Impact Area Review Team

River River Drops of rain on a leaf

Impact Area Review Team
Falmouth Holiday Inn
February 25, 2003
6:00 Ė 9:00 p.m.

Meeting Minutes





Hap Gonser




Ben Gregson



Marty Aker




Jerrime Oliver

Camp Edwards


Todd Borci



Bill Walsh-Rogalski



Margery Adams



Len Pinaud



Ellie Grillo



Richard Hugus



Jim Stahl



Amine Dahmani








Jim Murphy








Tina Dolen



Pam Richardson




LTC Will Tyminski




LTC Brian Rogers




Jane Dolan



Kevin Hood




Millie Garcia-Surette




Justin Mierz



Michael Butler




David Dow

Sierra Club



Ralph Vaccaro

West Falmouth resident


Patrick Skelly

Bourne resident


Jean Crocker




Kim Harriz


Jay Clausen



Mark Applebee



Joseph Robb



Katherine Weeks


Jim Quin

Ellis Environmental Group


Steve Denahan

Ellis Environmental Group


David Cobb



Rob Paine



Pete Delano

Nobis Engineering



Doug Larson

GeoSyntec Consultants


Rick Carr



Kris Curley



Lori Boghdan



Jennifer Washburn



Jane Moran



Action Items:

  1. Mr. Hugus requests that the U.S. Environmental Protection Agency (EPA) consider setting enforceable milestone dates for cleanup of the Southeast Ranges plumes.
  2. Mr. Gregson will check on the status of the programmatic agreement being pursued by the Massachusetts Military Reservation (MMR) with respect to cultural resource surveys, and then update the Impact Area Review Team (IART) at a future meeting.

Future Agenda Items:


  • Presentation on Northwest Corner of Camp Edwards
  • Presentation on Modeling


  • Gun and Mortar Firing Positions Workplans
  • Fate and Transport Presentation

Handouts Distributed at Meeting:

  1. Presentation handout: Demolition Area 1 Soil Interim Action
  2. IAGWSP fact sheet: January 2003 Ė Demolition Area 1 (with map attached)
  3. Information sheet: Demolition Area 1 (Demo 1)
  4. Rapid Response Action/Release Abatement Measure (RRA/RAM) Schedule Ė Demo 1 Soil Operable Unit
  5. Notice of public comment period for draft RRA/RAM for Demo 1 Soil Operable Unit
  6. Responses to Action Items from the January 28, 2003 Impact Area Review Team Meeting
  7. February 2003 EPA letter re: IART citizen representation from Bourne, with application attached
  8. 2/25/03 EPA e-mail letter from Jim Murphy to Robert Varney re: invitation to Mr. Varney to attend future IART meeting
  9. Presentation handout: Investigation Update
  10. Data Tables
  11. Impact Area Groundwater Study Program Update / February 2003

Agenda Item #1. Welcome, Review Draft Agenda, Approval of January 28, 2003

Meeting Minutes

Mr. Murphy convened the meeting at 6:10 p.m. and the IART members introduced themselves. Mr. Murphy reviewed the agenda, and then asked whether there were any changes or additions to the January 28, 2003 IART meeting minutes. Mr. Walsh-Rogalski said that heíd become aware of some discrepancies in the section of the minutes pertaining to his report on the new perchlorate guidance, and would like the opportunity to take another look at the reference documents heíd used and then submit any changes to the minutes in writing. Mr. Murphy stated that approval of the January 28, 2003 IART minutes would be postponed until the March 25, 2003 IART meeting.

Agenda Item #2. Late-Breaking News

There were no late-breaking news items to report at this time.

Agenda Item #3. Demolition Area 1 Rapid Response Action/Release Abatement

Measure for Soil

Mr. Hill stated that tonightís presentation of the Rapid Response Action/Release Abatement Measure (RRA/RAM) for the Demolition Area 1 (Demo 1) source area kicks off an informal public comment period. He then showed an aerial photograph of the approximately 7.5-acre Demo 1 source area, which is a topographic depression surrounded by a perimeter road. He noted that demolition training activities were conducted at Demo 1 from the early 1970s to the late 1980s. Those activities included open burning, open detonation, and training in the use of explosives.

Mr. Hill reported that more than 650 soil samples were collected as part of the Demo 1 source area investigation. The primary contaminants of concern (COCs) found were Royal Demolition Explosive (RDX), High Melting Explosive (HMX), trinitrotoluene (TNT), dinitrotoluenes (DNTs), perchlorate, and nitroglycerin. In addition, over 2,500 geophysical anomalies were identified, most of which are interpreted to be "kick-out" from demolition activities that occurred at the site over the years. Evidence of burning residue, which is indicative of open burning, also was discovered. Mr. Hill stated that the deposition of explosives and other contamination in the soil represents an ongoing source for groundwater contamination, which has resulted in the Demo 1 plume.

Mr. Hill stated that the Army is proposing to remove this source of contamination through an RRA/RAM, which should complement and limit the scope and duration of the Demo 1 RRA/RAM groundwater cleanup action. Also, itís hoped that this plan will represent a final remedy for the Demo 1 source operable unit.

Mr. Hill noted that one component of the RRA/RAM plan is 100% clearance of the geophysical anomalies found within the depression, a labor-intensive activity during which each individual item will be dug up. He said that when enough of the anomalies have been removed, equipment could be brought into the area so that the excavation work can commence.

Mr. Hill then showed a figure entitled "Excavation Plan, RRA/RAM Plan, Demo 1 Soil Operable Unit" and reported that the contour shown in green will be excavated to an average of 1 foot in depth, the contour shown in blue will be excavated to an average of 2 feet in depth, and the contour shown in orange will be excavated to an average of 8 feet in depth, all of which constitutes approximately 15,000 cubic yards of material.

Mr. Hill noted that the material will be removed from the site and taken to a staging area, which is likely to be the High Use Target Area 1 (HUTA 1). The excavation work is expected to be completed late in 2003, when the cold weather hits. Therefore, the material will be stockpiled at the staging area until the return of warmer weather, which is more conducive to the wet process of soil washing, a volume reduction technology. Mr. Hill noted that any burn pits probably would be handled during the anomaly removal phase of the project. The burn pit material will be handled separately, characterized separately, and disposed of appropriately.

Mr. Hill stated that the soil-washing treatment is expected to realize approximately 75% volume reduction, with 75% of that material going back to the hole at the Demo 1 site. Disposition options for the remaining material, which would be too contaminated to go back to the hole, include taking it off site or, more likely, using it to conduct some innovative technology evaluations. Mr. Hill also noted that post-excavation samples will be collected from the site, and once the IAGWSP and the regulators are satisfied that the excavation is complete, a site restoration plan will be implemented.

Mr. Hill stated that the informal public comment on the RRA/RAM plan ends on March 11, 2003. The plan should be finalized by May 2003, at which time the anomaly removal action will commence. The soil excavation is expected to begin in August and be completed by November 2003. The excavated material will be stockpiled for the winter, with burn pit residues to be disposed of without delay. A draft RRA/RAM completion report is scheduled to be submitted in June 2004, and site restoration should occur between July and September 2004.


Mr. Hugus suggested that it would be more efficient to use a staging area thatís closer to the Demo 1 source area than the HUTA is, given the huge amount of soil that will be transported from and back to the site. Mr. Hill replied that the stockpiling of material is going to require a fair amount of space. The HUTA is a wide-open space, it has good security, and itís convenient to other areas on Camp Edwards where soil removals are expected to be done. Mr. Hugus recommended that it would be worthwhile to look into other, closer areas. Mr. Hill said that there isnít a final decision on this yet; however, the IAGWSP is leaning heavily toward using the HUTA.

Mr. Hugus expressed some concern that the excavation might not be deep enough to remove all the contaminated soil that exists at Demo 1. He said that a former IART member had reported that a lot of backfilling occurred at Demo 1, such that it changed the whole topography there. Mr. Hill agreed and said that itís believed that most of the backfilling occurred within the orange contour shown on the figure. He then explained that 8 feet is the average depth of excavation in that area; in reality, however, digging will be done down to the natural soil horizon, below the original grade of the site. Mr. Hugus asked if Mr. Hill actually thinks that the excavation will remove all the contaminants in the soil. Mr. Hill replied, "We think we have a real good shot of doing that." Mr. Hugus also inquired about identifying the original depths of the soil. Mr. Hill replied that itís visible, and explained that soil development involves a sequence of horizons that are visible when the soil profile is exposed.

Mr. Walsh-Rogalski said that he was a little bit confused, and questioned whether Mr. Hill had meant to say that this work was being done by the National Guard Bureau (NGB), rather than by the Army. Mr. Hill replied, "Weíre all the Army really." Mr. Walsh-Rogalski mentioned that there was a recent discussion with COL Walter on this issue. He also said that he would appreciate it if the IAGWSP would keep the point clear that the NGB is the respondent, responsible for conducting and funding the cleanup work.

Mr. Pinaud asked how much of the estimated 15,000 cubic yards of soil would be treated. Mr. Hill replied that all but the burn residues would be washed. Approximately 15,000 cubic yards will go through the soil-washing apparatus, and itís expected that about 75% of the material coming of the soil-washing apparatus will be clean enough to go right back into the excavation. Mr. Pinaud asked whether the intention is to add more soil to the area as part of the restoration process. Mr. Hill said that the habitat protectors recommend against importing material thatís not native to MMR. However, the area could be opened up to receive clean-fill from elsewhere on post.

Dr. Stahl asked Mr. Hill to remind him of the depth of a rather deep burn pit at the Demo 1 site. Mr. Hill replied that test-pitting activities have uncovered about six burn pits so far, and the expectation is that more will be found. He said that one of the burn pits was in the bottom of the depression, but he canít remember exactly where the others were located. Dr. Stahl explained that his point is that heís not sure that 8 feet would be a deep enough excavation. Mr. Hill explained that 8 feet is the average; the expectation is to dig deeper in some areas, and perhaps not quite so deep in others. He added, "Öthe natural horizonís what weíre after."

Dr. Stahl then asked Mr. Hill to discuss the testing thatís planned for the soil washing process to ensure that no contamination is returned to the site. Mr. Hill replied that that testing regime hasnít been determined yet. He also noted, however, that the soil-washing apparatus sorts the materials by size and density, and he expects that each of those segregated piles will be sampled on some frequency, not just once.

Dr. Stahl noted that he has a vague recollection that there was some sort of problem with a previous soil-washing effort. Mr. Hill agreed that it had taken a while to optimize that operation. He noted that water management was probably the most onerous issue then, and a lesson learned from that experience was to not locate the staging area on an asphalt surface. Dr. Stahl then inquired about containment of the stockpiled material. Mr. Hill replied that the stockpile will be on poly, will be managed aggressively, and will have an appropriate cover thatís heavy enough to keep the wind from lofting it.

Ms. Adams noted that this project would be considered a waste management activity under the Resource Conservation and Recovery Act (RCRA), and therefore it will have to meet RCRA standards. She said that it also might have to meet land disposal regulations for replacement of the clean material back into the kettle hole, and there might be RCRA issues regarding the stockpiled soil as well. Ms. Adams said that she would urge the IAGWSPís attorneys to contact EPA and the Massachusetts Department of Environmental Protection (DEP) as soon as possible to ensure that these issues can be addressed.

Mr. Hugus inquired about the amount and the source of water needed to do the soil washing. Mr. Hill explained that the soil washing apparatus involves a closed-loop system, and contamination will get into the batch water, which ultimately will require treatment. He also said that it is likely that more than one batch will be used, and that water will come from a clean well. Mr. Hugus then asked how the contaminated water would be treated. Mr. Hill replied that the water typically would be treated with carbon. However, in the event that thereís a lot of perchlorate in the water, the expectation is that by that time thereíll be a treatment plant on line that can handle perchlorate contamination.

Mr. Pinaud stated that he found the plan to be light on information about soil washing, soil management, dust control, health and safety, and restoration of the area, and DEP will be looking for more of this kind of information. He also asked Mr. Hill to talk more about the innovative technology evaluation.

Mr. Hill said that the innovative technology evaluation project, which has been active since 2000, initially was intended to look at innovative technologies for the treatment of explosives in soil and groundwater. Since that time, however, perchlorate has become an issue as well. Mr. Hill explained that the evaluation essentially is a screening process, whereby some technologies were screened out because they were not innovative, and some were screened out because they wouldnít work. Two technologies that were retained are low-temperature thermal desorption and composting. Mr. Hill also said that the evaluation is an ongoing project that has not yet been finalized.

Mr. Pinaud noted that the plan didnít contain much detail on this issue either, and heís concerned about how much soil would be held at the site, and how long it would be held there. Mr. Hill replied that he believes that thereís enough room at the HUTA to conduct these demonstrations in the vicinity of the stockpile area. He also said that the project schedule is very aggressive, and more details will be forthcoming in the months ahead.

Mr. Borci stated that EPA had pushed for 100% removal of unexploded ordnance (UXO), and he would like to commend the Guard for agreeing to do that. He then noted, however, that EPA has some concerns about water management, and he mentioned that perchlorate was not an issue the last time that soil washing was done. Mr. Borci also said that he believes that the deepest burn pit went to 13 feet below ground surface. He acknowledged that 8 feet is an average depth, and added that he hopes that there arenít other burn pits that deep. He then said that contamination has been detected as far down at 26 feet below the bottom of the kettle hole, and noted that this is addressed in the workplan in some level of detail. Mr. Borci stated that on the whole, EPA is looking for more details, some of which he believes could have been included in the plan.

Mr. Dow asked how long the site would function as a source area once the soil removal action has been completed. Mr. Hill said that there isnít a real good answer for that question. He also noted, however, that itís believed that below the original soil surface, the contaminant is in the aqueous phase, migrating through the vadose zone. He further noted that the IAGWSP has been talking to some technology developers about methods to degrade explosives in situ in the vadose zone Ė something that might be applicable in this situation after the excavation has been completed.

Mr. Dow asked whether itís true that perchlorate travels more rapidly through the vadose zone than do explosives. Mr. Robb of AMEC replied that, like migration through groundwater, migration of perchlorate through the vadose zone is expected to be slightly more rapid than the migration of explosives. He also said that perchlorate has been detected in the soil, but at very low concentrations.

Dr. Dahmani commented that the issue of depth of contamination is going to be important because the soil thatís returned to the site will have a higher permeability after itís been treated, which could be a problem if all of the contamination isnít removed properly. Mr. Hill replied that as much contaminated soil will be excavated as possible, and strong consideration will be given to in situ treatment of any contamination that remains in the vadose zone. Any contamination that canít be removed before it reaches the water table will be addressed by groundwater extraction wells in the plume. Dr. Dahmani mentioned that because of the heterogeneous nature of the soil, it might be very difficult to treat it effectively in situ.

Mr. Vaccaro, a resident of West Falmouth, asked whether the different solubilities of the pollutants in water have been considered with respect to soil washing. Mr. Hill explained that the primary benefit of soil washing is volume reduction on the solids. Although some amount of dissolution is expected while the material is being manipulated in the wash apparatus, itís really a volume reduction step thatís taken so that itís not necessary to treat or dispose of all of the material.

Ms. Crocker asked whether itís absolutely necessary "to go that deep." Mr. Hill replied that the IAGWSP believes that it is. Ms. Crocker also asked if the kettle hole at the site is natural. Mr. Hill replied that itís a natural kettle hole thatís been affected by training activities. Ms. Crocker then inquired about the number of years it would take before the site is restored to its "natural indigenous habitat." Mr. Hill said that it could be a decades-long process, if left to nature, and he noted that there are seed mixes comprised of grasses found at MMR naturally. He also mentioned an ongoing research project that involves taking plugs of scrub oak plants from various areas around the installation and installing them in an excavated area to see how quickly they take root. Ms. Crocker questioned whether the results of that experiment would be published, and possibly used as a model for other installations. Mr. Hill said that results of the project would be documented and might prove helpful in developing standard operating procedures for excavations at MMR. He also noted, however, that heís not sure that it would be directly translatable to other installations, where the climate and growing conditions differ.

Mr. Hugus questioned whether any action had been taken with regard to clarifying whoís in charge of cleanup activities being conducted by the IAGWSP, and whether itís true that the Army is taking over the NGBís role. Mr. Walsh-Rogalski explained that the Army had asked to be made the respondent to the administrative orders in lieu of the NGB, and EPA had replied that it was appropriate for the NGB to remain the respondent. He said that itís clear to EPA that the legal respondent is the NGB, and EPA expects communications to come from the NGB, not from the Army. He further noted that EPA has asked that the Armyís involvement, now that the Army Environmental Center (AEC) is the supervising contractor, be clearly indicated in communications as "Army/NGB."

LTC Rogers clarified that COL Walter had said that the NGB is still involved because the money for the cleanup project flows through the NGB. He also noted that COL Walter had said that when the Army talks at the IAGWSP, it is representing the NGB as the respondent. In addition, COL Walter had noted that he appointed Mr. Gonser as his technical project coordinator, and Mr. Gonser works for the AEC Ė therefore, the Army is the lead on the project now, and when Mr. Gonser speaks he represents the NGB. Mr. Walsh-Rogalski stated that according to correspondence from COL Walter, the Army is the supervising contractor, and the NGB is the respondent thatís legally responsible.

Mr. Hugus suggested that if no one is taking clear responsibility, thereís potential for trying to avoid responsibility under the administrative orders. Therefore, he thinks itís important to straighten out this situation. Mr. Walsh-Rogalski stated that EPA is holding the NGB responsible. He also said that while EPA has accepted NGBís statement that AEC currently is its supervising contractor, EPA believes that presentations and correspondence should be characterized as NGB work, because NGB is the respondent and is paying for the work.

Mr. Hugus said that, as a citizen member of the IART, heíd like to be certain that itís clear who is taking responsibility for the cleanup. Mr. Walsh-Rogalski asked LTC Rogers if he agrees that the NGB is the legal respondent to the administrative orders. LTC Rogers agreed that the NGB is the legal respondent. He also noted that the orders call for the NGB to appoint a technical project coordinator, who would be the focus of all correspondence for the project, and that person is Mr. Gonser, an Army employee working for AEC. Mr. Walsh-Rogalski added, "Working for AEC working for National Guard Bureau."

LTC Rogers said that Mr. Walsh-Rogalski has it backwards, and then clarified that the NGB works for the Department of the Army. The Army is the ultimate decision-maker, it can tell the NGB what to do, and it provides the NGB with the money for the cleanup project. LTC Rogers explained that by keeping the money at NGB, the Army is able to ensure that it doesnít disappear from this project.

Ms. Crocker indicated that she is disturbed by these "persnickety concerns or power-plays," and thinks that itís important to get the job done. She also noted that while she never hears it mentioned at the IART table, money for the cleanup comes out of NGB operational and training funds, and she finds that to be very upsetting.

Mr. Gonser stated that he agrees with Mr. Hugus that any project for which no one is accountable could go astray. Mr. Gonser then assured the group that in this case, he is the person who is accountable, and if something goes astray, he is the one who needs to get it fixed. He also noted that he has access to all levels of the Army to get the resources and technical support needed "to make it happen." Mr. Hugus said that he probably wouldnít be concerned if the audit report that brought about this change hadnít specifically noted that the Department of the Army is not happy about the amount of money being spent on the cleanup and would like to change that. He also said that heís concerned about GEN Van Antwerpís statement that public health in some cases should be sacrificed to military training.

Ms. Crocker said that she thinks itís important to think of balance. She also questioned why Mr. Walsh-Rogalski would complain about having access to all levels of the Army. Mr. Walsh-Rogalski clarified that it was Mr. Gonser who said that he now has access to all levels of the Army. Ms. Crocker asked Mr. Walsh-Rogalski to excuse her error, and added that she thinks Mr. Gonser should have that access.

Dr. Stahl said that heís glad to hear that the innovative technology evaluation has not been forgotten, as he thinks itís a key component. He also asked Mr. Hill to talk about the soil washing in terms of percentage of pollutants and the fractions expected to be seen. Mr. Hill replied that in the process of separating soil material by size and density, the contaminant mass ends up being concentrated in the finer fractions, and 75% of the material is relatively coarse. Dr. Stahl observed that it hadnít come across clearly in Mr. Hillís presentation that most of the contamination would be in "the fines and the organic," which is why soil washing will work in terms of volume reduction.

Mr. Borci made a point of noting that the soil removal activity being discussed tonight is an interim remedial action. Although the goal is to try to make it the final remedy, there will be an opportunity to go back and do more work if necessary.

Ms. Garcia-Surette inquired about the confirmatory sampling program. Mr. Hill replied that whatís being proposed is a composite-sampling scheme, post excavation. Ms. Garcia-Surette said that the agencies are interested in risk-based numbers that ensure that the excavation reaches the level where thereís no longer any contamination. Mr. Hill noted that a licensed site professional (LSP) will render that opinion for the Massachusetts Contingency Plan (MCP). Ms. Garcia-Surette mentioned that with an August 2003 start date, itís important to start working on this aspect of the plan.

Agenda Item #4. Review Responses to Action Items from January 28, 2003 IART Meeting

Mr. Murphy referred to the bottom part of the "Responses to Action Items" where it was noted that by tonightís meeting the team would be provided with EPAís acceptance criteria for IART membership applicants, as well as copies of a letter to Robert Varney, EPAís regional administrator, urging him to attend a near-future IART meeting. He then noted that the acceptance criteria essentially are laid out in the questions posed within the IART membership application that was provided to the team. He also said that the day after the last IART meeting, he had told Mr. Varney that team members again asked that he attend a future meeting as soon as possible, and Mr. Varney had replied that that was his intent. Mr. Murphy said that Mr. Varney has not yet confirmed a meeting date, and he sent Mr. Varney an e-mail today, copies of which were provided to team members.

Mr. Hugus asked that the IART be given advanced notice when Mr. Varney does plan to attend a meeting, He also said that he thinks that time should be set aside on that meeting agenda for some general discussion about Camp Edwards and the cleanup, when citizens could offer their opinions. Mr. Hugus then stated that the idea is for the citizens to have a chance to speak with Mr. Varney, just as the military did a month or two ago. Mr. Murphy noted that he had suggested that when Mr. Varney does come to a meeting, that he try to arrive early so that there would be an opportunity to speak with him before getting into a typical meeting.

Agenda Item #5. Investigations Update

Demo Area 1 Recent Unvalidated Detections

Mr. Gregson referred to monitoring well 258 (MW-258), located along the power line, west of the toe of perchlorate contamination at the Demo 1 plume. He reported that profile results at that well showed low-level perchlorate detections, at 0.37 parts per billion (ppb) and 0.51 ppb, as well as a detection of RDX in one interval, but with interference. Screens have been set in MW-258, and sampling results are expected to be available soon. Mr. Gregson also noted that drilling has just been completed, or is nearing completion, at location D1P-19, a well whose purpose is to help define the lateral extent of contamination at the edge of the plume near Frank Perkins Road, where extraction is planned as part of the Demo 1 RRA/RAM for groundwater.

Mr. Hugus inquired about sampling results from MW-248 and MW-252, two wells also located near the power line, along with MW-258. Mr. Gregson replied that profile results showed MW-248 to be nondetect for both explosives and perchlorate, while profile results for MW-252 showed a 0.45-ppb perchlorate detection. Mr. Hugus asked when those profile results would be confirmed. Mr. Gregson replied that the wells were sampled this week and results are expected shortly. Mr. Hugus stressed the importance of finding the toe of the plume because it could affect the response action, and he urged the Guard to bring the team a "final answer" as soon as possible. Mr. Gregson assured Mr. Hugus that nobody wants information on the extent of contamination more than the IAGWSP does, and it is working toward getting that answer.

Dr. Stahl referred to the map and asked whether the contour line for perchlorate would be redrawn, given the detections at MW-214 and MW-74. Mr. Gregson replied that MW-214 was nondetect for perchlorate in the first sampling round, while the second round showed a 0.6-ppb perchlorate detection, which might cause the contour line to be extended a little bit. He also said that it looks as though the contour line is drawn correctly around MW-74, which is located within the contour that includes perchlorate concentrations from greater than nondetect to less than 1.5 ppb.

Dr. Stahl then asked whether the depth of the detection at MW-258 is in line with the Demo 1 plume. Mr. Gregson replied that the detection occurred at a depth of 36 to 46 feet, which does correspond to the current plume depth at that location.

Dr. Dahmani inquired about using the model to try to predict where the plume might be, based on travel times of contaminants. Mr. Gregson said that he thinks that has been done, and the current plume depiction is consistent with the travel times. Mr. Applebee of AMEC added that with every hole thatís drilled, more is learned about the geology and its effect on travel times and flow paths. He then stated that the model that was calibrated previously is no longer valid, and as part of the feasibility study thatís about to be restarted, the model is going to be updated and recalibrated to better predict travel times. He also mentioned that the previous travel time estimate was short of where the contamination actually is being seen.

Mr. Borci noted that the old model was fairly well calibrated in terms of the extent of RDX contamination, but was "not even close for perchlorate," and thatís the discrepancy that needs to be resolved. Mr. Applebee added that conductivity changes having to do with the transition from outwash materials to moraine materials were not part of the model. He said that the perchlorate plume extends much farther out into that moraine material, where the flow is much different than what would have been predicted previously. Mr. Hugus asked Mr. Applebee to identify that transition line on the map. Mr. Applebee replied that the line is near Frank Perkins Road.

Central Impact Area Recent Unvalidated Detections

Mr. Gregson referred to MW-256, located in the eastern part of the Impact Area, and reported that no RDX was detected in profile sampling, but 2,6-DNT was detected in one interval at a concentration of 0.27 ppb. He said that well screens would be set, after which it will be determined whether that detection is repeated in the well itself. Mr. Gregson then referred to MW-249 and reported that RDX was detected at 0.56 ppb, TNT was detected at 0.41 ppb, and the well tested nondetect for perchlorate. He also said that the next drilling site in the Central Impact Area is CIAP-27, on Pocasset Sandwich Road, at a location downgradient of MW-205.

Mr. Hugus brought up the subject of the detection that occurred recently in a well near the Cape Cod Canal. Mr. Gregson noted that that was a perchlorate detection, at 6 ppb. He also said that the well was screened from the water table to depth, and based on particle backtracking, the source of that contamination could be anywhere from the well itself back to a position in the northwest part of the Impact Area. Mr. Gregson stated that the IAGWSP is working with EPA and DEP on a plan to conduct additional investigations in that area in order to try to determine the extent and source of that contamination. Mr. Hugus said that he thinks itís important for the IART to follow up on this detection, which could possibly turn out to be a plume. He also said that he finds this particular detection to be disturbing because it appears to have traveled a great distance, and he wants to know why that happened, and whether the same travel distance might apply to other plumes on the base. Mr. Hugus said that at next monthís IART meeting he would like to hear more about this northwest area.

Southeast Ranges Recent Unvalidated Detections

Mr. Gregson showed a map entitled "Southeast Ranges Perchlorate Plume Recent Detections," and reported that MW-247 had a perchlorate detection of 5.4 ppb and an RDX detection of 0.9 ppb in the deep screen, and a perchlorate detection of 0.5 ppb in the shallow screen Ė detections that are consistent with those seen in profile sampling. He also reported that MW-250 had perchlorate detections of 7 ppb in the shallow screen and 3.1 ppb in the deep screen, and RDX detections of 0.5 ppb and 0.3 ppb.

Mr. Hugus said that he thinks itís time to discuss what should be done to stop the flow of "toxic groundwater" from this area into Snake Pond. Mr. Gregson stated that that is a priority for the IAGWSP, which is trying to gather information as quickly as possible in terms of the position, extent, and width of the plume.

Mr. Hugus asked whether the Guard is committed to any schedule with respect to this plume. Mr. Borci replied that there is a schedule for workplans pertaining to further definition of the plume. He also noted that thereís been discussion, at the IART and elsewhere, about the possibility of conducting some type of interim action, but part of the problem is that there are a number of areas of contamination coming off the Southeast Ranges. Mr. Borci said that EPA has been waiting for well results and for a more accurate representation of the plume to be drawn so that decisions can be made regarding how to address the plume without affecting other areas of contamination. He also confirmed that the Southeast Ranges area is a top concern for EPA as well.

Mr. Hugus asked if itís correct that any interim action taken on this plume would be voluntary on the part of the IAGWSP, and not mandated by a schedule. Mr. Borci replied that right now there is no enforceable milestone for submittal of an RRA/RAM plan for the Southeast Ranges, but there are enforceable schedules for the investigation. He also said that the Guard, as the principal respondent, needs to propose these actions. EPA prefers to use enforcement as a last resort. Mr. Borci said that heís been hearing for a while now that the IAGWSP is looking at this issue and EPA wants to allow the chance for the Guard to do that. However, EPA shares Mr. Hugusís concern about moving the process along.

Mr. Gonser stated that the Southeast Ranges is one of the IAGWSPís priority areas, and heís asked his staff to look at how quickly progress can be made there. He also noted, however, that itís a more complicated area than Demo 1 in that it involves multiple source areas and little wisps of contamination here and there, making it more difficult to move forward with an interim action with some assurance that itís likely to be the final action. He said that the IAGWSP is looking at what can be done "sooner rather than later, that makes sense in the long-term picture."

Mr. Hugus emphasized his belief that this is an urgent situation, given the plumeís proximity to a recreational pond and a residential area in Sandwich. He said that month-to-month waiting for well results seems to be taking far too long, while nothing is being done to stop the plume, and he is urging the IAGWSP to do something to stop that pollution.

Dr. Stahl inquired about the timeframe when the plume is expected to reach Snake Pond. Mr. Borci replied that RDX, but not perchlorate, has been detected at MW-171, which is located on the spit in the northern part of the pond. He noted that itís not really known how many different areas of contamination there are, or what the disposal history is; however, based on the speed at which perchlorate travels, the assumption is that it would be in the vicinity. He also mentioned the Guardís effort to look for perchlorate by conducting diffusion bag sampling in the northern part of the pond, although there were some problems due to the presence of humic acids and other interferences. Nevertheless, there might be ways to work around these problems. Mr. Borci said that he would hope that one objective of the investigation workplans will be to answer the question of "where is perchlorate in the vicinity of the pond."

Dr. Stahl suggested that humic acids in the pond might make a suitable anaerobic environment thatís conducive to significant degradation. He also said, however, that children swim in the pond, which means that the possibility of perchlorate in the pond is of particular concern. Mr. Borci said that he thinks that the potential for an anaerobic environment is limited because flow through the pond system is so great. He then reported that the Guard conducts biweekly sampling at the pond during the swimming season, and there have been no detections of perchlorate. He also noted that dermal absorption of perchlorate is thought to be a less toxic exposure route than ingestion. Mr. Borci stated that EPA continues to ask the Guard to look for ways to move the investigation along as quickly as possible and to offer solutions.

Dr. Dahmani asked whether direct-push techniques had ever been used in the area near the pond. Mr. Gregson replied that wells in that area were installed with a geo-probe type of rig. He also noted that the IAGWSP had the U.S. Geological Survey (USGS) install some hand-driven shallow drive-points in the northern part of the pond. Dr. Dahmani said that heís interested in knowing whether profile samples were taken as the wells were being installed. Mr. Gregson replied that he believes that profile sampling was conducted, and information from that sampling was used to set the well screens. He also stated that RDX, but not perchlorate, has been detected at depth in MW-171, and the question remains "as to whether something at that depth at that location would upwell into the flow, or would underflow the pond."

Mr. Borci advised the Guard to utilize the services of USGS as it is putting together workplans for future work in and around this site. He said that the USGS would lend a great deal of credibility and expertise, especially with respect to this flow-through pond area, and he thinks that the Guard should look for direct and significant involvement from USGS. Mr. Gregson agreed, and noted that the Guard has had the USGS conduct both diffusion sampling and drive-point sampling in this area. He added that the Guard would continue to use USGSís expertise on groundwater/pond flow interactions on the Upper Cape.

Mr. Hugus said that heíd like to take this opportunity to urge EPA to set an enforceable milestone date for cleanup of the Southeast Ranges plume, as he thinks that the lack of action has gone on for too long.

Agenda Item #6. Open Discussion/Other Issues

Contained Detonation Chamber Update

Mr. Gregson stated that 10,100 items have been destroyed in the contained detonation chamber (CDC), and 9,668 remaining items are awaiting destruction, most of which are 20-mm projectiles. He also noted that itís required that the CDC be demobilized from the site in order to fulfill a prior commitment at another location. However, itís expected that the CDC will return to MMR in early to mid April, when the remaining items will be destroyed.

Review Action Items

The action items from the meeting were reviewed, and can be found listed at the beginning of these minutes.

Agenda Item #7. Agenda Planning

Mr. Murphy led the group in a discussion about future agenda items, which also are listed at the beginning of these minutes.

Mr. Hugus asked whether EPA had received any IART membership applications from Bourne residents. Mr. Murphy replied that a total of four applications, including the one from Robert Mullenix, have been submitted. Mr. Hugus asked if itís correct that Mr. Mullenix had applied again. Mr. Murphy explained that Mr. Mullenixís original application is still pending, as Mr. Varney had decided to solicit additional applications before making a final determination. Mr. Murphy also noted that itís anticipated that IART members would have the chance to review the applications prior to the next meeting, when the applicants will introduce themselves to team members and state their reasons for wanting to join the team. Ms. Crocker mentioned that the Bourne selectmen are meeting this evening to select two applicants that they would recommend for IART membership.

Agenda Item #8. Adjourn.

Mr. Murphy stated that the IART would meet next on March 25, 2003 at the Bourne Best Western. He then adjourned the meeting at 7:50 p.m.

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