Impact Area Review Team

River River Drops of rain on a leaf

Impact Area Review Team
Bourne Best Western
January 28, 2003
6:00 Ė 9:00 p.m.

Meeting Minutes

Members:

Organization:

Telephone:

E-Mail:

Hap Gonser

IAGWSP

508-968-5636

 

Ben Gregson

IAGWSP

508-968-5821

Ben.gregson@ma.ngb.army.mil

Mike Minior

AFCEE/MMR

508-968-4670

 

Todd Borci

US EPA

617-918-1358

Borci.todd@epa.gov

Bill Walsh-Rogalski

US EPA

   

Margery Adams

US EPA

617-918-1733

Adams.margery@epa.gov

Len Pinaud

MA DEP

508-946-2871

leonard.pinaud@state.ma.us

Ellie Grillo

MA DEP

508-946-2866

Ellie.grillo@state.ma.us

Tom Cambareri

IART/CCC

   

Dick Judge

IART/CAC/Sandwich

508-833-0532

Judges@cape.com

Evelyn Hayes

IART/Yarmouth

508-362-1785

Truhayes@msn.com

Joel Feigenbaum

IART/ABC/PCT/Sandwich

508-833-0144

Joelf@cape.com

Janet Pepin

IART/Falmouth

508-548-8182

Jpepin1@capecod.net

Richard Hugus

IART/ABC/Falmouth

508-540-6034

Rhugus@cape.com

Peter Schlesinger

IART/Sandwich

508-540-9900

Pschles@adelphia.net

Jim Stahl

TOSC

   

Amine Dahmani

TOSC/UCONN

860-486-2781

Adahmani@evi.uconn.edu

       

Facilitator:

Organization:

Telephone:

E-Mail:

Jim Murphy

US EPA

617-918-1028

Murphy.jim@epa.gov

       

Attendees:

Organization:

Telephone:

E-Mail:

Tina Dolen

IAGWSP

508-968-5629

Tina.dolen@ma.ngb.army.mil

Pam Richardson

IAGWSP

508-968-5630

 

Dan Epright

Cape Cod Air Force Station

508-968-7327

Dan.epright@capecod.af.mil

Betsy Higgins

US EPA

   

Meghan Cassidy

US EPA

617-918-1387

Cassidy.meghan@epa.gov

Jane Dolan

US EPA

617-918-1272

Dolan.jane@epa.gov

Kevin Hood

TOSC/UCONN

860-486-2546

 

Millie Garcia-Surette

MA DEP

508-946-2727

 

Justin Mierz

MDPH

617-624-5757

Justin.meriz@state.ma.us

Robert Mullennix

Bourne resident

508-946-7385

 

Patrick Skelly

Bourne resident

   

George Seaver

CCA

   

Minos Gordy

PACERS

508-775-2839

Minost@attbi.com

Charles F. Ryberg

PACERS

508-759-3680

Cmryberg@aol.com

Ray Pool

PACERS

508-747-6463

Barney@mymailstation.com

Jean Crocker

CAC/STRONG

508-428-4283

 

Melissa Mills

AmeriCorps Ė Cape Cod

508-563-9589

Mbmills_4@yahool.com

Michelle Lemmon

AmeriCorps Ė Cape Cod

508-563-9589

 

Kevin Dennehy

Cape Cod Times

508-888-5454

Kdennehy@capecodonline.com

Kim Harriz

AMEC

 

Kim.harriz@amec.com

Rob Clemens

AMEC

978-682-9090

Robert.clemens@amec.com

Mark Applebee

AMEC

   

Katherine Weeks

AMEC

 

Katherine.weeks@amec.com

Steve Denahan

Ellis Environmental Group

352-332-3888

Sdenahan@ellisenv.com

David Cobb

Envirogen

   

Rick Carr

STL

781-455-0653

Rcarr@stl-inc.com

Kris Curley

Guild

508-968-5626

Kristina.curley@ma.ngb.army.mil

Lori Boghdan

CH2M HILL

508-968-5628

Lori.boghdan@ma.ngb.army.mil

Jennifer Washburn

CH2M HILL

508-968-5631

Jennifer.washburn@ma.ngb.army.mil

Jane Moran

CH2M HILL

508-759-9114

Jmoran1@ch2m.com

Action Items:

  1. Mr. Schlesinger requests that the Impact Area Review Team (IART) be provided with copies of the fluidized bed reactor (FBR) study referenced in the Demolition Area 1 Rapid Response Action/Release Abatement Measure (RRA/RAM) plan for groundwater.
  2. The U.S. Environmental Protection Agency (EPA) will notify IART members via e-mail regarding how to comment on recent EPA guidance pertaining to perchlorate.
  3. Mr. Judge requests that Henry Byers (rather than Dale Young) address the IART on behalf of the Natural Resources Trustee Council (NRTC).
  4. Mr. Murphy will forward Ms. Hayes's request that the IART be provided with EPA's acceptance criteria for IART membership applicants.
  5. Dr. Feigenbaum asks that Mr. Murphy draft a letter, on behalf of the IART, to urge Robert Varney of EPA to attend a near-future IART meeting.
  6. Dr. Feigenbaum recommends that a letter be sent to Secretary of Environmental Affairs Ellen Roy, inviting her to a future IART meeting.
  7. The Impact Area Groundwater Study Program (IAGWSP) office will notify the Upper Cape Regional Technical School about the perchlorate detection that occurred in the nearby U.S. Army Corps of Engineers (USACE) well.
  8. EPA requests that future maps depicting updated zones of contribution (ZOCs) for the Upper Cape Water Cooperative production wells be provided to the IART. The Massachusetts Department of Environmental Protection (DEP) agreed to provide, to those team members requesting it, modeling information regarding those ZOCs.
  9. Dr. Feigenbaum suggested that Dr. Dahmani provide the IAGWSP with a list of specific questions he'd like answered as part of a future agenda topic on modeling, which was requested by the team.

Future Agenda Items:

  • Gun and Mortar Firing Positions Workplans
  • Fate and Transport Presentation (proposed for March 24, 2003)
  • Demolition Area 1 RRA/RAM for Soil (February 25, 2003)
  • Update on the Programmatic Agreement being Pursued by MMR with Respect to Cultural Resource Surveys
  • Presentation to Answer Questions about Modeling

Handouts Distributed at Meeting:

  1. 1/22/03 EPA Memo re: Status of EPAís Interim Assessment Guidance for Perchlorate
  2. Presentation handout: Demolition Area 1 Groundwater Interim Action
  3. IAGWSP fact sheet: January 2003 Ė Demolition Area 1 (with map attached)
  4. Information sheet: Demolition Area 1 (Demo 1)
  5. Rapid Response Action/Release Abatement Measure (RRA/RAM) Schedule Ė Demo 1 Groundwater Operable Unit
  6. Notice of public comment period for draft RRA/RAM for Demo 1 Groundwater Operable Unit
  7. Responses to Action Items from the December 10, 2002 Impact Area Review Team Meeting Ė Revised as of January 28, 2003
  8. Presentation handout: Investigation Update
  9. Data Tables
  10. Groundwater Program Update / December 2002 Ė January 2003

Agenda Item #1. Welcome, Review Draft Agenda, Approval of December 10, 2002

Meeting Minutes

Mr. Murphy convened the meeting at 6:05 p.m. and the IART members introduced themselves. Mr. Gonser noted that heís been assigned as interim program manager of the IAGWSP, and a permanent civilian program manager is expected to be hired in March or April.

Mr. Murphy reviewed the agenda and noted that as follow-up to the Demolition Area 1 (Demo 1) posterboard session that occurred just before the meeting, the Demo 1 agenda item will be discussed prior to the review of action items from last monthís meeting, which typically occurs closer to the beginning of the agenda.

Mr. Murphy asked if there were any changes or additions to the December 10, 2002 IART meeting minutes. No changes were offered and the minutes were approved as written.

Agenda Item #2. Late-Breaking News

Mr. Walsh-Rogalski announced that EPA Headquarters recently released a document called "Status of EPAís Interim Assessment Guidance on Perchlorate." He then noted that in 1992 EPA issued a provisional reference dose (RfD) of 4 parts per billion (ppb) for perchlorate. He explained that an RfD is the amount that EPA considers not harmful for an individual to ingest over a lifetime, based on a daily intake. In 1995, EPAís Office of Research and Development was asked to look at that RfD again, after which it was changed to 18 ppb. Since that time, EPA has seen additional information regarding exposure pathways that would be the most problematic for perchlorate, that is, "neuro-developmental toxicity for in-utero fetuses." The Department of Defense (DoD) and EPA conducted a host of studies during 2000 and 2001. In 2002 EPA issued for external peer review a draft document, which already had undergone internal peer review, and which summarized all the studies and proposed an RfD that would translate to a drinking water equivalency level of 1 ppb.

Mr. Walsh-Rogalski noted that while the external peer review isnít yet complete, thereís been a lot of controversy Ė generated primarily by parties who would be conducting cleanups Ė around the 1 ppb number. Therefore, EPA Headquarters decided that it should issue some clear guidance to the regions with respect to which numbers should be used. The new guidance document states that until an RfD is finalized, the 1999 EPA memorandum, which notes a 4-18 ppb range, should be followed with respect to perchlorate cleanup decisions. Mr. Walsh-Rogalski said that his office is trying to sort out what this means now and in the future in terms of cleanup at the Massachusetts Military Reservation (MMR).

Ms. Hayes asked if itís correct that the cleanup program should immediately begin using a 4-18 ppb range. Mr. Walsh-Rogalski replied that the guidance document states that as a general rule one should be guided by the 1999 policy, which noted a 4-18 ppb range. He also said, however, that the guidance document states that in site-specific instances, the regions might want to depart from that range, but shouldnít do so without first checking in with EPA Headquarters.

Mr. Gregson asked whether thereís any information on when the new RfD will be issued. Mr. Walsh-Rogalski replied that there is not, and mentioned that thereís been some talk about going to an outside third party for evaluation, which he believes would be a six-month process. He also said that his guess is that it would be on the order of one year before the new RfD is finalized.

Mr. Judge questioned whether the new guidance document mentioned child exposure pathways. He also inquired about measures that would allow reexamination of decisions based on a 4-18 ppb range, in the event that the numbers change. Mr. Walsh-Rogalski replied that, unlike the Superfund program, which has a fairly defined process for reevaluating decisions, the Safe Drinking Water Act (SDWA) would be "very flexible" in that regard. He also said that he thinks that EPA and the National Guard Bureau (NGB) should discuss whether the NGB wants to make decisions that would accommodate cleanups that look forward to a 1 ppb cleanup number, which EPA would require should that turn out to be the final number.

Mr. Walsh-Rogalski then stated that the reading heís done suggests that exposure by ingestion, rather than dermal and inhalation exposures, is the primary concern. He also said that the RfD takes child exposures into account; the 4-18 ppb number doesnít have to be adjusted for child exposure. Mr. Walsh-Rogalski further noted that the document includes a footnote that the suggestions have carefully considered the lower end of the 4-18 ppb range in light of new data that suggest that an in utero fetus could be at risk. Mr. Judge said, "so children arenít necessarily mentioned there." Mr. Walsh-Rogalski replied that EPA Headquarters looked at the fact that "children tend to be more sensitive to certain things" and concluded that the numbers that were derived donít need to be adjusted for children.

Mr. Judge asked whether it was just the exposure pathway for pregnant women that led to the change "from 18 to 1" ppb. Mr. Walsh-Rogalski replied that the studies that were done focused on iodine uptake, and pregnant women and women of childbearing age were identified as the most sensitive sub-population. He also said that he believes that other risks, among populations that arenít as sensitive, were identified and taken into account, and added, "but by capturing that as the most sensitive population, youíre safe with respect to less sensitive populations." Mr. Judge asked whether the document specifically states that the 4-18 ppb range sufficiently covers pregnant women and women of childbearing age. Mr. Walsh-Rogalski replied that he doesnít know whether it does or not.

Mr. Gonser noted that some copies of the "Status of EPAís Interim Assessment Guidance for Perchlorate" document are available this evening, and the last sentence of that document deals with the issue thatís of particular concern to Mr. Judge.

Mr. Gonser also mentioned the issue of how to move forward, and noted that the IAGWSP is certainly concerned about being a steward of the federal dollar and doesnít want to waste money in any way. He said that the program would look toward "the best answer in the end, so we donít have to do things over again," and therefore it would be flexible with respect to designing and building systems that come as close as possible to achieving "whatever answer they come up with."

Mr. Schlesinger inquired about obtaining reports on the perchlorate studies that were conducted in 2000 and 2001. Mr. Walsh-Rogalski replied that the EPA document thatís currently out for external peer review, and can be found through a "Google" search on the web, refers to the actual studies and is itself very useful in terms of providing a good background on the development of the 1 ppb number.

Mr. Schlesinger then asked whether the recent guidance means that EPA is recommending that the Bourne Water District resume operating the production wells that it shut down. Mr. Walsh-Rogalski said that he doesnít think he can provide an answer to that right now. Mr. Schlesinger then asked whether the state would be using a more restrictive level. Mr. Pinaud noted that DEP received the EPA information only yesterday, and since then DEP and EPA risk assessors have been discussing the issue. He then said that as of today, the Massachusetts interim drinking water advice for perchlorate that DEP issued for the Town of Bourne in April 2002, which states that for sensitive receptors the drinking water concentration is 1 ppb, stands.

Mr. Hugus asked whether the individuals at EPA who made the decision regarding the guidance for perchlorate are the same ones who recently decided to lower the clean air standards. Mr. Walsh-Rogalski replied that he believes the decision was made at the highest levels of the organization. Mr. Hugus stated that, as a citizen, heíd like to convey the message to EPA Headquarters in Washington, D.C., that "we donít think that making standards lower is a good idea." He also asked Mr. Gonser to keep in mind that the first concern of Cape Codís citizens is not "saving federal dollars," but "protecting public health."

Ms. Pepin asked whether the iodine uptake studies were done on pregnant women. Mr. Walsh-Rogalski replied that the earlier studies were done on individuals with Gravesí disease, a thyroid condition that leads to hypothyroidism. The more recent studies, however, were done on rats, and an uncertainty factor was applied to the translation of rat numbers to human numbers.

Ms. Hayes requested a copy of the "Status of EPAís Interim Assessment Guidance for Perchlorate" document, and Ms. Dolen provided Mr. Gonser with a number of copies to distribute among the IART members.

Mr. Judge questioned whether the head of EPA would be held accountable in the event that this recent decision is found to have compromised public health. Mr. Walsh-Rogalski replied, "From a legal perspective, I donít think so Ė morally, maybeÖ" Mr. Judge asked whether "that personís boss" would then be held accountable. Mr. Walsh-Rogalski replied that heís "not here to defend Headquarters" as that is something he does not do. He also explained, however, that EPA makes decisions based on risk analyses all the time. These are always risk management decisions Ė not decisions to reduce risk to zero, but to identify an acceptable level of risk.

Mr. Judge asked whether members of the public could submit comments to the decision-makers at EPA regarding the recent perchlorate guidance document. Mr. Walsh-Rogalski replied that comments could be submitted, and added that he thinks the public would want to submit comments to those who came out with the recent guidance document, as opposed to those who wrote the external peer review document, which is more of a scientific document.

At this time, Mr. Cambareri requested that his name be added to the sign-in list for the December 10, 2002 IART meeting minutes.

Agenda Item #3. Demolition Area 1 RRA/RAM for Groundwater

Mr. Hill stated that this presentation kicks off the informal public comment period on the Demolition Area 1 (Demo 1) RRA/RAM plan for groundwater. He noted that individuals can comment on the plan this evening by speaking into one of the audience microphones, or they can provide comments through other mechanisms, including the IAGWSP web site, until February 11, 2003. Mr. Hill also mentioned that Mr. Applebee and Ms. Weeks are available to help answer questions after the presentation.

Mr. Hill noted that Demo 1 is a historic training range on Camp Edwards, where activities included the destruction of various types of unexploded ordnance (UXO), as well as training in the use of explosive ordnance. He showed an aerial photograph of the site, pointed out the "cratered area" at the bottom of the natural depression, and noted that the Armyís soil investigations have led to the discovery of a fair amount of explosives and other compounds in and around that depression. Mr. Hill reported that extensive geophysical surveys conducted at the site showed thousands of magnetic anomalies, most of which are interpreted to represent "kick-out" from demolition activities. He noted that thereís evidence that burning occurred at the site, which was a common disposal practice for items that were obsolete or had otherwise expired. In addition, from time to time the state police brought loads of fireworks to the site for burning. Mr. Hill stated that dissolution by rainfall resulted in the leaching of some of these compounds into the groundwater, where the contamination continues to migrate coincident with the regional groundwater flow, in a west/southwest direction.

Mr. Hill reported that to date, by the use of 91 monitoring wells in 33 locations, detectable contamination within the plume has been tracked 8000 feet downgradient. The IAGWSP is in the process of finishing that investigation and currently is drilling the third well of the farthest downgradient well fence. He noted that perchlorate was detected in profile samples at less than 0.5 ppb in the southernmost of those wells, monitoring well 252 (MW-252). He also reported that a first-time perchlorate detection occurred recently in the middle screen of MW-214, at a concentration of less than 1 ppb.

Mr. Hill then recounted the recent history of the Demo 1 project. He stated that in October 2001, coincident with the submittal of the Armyís Draft Demo Area 1 Feasibility Study document, field data were becoming available that indicated that contaminant concentrations in what was then thought to be the distal portion of the plume actually were increasing rather than diminishing. Also, it began to be recognized that perchlorate, in addition to Royal Demolition Explosive (RDX), was a constituent of concern at the Demo 1 plume. The Army, the regulators, and the IART reached consensus to suspend further work on the feasibility study until more complete delineation of the plume. As the delineation effort proceeded, field data showed perchlorate being detected farther and farther downgradient, and the Army became more attracted to the idea of an interim action for this plume.

Mr. Hill stated that by spring of 2002 the IAGWSP had proposed a number of locations where such an action might occur, and together with the regulators and the IART, two locations were selected. One location is in the vicinity of Frank Perkins Road, which more or less bisects the plume. That system is intended to head off the majority of the mass of the plume, which resides upgradient of Frank Perkins Road, and prevent it from migrating into the extensive wilderness area that lies to the west. The second location generally was intended to involve pumping at or near the toe of the plume, depending on where the investigation determined that toe to be. The RRA/RAM plan that was sent out to IART members last week notes that the proposal is for the downgradient portion of the interim action to occur along Pew Road.

Mr. Hill explained that the interim action is referred to as an RRA/RAM because it combines the term "Rapid Response Action" from the EPA administrative orders, with the term "Release Abatement Measure," from the Massachusetts Contingency Plan (MCP).

Mr. Hill noted that the practical considerations that went into selecting the two locations included ease of access, which is one of the main reasons why the systems are located along roadsides, and minimal ecological impacts, because construction would occur in areas that already had been impacted. He also noted that at the Pew Road location, thereís a symmetry to the plume that lends itself to capture by a single extraction well. Mr. Hill then stated that both locations would have stand-alone systems.

Mr. Hill reported that the Frank Perkins Road system will involve a single extraction well pumping approximately 200 gallons per minute (gpm), from which the extracted water will be piped to a treatment plant on the north side of the plume. That plant will involve the use of a fluidized bed reactor (FBR), which is a biologically active treatment vessel thatís been shown to be effective at destroying perchlorate as well as explosives. To address concerns about the reintroduction of alien bacteria into the aquifer, and as indicated by some treatability studies conducted on water from the Demo 1 plume, a carbon polishing unit will be added to the lag end of the treatment train in order to optimize efficiency of the plant. The treated water will be reintroduced to the aquifer at two reinjection wells Ė one on the north side and one on the south side of the plume. Mr. Hill stated that approximately 85% of the total plume mass resides upgradient of Frank Perkins Road; therefore, this component of the RRA/RAM is fully expected to become part of the final remedy selected after completion of the feasibility study.

Mr. Hill stated that perchlorate is the only plume constituent in the area of the proposed Pew Road system. He also reported that the Army is proposing to dovetail the remediation aspects of this component of the plan with some treatment technology evaluations aimed at better informing the feasibility study. These evaluations will look at different forms of granular activated carbon (GAC), as well as field testing of some ion exchange resins. Mr. Hill said that the Pew Road system would involve a single extraction well pumping at a rate of 100 gpm.

Mr. Hill also mentioned that while the RRA/RAM plan contains information about a fixed-foundation treatment plant, the IAGWSP also is looking into a technology that would lend some portability to the treatment plant such that it could be transported from extraction well to extraction well. He noted that this is another aspect that will be considered in conjunction with the Pew Road component of the RRA/RAM plan.

Mr. Hill then showed a schedule for the RRA/RAM plan and noted that because implications of the research and development aspects of the Pew Road component are a little bit uncertain at this point, the schedule speaks primarily to the Frank Perkins Road component. He noted that barring any show-stopping issues, itís expected that the RRA/RAM plan should be finalized by the end of April 2003, and that construction should start in June 2003, with system start-up occurring in November 2003. Mr. Hill said that itís thought that the schedule for the Pew Road component will lag by a number of months, but that there wonít be an extensive separation in the schedules.

Discussion

Mr. Walsh-Rogalski asked Mr. Hill to identify where the movable remedy would be implemented. Mr. Hill referred to the map and pointed out the treatment plant location. He also explained that rather than a fixed foundation, the idea would be a treatment plant thatís skid-mounted on a concrete pad, with the capability of being moved to different extraction locations. Mr. Gonser added that if standards change, or if the situation changes, a portable system would provide the flexibility to do whatís required.

Mr. Walsh-Rogalski also noted that heís curious about Mr. Hillís having mentioned "that this was a U.S. Army presentation," when the cleanup is an NGB project. Mr. Gonser explained that, as discussed with Mr. Varney last week, the Army is taking a more active role in the program and "managing it in response for itís subordinate elements," which are all part of the Army. Mr. Walsh-Rogalski noted that the NGB has the legal obligation to do this work. Mr. Hill said that the new management structure is similar to whatís seen at the Installation Restoration Program (IRP), with the Air Force Center For Environmental Excellence (AFCEE) as the management entity for various staff members who are with the Air Guard.

Mr. Walsh-Rogalski replied that he believes that those parties are all respondents under the Federal Facilities Agreement (FFA). However, the Army is not a respondent under EPAís administrative orders (AOs). He then said that for the purpose of clarity and so that itís understood that the NGB is fulfilling its legal obligation, he thinks it would be useful if NGB work were labeled as such. He also suggested that the Armyís work is volunteer work because it is not "under any legal obligation to do anything here right now."

Ms. Pepin noted that it was still unclear to her which party was responsible for this presentation. Mr. Gonser explained that the Army and the Guard are both part of the Army program, and while there may be some legal distinction that needs to be worked out, the Demo 1 RRA/RAM plan is "everybodyís plan." Mr. Hill noted that he is with the NGB, heís the site manager for the Demo 1 site, and his local management is from the Army. Ms. Pepin inquired about the roles of Mr. Applebee and Ms. Weeks, whom Mr. Hill had mentioned at the beginning of his presentation. Mr. Hill replied that Mr. Applebee is AMECís project manager, and Ms. Weeks, who also works for AMEC, the IAGWSPís contractor, is involved in the ongoing technology evaluation project.

Ms. Pepin also asked about the proximity of base housing to the proposed Frank Perkins Road system. Mr. Hill replied that base housing is located south of Connery Avenue, and the Frank Perkins Road system would be about four or five miles north of Connery Avenue.

Ms. Pepin then inquired about the FBR technology. Mr. Hill replied that the FBR is considered a relatively innovative technology, and while there arenít many proven technologies that are effective in treating perchlorate, at some industrial sites in California FBR technology has been implemented specifically for the treatment of perchlorate, and been shown to be very effective. In addition, a treatability study was conducted on water from the Demo 1 plume, and the FBR proved to be effective. Mr. Hill then noted that the FBR also would degrade explosives, but not as quickly as it degrades perchlorate. Therefore, either a very large FBR would be required in order to accommodate a flow rate through the plant, or else follow-up GAC treatment would be required to address the remaining explosives contamination.

Ms. Weeks added that the study done at Frank Perkins Road involved water from MW-114, which had perchlorate concentrations of approximately 100 ppb and RDX concentrations of approximately 190 ppb. She noted that the FBR was very successful in totally destroying the perchlorate, and it reduced the RDX concentrations down to about 1 ppb.

Ms. Pepin also mentioned the concern about alien bacteria being reintroduced into the environment. Mr. Hill said that itís his understanding that the bacteria that degrade perchlorate exist in the natural environment, but itís a concentrated community of these bacteria that exists in the reactor vessels. Ms. Weeks agreed and explained that the bacteria are referred to as "alien" because they would be within the FBR and then reintroduced into the environment. She assured the group that these bacteria could be found anywhere Ė no new bacteria are being manufactured or genetically engineered. She also said that the FBR probably will be "inoculated" with bacteria brought in from a wastewater treatment plant or a similar source. Ms. Pepin inquired about the names of the bacteria. Ms. Weeks named the following genera to which those bacterial species belong: Desulfovibrio, Enterobacter, Alcaligenes, Streptomyces, Clostridium, Rhodococcus, and Pseudomonas. She also said that sheís heard at conferences throughout the country that Dechloromonas and Dechlorosoma are best suited toward degrading perchlorate.

Ms. Pepin asked if itís correct that carbon polishing is expected to take care of any leftover bacteria. Mr. Hill clarified that a sand infiltration unit located between the two treatment media should knock out any residual bacteria that escape from the reactor vessel, while dissolved explosives compounds would sorb onto the carbon in the polishing unit.

Ms. Pepin asked Mr. Hill to explain why the schedule doesnít apply to the Pew Road component of the plan. Mr. Hill explained that the technology evaluations are going to build upon one another; therefore, itís premature to put a fixed schedule on this part of the plan until those study results are available. He also said that he considers the design of a compact portable treatment plant to be more of a "wildcard" in terms of affecting the schedule, than the treatment media evaluation would be.

Mr. Schlesinger noted that the RRA/RAM plan refers to an AMEC document called "Final Innovative Technology Evaluation Groundwater Study Treatability Study Summary Ė Fluidized Bed Reactor/Camp Edwards, MMR, Cape Cod/November 2002." He then asked if copies of this document could be made available to IART members. Mr. Hill replied that copies could be provided to the team, and he believes that copies already have been provided to the regulators. He also noted that that particular project was not a requirement under the administrative orders, but one that the IAGWSP has been doing out of its own volition, and, as such, itís been one of the first to suffer when another priority emerges.

Mr. Schlesinger asked whether information from the fate and transport study figures into the interim action at Demo 1. Mr. Hill noted that the main thrust of the fate and transport study has to do with leachability and the strength of source that results in groundwater contamination. While these concerns donít have immediate bearing on the interim action as such, they might have bearing on the feasibility study, which would look at cleanup within 10 years, and therefore be concerned with the residual source strength in the vadose zone following soil excavation.

Mr. Schlesinger also noted that the RRA/RAM document doesnít specifically say whether GAC will treat other contaminants of concern (COCs) in the Demo 1 plume, such as High Melting Explosive (HMX) and trinitrotoluene (TNT), which might not be completely degraded in the FBR. Mr. Hill replied that the COCs, if left long enough in the FBR, would be completely degraded there. The polishing unit, however, is added to the treatment train in order to expedite treatment of the COCs.

Mr. Schlesinger also noted that the RRA/RAM document mentions that steps would be taken to minimize problems with clogging of screens on the injection wells for the Frank Perkins Road system. He asked what those actions would be. Mr. Applebee replied that sand filtration, as well as ensuring that settling of fine particles occurs throughout the process, would be actions taken to help minimize any problems. He also noted that the injection wells could be back-washed during the process, but added that the full design of these components hasnít yet been completed.

Dr. Stahl asked Mr. Hill to repeat the information about RDX detections at MW-252. Mr. Hill replied that these were unvalidated profile detections in two intervals, at concentrations less than 1 ppb. Dr. Stahl inquired about the depths of these detections. Mr. Applebee clarified that in fact these were perchlorate detections, not RDX, and they occurred at 6 feet below the water table and at 36 feet below the water table, at concentrations less than 0.5 ppb. Dr. Stahl noted that the figure indicates that RDX was detected there. Mr. Hill acknowledged that this was an error on the figure.

Dr. Stahl said that he assumes that a model was run with the proposed treatment regime, and he inquired about drawback beyond Frank Perkins Road. Mr. Hill replied that using the road as a benchmark, and pumping at 200 gpm, the capture zone would extend downgradient as well as upgradient some distance. Dr. Stahl noted that he didnít see any capture zone depictions in the RRA/RAM document, and he wonders about that because the 2-ppb RDX plume extends a fair distance beyond Frank Perkins Road. Mr. Hill mentioned that the person who did most of the modeling is in attendance tonight, should Dr. Stahl want to ask more specific questions.

Dr. Stahl also asked whether thereís been any discussion about tying the Pew Road system into the FBR at Frank Perkins Road system to remove perchlorate, if needed. Mr. Hill replied that while this approach is not out of the realm of possibility, it probably wouldnít be the first option. He said that the program is looking to determine what the best treatment medium is for the low concentrations of perchlorate being seen in the Demo 1 plume, and elsewhere on Camp Edwards.

Mr. Hugus remarked that only two extraction wells for a plume thatís 8000 feet long and 1000 feet wide doesnít seem like enough. Mr. Hill replied that this is an interim action and itís believed that those wells will be part of any ultimate remedy, which could involve additional extraction wells. He also said that once thereís concurrence that the plume delineation is complete, the process would resume through the feasibility study. He noted that the draft revised Demo 1 Feasibility Study is scheduled to be submitted in September 2003.

Mr. Hugus stated that from his point of view, an interim action is being implemented because it would have taken "forever" to get to a final action by going the full feasibility study route. He said that he it thinks that the current proposal "is really what weíre going to get," so he believes that the job should be done correctly now. Mr. Hugus reiterated that he thinks that two wells are inadequate for a plume of this size. Mr. Hill stated that the interim action is not intended to prejudge the ultimate remedy. Mr. Hugus questioned why it wouldnít make sense to try to make the interim action the ultimate remedy by installing enough extraction wells to take care of the problem. Mr. Hill noted that part of the feasibility study process involves soliciting input from other stakeholders, some of whom are more concerned about the habitat than the groundwater. He also said that there are many stresses on the aquifer and itís not as easy at it might seem to "start pumping lots of water."

Mr. Hugus said that his point is that he finds it unacceptable to put an extraction well upgradient of the toe of the plume because he thinks the entire plume needs to be captured. Mr. Hill explained that an extraction well located in the midst of the advection front of the plume, where fingering typically occurs, would mean pumping a lot of clean water along with the contaminant. In areas like that, with the concentrations that are being seen there, an extraction well would end up moving a lot of water, but with nothing detectable in the influent at the treatment plant.

Ms. Hayes inquired about Mr. Hillís level of confidence that the RRA/RAM schedule can be met. Mr. Hill replied that while itís very aggressive, and things would have to proceed swiftly in order to accommodate it, the schedule is achievable.

Mr. Judge asked how much of the plume is expected to be lost beyond Pew Road. Mr. Hill noted that while the definition of the plume hasnít yet been determined, his "total guess" is that it would be less than 1% of the mass. He also noted that more than 85% of the mass occurs upgradient of Frank Perkins Road. Mr. Judge stated that no matter how small the percentage thatís lost, it should be reported to the NRTC so that a proper assessment of damages can be done.

Mr. Judge also said that heís interested in learning more about portable treatment plants, and noted that he was quite involved in overcoming resistance to securing the use of a portable contained detonation chamber (CDC) at MMR. He said that heíd like to know about the effectiveness of a portable system, as well as the money-saving aspects of such a system. He also acknowledged, however, that a portable system wouldnít be appropriate for plumes with extended cleanup timeframes.

Dr. Feigenbaum said that he thinks that this project getting started is a "pretty important and auspices occasion," especially given all the past acrimony and argument over this interim action. He offered his congratulations to the Guard and to the agencies. He also acknowledged the Armyís recent involvement and said that he thinks itís important that the Army not "slip and slide in and out of this project" whenever it wants to. He stated that if the Army can absorb the role of respondent, he thinks it should do so formally so that itís understood where everybody stands.

Dr. Feigenbaum then said that he sees no evidence that extraction well D1-1 (EW-D1-1) would span the entire plume. Mr. Hill replied that the proposed pumping rate at that well would be adequate to capture the width of the plume, but not at Frank Perkins Road. The capture zone wouldnít propagate north/south at the longitude of Frank Perkins Road, but would capture the width some distance upgradient of the road. Dr. Feigenbaum suggested that it might be a good idea to "get those extraction wells outside to kind of pinch the plume." Mr. Hill noted that the reinjection wells are designed with that in mind. Dr. Feigenbaum asked when the team could expect to see some specifics and modeling. Mr. Hill replied that the IAGWSP would be sharing information with the team as progress is made. Dr. Feigenbaum also asked if, in addition to the design work, AMEC would be doing the construction work as well. Mr. Hill replied that it would.

Dr. Feigenbaum then commented that it seems like the leading edge has just been forgotten. Mr. Hill disagreed with that opinion, and also said that pumping at a leading edge thatís defined at the detection limit would mean being "overwhelmed by clean water." He also mentioned that perchlorate was detected in MW-225, and while itís not known exactly how far downgradient the perchlorate is, that is a wild area that doesnít lend itself to drilling activities, which is why further drilling was done along the power line. He then noted that the perchlorate detection at MW-252 occurred in a profile sample, not a bona fide monitoring well sample.

Dr. Feigenbaum questioned whether in fact the leading edge would be located. Mr. Hill replied that the IAGWSP and the agencies need to come to concurrence on whether to proceed now with the feasibility study or continue the effort to define the leading edge. He also noted that his opinion is that the plume is defined enough to move forward. Dr. Feigenbaum pointed out that a year ago it was argued that an interim action shouldnít be taken until the leading edge is defined, and now the interim action is moving forward and "we may give up on ever nailing down the leading edge."

Mr. Pinaud noted that the Frank Perkins Road system involves a conceptual piping layout on a tank trail. He then asked whether that trail is a hardened surface. Mr. Hill replied that it is not. Mr. Pinaud recommended that consideration be given to putting that piping run on Frank Perkins Road, where heavy vehicles arenít allowed to drive.

Mr. Pinaud asked if itís correct that thereís no schedule at this point for implementation of a toe extraction system, whether itís at Pew Road or some other location. Mr. Hill replied that installation of an extraction well will be a precursor activity, and the type of treatment facility to which that well is plumbed will be the subject of the technology evaluations. He noted that that extraction well will be used as a source for water to run the ion exchange studies, and he mentioned that the carbon studies are intended to be conducted in a laboratory. Mr. Pinaud asked if itís correct that a treatment system might not be constructed for some time. Mr. Hill replied that it remains to be seen what the treatment system will contain and what it will look like.

Mr. Pinaud stated that DEP is concerned that the IAGWSP might be missing an opportunity to capture the plume down at the toe. Mr. Hill replied that he doesnít think that the opportunity would be lost. He noted that the road at the power line is "one intersection you can look at," and thereís another road downgradient, which might be considered, depending on how the cleanup standard issue is resolved. Mr. Pinaud asked when the regulators could expect to see a schedule for the treatability studies. Mr. Hill replied that the technology evaluation contract currently is being negotiated. Then, a schedule for the treatability studies will be developed, and from that a timeframe for follow-on activities will be inferred.

Mr. Pinaud asked whether thereís still a commitment from the Army to treat the toe of the plume. Mr. Hill replied that there is, but noted that itís uncertain at this time what the toe of the plume might be Ė for example, it might be a 4-ppb contour, or an 18-ppb contour. He also noted, however that under the MCP, treatment is evaluated to background, and the intention is to comply with the MCP as well as the AOs.

Mr. Borci noted that the estimated plume volume east of the Frank Perkins Road system, based on the perchlorate plume shell, is 691 million gallons. He said that this is a significant amount of contamination, and an almost equal amount exists downgradient of that point. He also stated that overall EPA thinks that the RRA/RAM is a quality plan, although there are some questions.

Mr. Borci then clarified that the Frank Perkins Road extraction well is not intended to be a cutoff well; therefore, itís expected that some contamination will pass beyond that well. He said that EPA also has questions about placement of a toe extraction well. And he mentioned delays because of the carbon tests, and noted that he has a report that compares costs for an FBR system versus a straight carbon system, which requires more frequent maintenance by way of carbon change-outs than the type of maintenance that an FBR system requires. Mr. Borci explained that itís being questioned whether itís really necessary to go through the technology evaluation, which might result in delays. He also said that the concept has been that the entire system, not just one part of it, would be turned on in November 2003.

Mr. Borci also made a point of noting that the feasibility study process is ongoing and although some people might "think that this is all youíre going to get," the AOs require that more robust remedies be proposed, including a remedy that addresses the problem within 10 years. He said that the Draft Demo 1 Feasibility Study for Groundwater should be coming out by the end of this year, and he asked the team members not to lose sight of the fact that theyíll be talking about the long-term remedy.

Dr. Dahmani stated that he thinks that pump-and-treat is the right approach for this plume. He also asked whether the FBR has been tested at the bench-scale level. Ms. Weeks replied that two sites where the FBR was tested are the Aerojet facility in Rancho Cordova, California, and the Longhorn Army Ammunition Plant in Karnack, Texas. She explained that at these sites very robust laboratory studies were conducted, the results of which were used to design full field-scale implementations. She also noted that FBR systems have been operating successfully for two or three years at these sites. Dr. Dahmani said that he expects that the system would be monitored and optimized. He also asked whether there would be future presentations about the system. Mr. Hill replied that that is the intention.

Mr. Cambareri asked whether there would be a future presentation on the modeling associated with these systems. Mr. Hill replied that this type of presentation would occur closer to design, when thereís better resolution on capture zones and the like. Mr. Cambareri also questioned whether a single 80-foot screened extraction well at Frank Perkins Road would draw evenly throughout the thickness of the plume. Mr. Hill replied that the system would be evaluated. He also noted that once pumping begins, system performance would be evaluated, as would any required or recommended modifications.

Dr. Stahl asked whether the capacity factor is being taken into account in terms of modeling and engineering. Mr. Hill replied that it is, and stated that the treatment plant will be designed with expandability in mind.

Dr. Feigenbaum noted that some issues are being framed in terms of "the Guard intent," but he thinks that the emphasis should go to "in accord with the administrative orders and the Safe Drinking Water Act, because thatís the guiding way for this project."

Mr. Dow asked whether thereís an interim action plan to deal with contaminated soil at the Demo 1 source area. Mr. Hill replied that there is, and noted that the RRA/RAM for Demo 1 Soil will be presented at next monthís IART meeting. Mr. Dow asked if itís correct that the groundwater and source area cleanups will occur more or less simultaneously. Mr. Hill replied that it is.

Ms. Crocker requested that every effort be made to drill no more than is needed and advisable, as she believes that a great deal of land throughout Camp Edwards already has been damaged unnecessarily. She also said that the perchlorate standards that have been used at MMR have seemed overly cautious to many people. She then questioned whether continuing to use a 1.5-ppb standard at MMR, rather than the 4-18 ppb range, wouldnít really be "an insubordination to the highest levels of the decision-makingÖ"

Mr. Seaver stated that perchlorateís status as a carcinogen is an issue that continues to be raised. He noted that the Cape Cod Times has referred to it as a carcinogen, and EPA frequently does too. He then noted that the National Institutes of Health (NIH) web site contains a report that lists about 1000 known and possible carcinogens, and perchlorate is not among them. He also noted that Dr. Zoeller of the Institute for Science and Interdisciplinary Studies at UMASS Amherst and Hampshire College, who was a member of the review committee that looked at interim standards for perchlorate, said, "Perchlorate is not a cancer-causing agentÖ" Mr. Seaver said that he thinks that the references in the literature and on the web that perchlorate is not a carcinogen should be respected.

Mr. Borci said that he wants to clarify that the Pew Road system is a 4-ppb remedy. He noted that the concentrations at the proposed extraction well location have been and are currently 3 ppb, and itís reasonable to assume that the area immediately upgradient has 4-ppb concentrations. Mr. Borci said that the question is whether the best location is based on technical practicability. He also said that he wouldnít want to hear two months from now that the design needs to be restructured toward a 4-ppb remedy, because "what you see in front of you does that." Mr. Walsh-Rogalski asked whether the IAGWSP also views the Pew Road system as a 4-ppb remedy. Mr. Gonser replied that he doesnít disagree with Mr. Borciís analysis. Mr. Walsh-Rogalski asked if itís correct that the public would be commenting on a remedy thatís not going to change, six months from now, for instance. Mr. Gonser replied that he wouldnít anticipate a change.

Mr. Skelly noted that an extraction well ahead of the toe would pull the contamination down towards it, and he thinks that the well should be installed at the proposed location because it would slow migration of the toe. He also suggested installing an injection well ahead of the toe to help reverse the flow of contamination.

Mr. Judge stated that right now it really isnít known where the toe of the plume is located. He said that if EPA ultimately establishes a 1-ppb standard for perchlorate, it would be very important to know where that toe is.

Mr. Schlesinger said that he finds it confusing that Mr. Borci and Mr. Walsh-Rogalski were talking about a 4-ppb solution, yet the state holds the program to a 1.5-ppb or 1-ppb standard for perchlorate. Mr. Borci clarified that DEP provided the Town of Bourne with specific guidance pertaining to the situation in the Monument Beach wellfield. He also explained that, as it currently stands, the interim action at Demo 1 is going to treat groundwater starting at 3 ppb for perchlorate. The technical issue that needs to be examined is whether moving the extraction well farther downgradient would mean pumping too much clean water. However, it should be understood that the interim action at Pew Road is designed to clean up to 4 ppb. He also noted that if the standard for perchlorate turns out to be 1 ppb, but that decision isnít made in time for the interim remedy, that issue would be addressed as part of the feasibility study process this fall. Mr. Gonser added that basically the point is that this is a good place to start for remedial action, with further discussion to occur during the feasibility study process.

Mr. Mullenix asked whether itís correct that the FBR is designed to treat perchlorate to a level of less than 1 ppb. Ms. Weeks confirmed that this is correct, but noted that itís not yet certain which type of treatment technology will be used at the toe.

Ms. Garcia-Surette asked whether sufficient funding had been programmed for whatever technology is chosen for the toe. Mr. Hill replied that the program has the necessary funding to implement both the Pew Road and the Frank Perkins Road components of the RRA/RAM. Mr. Gonser added that this project is the IAGWSPís priority.

Agenda Item #4. Review Responses to Action Items from December 10, 2002 IART Meeting

Mr. Murphy noted that rather than going to "Google" to find the EPA external peer review document on perchlorate, it would be better to go to www.epa.gov and use the search function at that site. He also said that comments on the interim perchlorate guidance could be referred to Marianne Horinko, the assistant administrator of EPAís Office of Solid Waste and Emergency Response. He further noted that he would e-mail to team members the contact information for Ms. Horinko. Mr. Murphy then asked if there were any comments on the responses to action items from the December 10, 2002 IART meeting.

Mr. Hugus referred to Action Item #2, and asked when the perchlorate plume at the Monument Beach area would be mapped. Mr. Gregson replied that while he canít provide a specific date, the IAGWSP is working on that plume map and today presented a version to EPA, DEP, and the Bourne Water Districtís consultant. Mr. Hugus indicated that he thinks itís very important that the public has a visual representation of that contamination, which led to the shutdown of a significant percentage of Bourneís water supply.

Mr. Hugus referred to Action Item #4, and asked whether the estimate of contaminated groundwater pertains to just the Central Impact Area plume or to all plumes associated with the Impact Area. Mr. Gregson clarified that the estimate pertains just to the Central Impact Area plume itself.

Mr. Hugus also referred to Action Item #11, his request that EPA Regional Administrator Robert Varney attend an IART meeting. He noted that last week Mr. Varney met privately with representatives of the Guard and the Army, and he feels that Mr. Varney also should hear the citizensí point of view on issues such as the Army auditís recommendation that the management structure of the IAGWSP needs to be changed. Mr. Murphy noted that he had conveyed Mr. Hugusís request to Mr. Varney, who initially planned to attend the March IART meeting. As it turns out, however, Mr. Varney canít make that meeting, but intends to attend another IART meeting in the near future.

Mr. Schlesinger noted that the estimate of contaminated groundwater in the Central Impact Area plumes refers only to RDX, but there are other COCs there that he believes should be included in that estimate. He also referred to Action Item #13 and asked why Mr. Mullenix was denied membership in the IART, and whether Mr. Mullenix would be able to apply again Ė and if so, when. Mr. Murphy replied that heís been directed by Mr. Varney to conduct an outreach effort to find citizens of Bourne who would be interested in being considered for membership on the IART. He noted that Mr. Mullenix had communicated to Mr. Varney the point that currently there is no citizen representation from Bourne, which is a void on the team. Mr. Murphy said that Mr. Mullenixís application for membership would be reconsidered along with any new applications that come in as a result of EPAís outreach effort.

Mr. Judge inquired about the nature of communication between Mr. Mullenix and Mr. Varney. Mr. Murphy said that Mr. Mullenix wrote to Mr. Varney, but he doesnít think that Mr. Varney has written back as yet. Mr. Judge explained that heís wondering whether the IART should write a letter to Mr. Varney to ask him to attend a future IART meeting. Mr. Murphy assured Mr. Judge that Mr. Varney intends to attend a future meeting. Mr. Judge asked that Mr. Murphy convey to Mr. Varney that he, and perhaps other members of the IART, are extremely disappointed that Mr. Varney didnít meet with the entire IART, rather than just those select parties with whom he met last week, when he "may not have gotten a balanced presentation." Mr. Murphy agreed to convey this message to Mr. Varney.

Mr. Judge also referred to Action Item #3, regarding the request for an update from the NRTC and stated, "Weíre looking for Bruce Leighton to come and do a presentation to this board here." He said that he thinks Dale Young is great, "but sheís not a voting member of the NRTC." Ms. Grillo clarified that the Commonwealth of Massachusetts is a trustee and co-lead on the NRTC because the Secretary of Environmental Affairs, which had been Bob Durand and is now Ellen Roy, is the trustee for the groundwater of the Commonwealth. She explained that Mr. Durand had designated Ms. Young, who is the director for NRTC activities for the Commonwealth, as his representative on the NRTC. Ms. Grillo confirmed that Ms. Young is a voting member and a co-lead on the NRTC. She further noted that the other co-lead, the Air Force, has taken on the administrative responsibilities for the NRTC, and Mr. Leighton was the first person designated with that responsibility.

Mr. Judge repeated his request for Mr. Leighton to address the IART, especially since Mr. Leighton is "in charge of the money end of the game." He said that the damages that are awarded by the NRTC will be used for environmental reclamation purposes on Cape Cod, and he thinks that that money will be in the billions of dollars, and could be used toward solving the problems that the Cape is having with nitrates in the water from septic systems.

Mr. Minior clarified that Mr. Leighton is not currently the designated trustee representative of the Secretary of the Air Force. He noted that Henry Byers has taken over that role at this time, while Mr. Leighton is fulfilling other duties in San Antonio, Texas. Mr. Minior also reported that yesterday the NRTC issued a news release containing information about some recent progress made at a meeting last week in terms of future activities the Council plans to undertake in order to resolve the Preliminary Assessment Screen (PAS) document by the end of this April.

Mr. Judge stated that he then wants Mr. Byers to update the IART on NRTC activities. He said that he thinks itís very important that the NRTC process be transparent to the public, especially with respect to considerations such as "what is a pollutant and what is not a pollutant" and "what is making the Cape whole and what is not."

Mr. Gregson referred back to Mr. Schlesingerís comment on Action Item #4, and explained that there arenít any mappable plumes for COCs other than RDX in the Central Impact Area. He also said that, as noted in the action item response, the IAGWSP is in the process of defining and mapping the extent of perchlorate contamination. He further noted that perchlorate is the only propellant thatís been detected there. Mr. Borci stated that the greatest extent of contamination at the Central Impact Area is from RDX. He also mentioned that the contaminated groundwater estimate from 2001, as noted in the action item response, would be updated at some point.

Ms. Hayes referred to Mr. Mullenixís request to join the IART, and asked whether it would be possible to ask Mr. Varney to provide the acceptance criteria he uses when considering new membership applicants. She explained that she thinks it would be appropriate for individuals who are interested in joining the team to at least know whether they are going to meet those criteria. She also said that she doesnít think itís good public relations to invite someone to volunteer to serve on the team and then reject him. Ms. Hayes said that if interested individuals were informed about the requirements for membership, no oneís time would be wasted. Mr. Murphy said that he would bring this request back to Mr. Varney. Ms. Hayes also asked if there had ever been an IART member from Bourne. Mr. Minior replied that the IART member from Bourne had died. Ms. Hayes repeated her request for the acceptance criteria so that "people donít waste their time or ours, and they donít face rejection inappropriately."

Mr. Cambareri stated that the previous representative from Bourne had been his friend, Dick Prince. He also said that he hadnít received the sampling results from the Bourne landfill monitoring wells. Mr. Murphy noted that those results were attached to the action item response document.

Mr. Cambareri then stated that calculating areas of contaminated groundwater could be "very objective science." He noted, for example, that while a 50-foot thick plume in a 100-foot thick aquifer might technically be the contaminated piece of aquifer, its presence there likely affects the availability of other parts of the aquifer for water supply. He mentioned the IRPís policy of offering water hookups to residents whose homes are within a certain buffer zone of a defined plume. Mr. Cambareri suggested that two calculations might be appropriate when looking at volume of contaminated water Ė the actual volume of contaminated water, and the volume of aquifer loss in terms of potential water supply.

Dr. Feigenbaum said that he thinks itís unacceptable that Mr. Varney hasnít met with the IART, and he wants Mr. Murphy to draft a letter asking him to do so. Mr. Murphy replied that he thinks it would be better if someone else wrote a letter. Dr. Feigenbaum asserted that as the facilitator of the IART, Mr. Murphy should write the letter. Mr. Murphy agreed to write the letter. Dr. Feigenbaum also remarked that he thinks it would be suitable to send a similar letter to Ms. Roy, Secretary of Environmental Affairs for the Commonwealth.

Mr. Gregson referred to the estimate of groundwater contamination noted in the 2001 Central Impact Area Groundwater Report and said that certain assumptions, which are detailed in that report, were made when arriving at that estimate. He explained that itís a complicated area in that it involves not just a single plume, but fingers and multiple areas of contamination.

Mr. Dow said that he thinks that at one point Russell Cookingham of Bourne was a member of the IART. Mr. Murphy replied that he thinks that Mr. Cookingham used to attend IART meetings frequently, but was not a member at the table.

Mr. Mullenix said that heíd like to thank everyone who supported his application for membership on the IART. He noted that heís lived in Bourne for 11 years, is committed to the town and its people, has a lot of friends there, and is active in the community. He also said that because of his background and education, heís often asked questions about activities occurring at the base.

Mr. Mullenix then said that Mr. Murphy called him this past spring and said that heíd heard that he (Mr. Mullenix) might make a good addition to the IART. Mr. Mullenix said that, at Mr. Murphyís suggestion, he attended a couple IART meetings to see if he might like to apply for membership. He noted that during those meetings there was discussion about the perchlorate issue, which directly affects the Town of Bourne and, specifically, affects the source of his own water supply. Mr. Mullenix said that he became more interested in IART membership, submitted his application in June, and recently was informed that his application has been rejected.

Mr. Mullenix also said that he appreciated the Cape Cod Times article regarding his situation, and he has since received a number of phone-calls from Bourne residents "offering their support and wondering what happened." He then said that at this point heís at a loss. He noted that heís asked Mr. Varney by letter why he was not accepted on the team, and still would like to know the rationale for that decision. Mr. Murphy said that he couldnít respond any more than to say that Mr. Mullenix will be getting a letter from Mr. Varney, in which he hopes Mr. Mullenix finds some satisfaction.

Mr. Schlesinger noted that when he wrote a letter asking to become a member of the IART, no one told him that other Sandwich residents were being solicited and he had to vie for the position. He said that this may be something new with the current EPA Regional Administrator, but it didnít occur when he applied for IART membership.

Agenda Item #5. Investigations Update

New Areas - Recent Detections

Mr. Gregson referred to a map entitled "Northwest Corner of MMR" and reported that perchlorate was detected in well 4036009, located on U.S. Army Corps of Engineers (USACE) property next to the Cape Cod Canal. He also pointed out the location of the nearby Schooner Pass well. He noted that initial sampling at well 4036009 showed a validated 5.3-ppb perchlorate detection, and follow-up sampling came back with a validated 6.1-ppb perchlorate detection. Mr. Gregson said that while itís not known where the screen is in well 4036009, a particle track from the bottom of that well ran back to the Central Impact Area. He also said, "if you take a particle track from the water table, itís right near the well," based on the modeling alone, a possible source of the perchlorate is somewhere between the well and the Central Impact Area. Mr. Gregson also reminded the group that the contaminant detected previously in the Schooner Pass well was RDX, while the contaminant detected in well 4036009 was perchlorate. He noted that his office is working with DEP and EPA to look at additional sampling locations in that area to get a better handle on the source of the perchlorate.

Mr. Cambareri asked if there are any plans to test the well at the Upper Cape Regional Technical School. Mr. Gregson replied that there are some mechanical problems with access to that well, and he believes that the plan is to take a closer look at the "95" series of wells shown on the map. He also noted, however, that there will be an effort to do a repair on the irrigation well at the school so that a sampled can be collected. Mr. Cambareri also asked Mr. Gregson to identify the red dot to the east on the map. Mr. Gregson identified that location as gun position 16 (GP-16), where perchlorate also has been detected.

Mr. Hugus noted that contamination has now been detected at two different locations in this area, and he thinks that anyone on private water supply there should be advised not to use that supply, and should be provided with an alternate water supply. He noted that the residents of the Schooner Pass development continue to use water from their supply well.

Mr. Judge asked if itís correct that the Upper Cape Regional Technical Schoolís irrigation system draws water from that area. Mr. Gregson said that he believes that the schoolís irrigation well is broken down and hasnít been used in a while. He also noted that for drinking water supply, the school is on town water. Mr. Judge said that heís glad to hear that the schoolís irrigation system isnít working because otherwise it might be pumping up that contamination and dispensing it on the grass. He then asked whether the school was notified of the recent nearby perchlorate detection. Mr. Gregson replied that heís not sure, but will make certain that the school is informed. Mr. Judge also inquired about the party responsible for keeping the Schooner Pass residents informed about detections in their well. Mr. Gregson replied that as provider of water supply for that community, itís up to the water supply manager at Schooner Pass to keep his customers informed.

Mr. Murphy asked Mr. Gregson to say who was notified of the perchlorate detection in well 4036009. Mr. Gregson replied that his office notified the Town of Bourne, the Bourne Board of Health, and the USACE.

Mr. Schlesinger inquired about the possibility of installing a monitoring well upgradient of well 4036009 Ė perhaps near the base boundary. Mr. Gregson replied that upgradient locations on the base boundary, along the particle track, are being considered. He also noted that this would be part of a larger plan that the IAGWSP, along with the agencies, is working on. Mr. Schlesinger also asked whether information about the detection would be in the newspapers. Mr. Gregson replied a news release was issued last Friday.

Dr. Dahmani said that in order to have some comfort about the accuracy of the particle tracking, he thinks the team should see information about any sensitivity analyses conducted by the modeler with respect to those particle tracks. Mr. Gregson noted that thereís a higher level of confidence in particle tracks in that area of the base because itís off the edge of the mound, where groundwater flow direction doesnít fluctuate as much as it does near the top of the mound. Dr. Dahmani stated that he thinks it would benefit the whole team to understand the limitations associated with the depictions that are modeled. He said that while he doesnít think a great deal of detail is necessary, he thinks that it would be good to know "that you have done this, youíve evaluated it, youíve calibrated it, that you have done the sensitivity analysis, and based on that, this is what you have come up with." Mr. Gregson said that he would contact the AMEC modelers for this information.

Mr. Gregson then referred to a map entitled "Northeast MMR Boundary" and reported that RDX was detected in profile samples taken at MW-254, formerly known as KP-2. He explained that MW-254 was drilled as an offset to MW-18, which has had fairly consistent detections of RDX at levels between 0.34 and 0.52 ppb. He noted that at MW-254, profile results showed RDX detections from 0.53 to 1.2 ppb, and screens are being set at those interval locations. Mr. Gregson then stated that backtracking from MW-18 goes back to the former K Range, or perhaps as far back as the J-2 Range. He noted that RDX has not been detected in soil at the former K Range, and he mentioned that while trichloroethylene (TCE) also has been detected in MW-18 historically, it was not detected in profile samples from MW-254.

Mr. Schlesinger referred to the "Northeast MMR Boundary" map and asked when the detection at MW-215 occurred. Mr. Gregson replied that MW-215 was installed fairly recently, and is located at the firing point for the former K Range. He also noted that the detection at that location was RDX and it was at a level just above the health advisory. Mr. Schlesinger asked if additional samples from that area are being pursued. Mr. Gregson replied that additional work is planned or under way for the J-2 Range, a possible source area for that detection at MW-215.

Ms. Adams asked if itís correct that the zones of contribution (ZOCs) shown on the map are based on each of the Upper Cape Water Supply Cooperative production wells pumping 1 million gallons per day (mgd). Mr. Gregson replied that he believes that is correct. Ms. Adams noted that itís her understanding that the three production wells could be increased to pump 4.5 mgd total, in which case she questions whether MW-254 or the potential source areas (the former K Range and the J-2 Range) would fall within those increased ZOCs. Mr. Gregson replied that he couldnít comment on this without seeing what those ZOCs would look like.

Mr. Pinaud stated that the Commonwealth approved the ZOCs and the pumping rate for each of the wells from 1 to 1.5 mgd, for a total of 4.5 mgd. He said that the ZOCs did get a little bit bigger, and although DEP tried to have that map ready for tonight, it was unable to do so. Ms. Adams said that she thinks it would be good to have future maps showing the updated ZOCs.

Mr. Gonser noted that the 4.5-mgd rate is only for a peak demand day, while the average annual rate is still only 3 mgd. He said that perhaps Denis LeBlanc of the U.S. Geological Survey (USGS) could shed some light on the immediate impacts versus long-term impacts; however, itís his understanding that "the aquifer doesnít see short-term changes like that, and so from the aquiferís perspective, it would see 3" mgd. Ms. Adams replied that although thatís a refinement of which she wasnít aware, she maintains that contaminants within the larger ZOC could at some time be drawn into the production wells, and she thinks that the map should represent that, even if itís not happening on an average annual basis.

Ms. Pepin asked that a request for DEP to provide updated ZOC maps at the next IART meeting be noted as an action item.

Mr. Judge stated that itís his understanding that last week the Senior Management Board (SMB) voted and agreed that "4.5 mgd was enough," although 10 mgd is the amount thatís been discussed historically. He also said that given the situation with the Bourne Water District shutting down some of its supply wells, it was just lucky that the 3-mgd system was overbuilt to be a 4.5-mgd system, but he wants to be sure that "that overbuilt system isnít the final answerÖ" Mr. Gonser replied that heís not aware that the SMB had determined that anything beyond 4.5 mgd wouldnít be necessary. He also said that he thinks that the potential for the development of additional water supply exists, although concerns such as impacts to ponds would have to be taken into consideration.

Dr. Dahmani stated that a ZOC is also a depiction of a set of values associated with a number of parameters, some of them sensitive parameters. He said that, again, he would like at least some indication from the modeler as to what sensitivity parameters were changed so that the team could have some comfort in terms of where the ZOCs are. Mr. Gregson replied that the modeling for the ZOC determination was done outside of the IAGWSP, through a consultant who coordinated with DEP Water Supply under DEPís standard water supply development procedures. He also said that he thinks DEP could provide a copy of the report and modeling that went into that effort. Dr. Dahmani said that he thinks the team should see not just one ZOC, but several, based on the changes made to some of the important parameters. He noted that he knows from experience that changing just one of the sensitive parameters by 20 to 30% could increase the ZOC such that it includes MW-215. Mr. Pinaud stated that DEP approval was based on a pump test report provided through the Upper Cape Water Supply Cooperative. He said that he could obtain a copy of that report for whoever wants one.

Mr. Hugus suggested that the best way to answer Dr. Dahmaniís questions would be to have a presentation on modeling. Dr. Feigenbaum agreed, and suggested that Dr. Dahmani put his questions in writing to ensure that such a presentation would provide the answers. Mr. Gregson said that he has no objection to adding this topic to the next IART agenda, or to Dr. Dahmani sending the IAGWSP an e-mail specifying what heíd like that presentation to cover. Mr. Borci said that while he agrees this is a worthy topic, the next IART meeting agenda includes the potentially lengthy topic of the Demo 1 RRA/RAM for Soil. Therefore, the team should be aware of the possibility that there wonít be time for the modeling agenda item at that meeting.

Southeast Ranges Ė Recent Unvalidated Detections

Mr. Gregson showed a map entitled "Southeast Ranges Perchlorate Plume Recent Detections" and reported that at MW-251, which is located on the northern shore of Snake Pond, perchlorate was detected at concentrations from 0.37 to 0.53 ppb in profile samples at three intervals between 95 and 125 feet below the water table. He noted that well screens are being set at those locations. He also reported that the first sampling event at MW-239 showed perchlorate at 0.7 ppb, which was consistent with profile results. He also said that no explosives were detected at location, nor were they detected at MW-243-M2, where perchlorate was detected at 1.4 ppb, which also was consistent with profile results.

Agenda Item #6. Adjourn

Mr. Murphy suggested that the IART forego the review of action items, which would later be e-mailed out to team members. There were no objections from the team. Mr. Murphy also announced that the IART would meet next on February 25, 2003 at the Falmouth Holiday Inn. He then adjourned the meeting at 9:10 p.m.

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