asked if the Pew Road extraction well would capture the toe of the plume. Mr. Nixon replied that while there's been some discussion about what to call the toe, an extraction well will be in placed at the downgradient portion of the plume. He also reminded the group that the RRA is a temporary solution, and the feasibility study process will result in a comprehensive solution several years down the road.

Mr. Butler referred to Mr. Judge's earlier comment and said that EPA would not impose fines on the cleanup program because that would take away from resources needed for the base. He then remarked that the military already has violated the spirit of the Memorandum of Understanding that it recently signed with the state, and he would recommend going to EPA attorneys for help on filing a qui tam action in the Massachusetts District Federal Court to put a cease and desist order on National Guard operations at the base.

Mr. Walsh-Rogalski stated that the reason for going forward with the temporary system, as opposed to the system that was planned originally, is that it doesn't constitute military construction and is not subject to MILCON constraints. Mr. Nixon added that with the prepackaged system, the IAGWSP will be able to begin treating water much faster.

Northwest Corner Recent Unvalidated Detections

Mr. Gregson reported that perchlorate was detected at 1 ppb in the water table screen at an existing well, MW-65. Perchlorate was detected in samples from MW-210, located along Canal Road, at concentrations from 2 to 8 ppb, with the higher concentrations at the water table. Screens have been set in MW-210. Mr. Gregson also noted that profile results from NWP-11 show low levels of perchlorate, between 0.8 ppb and 0.4 ppb, with detections at the water table and a deep detection at 111 feet below the water table. Mr. Borci asked about the purpose of MW-65. Mr. Gregson replied that the purpose of that well was to assess contamination from the gun position there, as part of an earlier investigation.

Mr. Gregson then displayed a figure showing soil sampling results. He noted that samples collected at old Gun Position 19 yielded just one perchlorate detection, at about 5 ppb. He also pointed out a number of perchlorate detections in the center of the figure, at concentrations up to about 20 ppb, as well as the nondetects to the north. He noted that "A" samples were collected from zero to 0.5 feet and "B" samples were collected from 1.5 to 2 feet.

Mr. Gregson stated that next steps include drilling a new well (NWP-12) upgradient of MW-298, and another to the south (NWP-8A). Also, the IAGWSP has been working with EPA and DEP to obtain access to install a well downgradient of the existing water supply well at the Schooner Pass condominium complex. Mr. Gregson said that a preliminary report on findings to date at the Northwest Corner is scheduled to be out in January 2004.

Mr. Mullennix asked if the source of contamination has been identified. Mr. Gregson replied that it has not, but the investigation is still ongoing. Mr. Mullennix then asked if the preliminary report would speak to fate and transport and the contamination source. Mr. Gregson said that if the data support it, the report would include information on potential sources of the perchlorate. He also noted that two potential sources being looked at are military training with smokes, and the fireworks. Mr. Mullennix asked whether the regulators had any comment on the possible source of perchlorate contamination at the Northwest Corner, but received no reply.

Mr. Schlesinger asked if any "chunked perchlorate" had been found on top of the soil. Mr. Gregson replied that the only evidence seen on the surface of the soil is cardboard debris from the fireworks. Mr. Schlesinger asked what kind of work is being done to determine how quickly perchlorate, regardless of its source, leaches through the soil. Mr. Gregson said at this point the only effort in that regard is the routine monitoring of locations where the highest levels of perchlorate in both soil and groundwater were detected.

Mr. Schlesinger inquired about moving the investigation upgradient, assuming that the detections Mr. Gregson mentioned tonight are from military training of some sort. Mr. Gregson replied that the information from the groundwater wells points to a nearby source of perchlorate rather than one that's far upgradient. He also noted, however, that detections of RDX at locations off base are deeper in the aquifer, and look like they would track back closer to the Impact Area. Mr. Gregson stated that information from the well at NWP-12 should help to complete the picture.

Mr. Borci said that he disagrees with "the implication that it's all coming from fireworks." He noted that some RDX detections are co-located with perchlorate detections and that not all soil sampling locations exhibit characteristics of fireworks papers. He also noted that the four sampling grids east of the road were selected because an historical aerial photograph showed a cleared area there and a significant number of training diary entries mention specific activities that could have contributed perchlorate to groundwater "at these locations." He said that the investigation is ongoing, and no potential source areas have been eliminated at this point. Mr. Pinaud agreed with Mr. Borci that the investigation has not been completed, and will go wherever the data indicate the source areas are. Mr. Gregson noted that that's what he was trying to say.

Mr. Mullennix asked if it's correct that the Upper Cape Regional Technical School refused a request to allow sampling on its property. Mr. Gregson confirmed that it is. Mr. Mullennix questioned whether DEP or EPA might step in and require the school to permit access to the property. Mr. Borci replied that the school location was secondary. The best location is a site near well 4036011, and an access agreement with that property owner is currently being worked. He also said that the existence of clean well screens downgradient of the school property make that an inferior location to the one at Schooner Pass. Mr. Mullennix said that he's really impressed by the power of the school to refuse a request by EPA and DEP to obtain access to that property, and thinks it's "really quite something" that the regulators accepted that.

Mr. Judge questioned why the map doesn't show the perchlorate detection at MW-297 as part of the plume. Mr. Gregson explained that the map hasn't yet been revised to show the extent of the plume based on new data. He said that typically plume maps aren't updated for every well that's installed, but after certain phases of the drilling program have been completed. Mr. Judge expressed great dissatisfaction with this approach and said that as the map appears now, it seems that the detection at MW-297 is not part of the plume.

Southeast Ranges

Mr. Gregson reported that profile results from a new well at the L Range (LP-11) showed perchlorate at 1.1 ppb and RDX at 0.52 ppb. Profile results from the well at J3P-33, which was drilled to help define the western extent of the plume emanating from the center of the J-3 Range, showed perchlorate detections at six intervals at concentrations from 0.42 ppb to about 3 ppb.

Mr. Gregson then referred to the map showing perchlorate and RDX contamination coming from Disposal Area 2 at the J-2 Range, and pointed out the zones of contribution to the Upper Cape Water Cooperative supply wells. He reported that perchlorate was detected at 45 ppb in profile sampling at MW-293, located along Wood Road. A downgradient well along Jefferson Road, MW-296, was subsequently drilled, and profile sampling there showed nondetect results for perchlorate and explosives. Mr. Gregson also noted that perchlorate was detected at 89 ppb in a recently drilled well at J2P-31. He said that the IAGWSP is trying to ensure that the nondetect at MW-296 is something that's beyond the toe of the plume, rather than off to one side of it.

Mr. Gregson stated that 30 wells currently are scoped for the J-1, J-2, J-3, and L Ranges, and the RRA workplans for soil removal at the J-2 and J-3 Ranges are being finalized. He also noted that the evaluation continues regarding the potential for using the FS-12 treatment plant to address the contamination migrating south from the J-3 Range. At a meeting with the contractors yesterday, treatment train requirements were reviewed, as were some options for placing equipment, and an evaluation of ecological thresholds and regulatory constraints. Mr. Gregson said that the IAGWSP would meet with the regulators this Thursday to discuss the FS-12 system evaluation.

Mr. Racheotes introduced himself as "RSNWO3, the dot on the map." He offered his thanks to those individuals in the room whom he hadn't met in person but who were effective in having bottled water delivered to his house and having his water tested twice a month. He also remarked, however, that because his well is contaminated, there needs to be a long-term solution for him personally. Mr. Racheotes said that it doesn't make sense to him to spend hundreds of dollars a month providing bottled water and testing his well when his residence could simply be connected to the town water system.

Mr. Racheotes also said that he wants the IART to understand that although he hasn't done any interviews or sought out other actions, he has been patiently waiting for nine months for the military to "do the right thing," which is what he expects. He added that if it doesn't, however, he will "force them to do the right thing." Mr. Racheotes commented that his house is not just a dot on the map, but "a household that for eight years drank the water, bought the property, and thought things were fine." He also said that it's only because of "the EPA doing an investigation" that he became aware of the situation and is where he is tonight, and when these situations affect people personally "they can't drag on for months and years." Mr. Racheotes further noted that 25 years ago, when he began working on Cape Cod, "people in Falmouth were boiling their water because of the base." He said that 25 years is a long time to clean up a problem. Ms. Cassidy thanked Mr. Racheotes for his comments and said that she hopes the Guard takes them to heart.

Mr. Schlesinger asked what the objection would be to hooking up Mr. Racheotes's residence to town water. Mr. Gonser confirmed that Mr. Racheotes's address is 5 Foretop Road. He then said that this is a difficult policy issue for the military, and noted that people in Washington, D.C. have indicated that there are fiscal and policy constraints associated with providing replacement water supplies because of low-level perchlorate detections off base. He said that the IAGWSP has asked the question, and recommended that action, but has not received approval. Mr. Gonser also noted that he'll be going to Washington next Wednesday and meeting with some of the decision-makers, at which time he'll raise this issue again, as planned. He further stated that from an economic standpoint he thinks it's wise to provide a water hookup, but it's a matter of fiscal and legal constraints on what can and cannot be done.

Mr. Judge recommended that EPA "add the weight of their offices" to do whatever it can to help Mr. Racheotes, and to do so quickly so that Mr. Gonser can bring with him to his meeting in Washington a letter stating EPA's request for an immediate decision on a water hookup. Mr. Judge also suggested that if Mr. Racheotes's neighbors are similarly affected, they too should be included in any rapid response to this problem. He said that this is a human issue that calls for an immediate proactive response.

Mr. Borci said that when the project managers learned of this issue, the first recommendation made to the Guard was that the most sensible solution would be to hook up Mr. Racheotes's house to town water. Mr. Borci also asked Mr. Gonser to provide the regulatory agencies with copies of any written correspondence with his higher-ups in which Mr. Gonser recommended that course of action.

Mr. Pinaud said that on behalf of DEP he's very sorry that Mr. Racheotes has to go through this situation. He also reminded the team that the Commonwealth of Massachusetts, not the Army, is paying for the bottled water being provided to Mr. Racheotes. And while the state doesn't mind incurring that cost, he wishes there were a way to ensure that the federal government takes responsibility for a town water connection. He added that right now, however, "we're stuck with the process that [Mr. Gonser] is trying to pursue."

Mr. Hugus told Mr. Racheotes that upon first hearing about his situation, team members thought it outrageous that the military wouldn't pay for a town water hookup, and have complained every time the issue has come up. Mr. Hugus also noted that in the past, residents of Mashpee and Falmouth sued in order to get the military to pay for water hookups, so that course of action has been taken. He then noted his belief that the reason the military is resistant to paying for a hookup to Mr. Racheotes's house is that doing so would be an admission of responsibility, which would open up liability questions at military bases throughout the country. He added that from his point of view, "it's just totally immoral." Mr. Hugus then questioned whether DEP, which is providing bottled water, could somehow provide a water hookup as well.

Mr. Racheotes stated that he expects the parties that are responsible to live up to their obligations, which is what he does every day, and he doesn't think he should have to bring suit. He said that his government should work for him, as his state government is doing. He also said that while the military paying for his water hookup might "open up things across the country," the problem exists across the country, not just at RSNW03. Mr. Racheotes further noted that although he's healthy today, if he's not next year, "it's not just a couple of thousand dollars to run a copper tube 20 feet out to the street - it gets real big then." He clarified that he's not threatening anyone, and people familiar with his situation have been surprised at his low-key approach - driving reporters off his property, refusing to return phone calls from the New York Times - because that's the not the way he conducts his business. Mr. Racheotes stated that he makes decisions every day to "set people's problems straight" because he knows that letting them go longer means that they'll get worse and cost more money, and ultimately there will be no satisfaction on anyone's part.

Mr. Racheotes said that tonight he wanted to "put the face with the address" in the newspapers and personalize the situation. He stated that he's not waging war with DoD, the Massachusetts National Guard, or anyone else, but just expects them to "do the right thing" for him or anyone who's affected by pollution from the base. Mr. Racheotes also noted that he's lived at Foretop Road for eight years, "the fireworks have only been there three or four," and he thinks the perchlorate has probably been there longer than the fireworks.

Agenda Item #6. Adjourn

Ms. Cassidy noted that the IART would meet next on Tuesday, January 27, 2004 at the Bourne Best Western. She then adjourned the meeting at 9:30 p.m.

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