Impact Area Review Team
Future Agenda Items:
Handouts Distributed at Meeting:
Agenda Item #1. Welcome, Review Draft Agenda, Approval of April 22, 2003 and May 27, 2003 IART Meeting Minutes
Mr. Murphy convened the meeting at 6:08 p.m., reviewed the agenda, and asked for any comments on the April 22, 2003 or the May 27, 2003 Impact Area Review Team (IART) meeting minutes. Ms. Hayes expressed concern about a conversation reflected in the May IART minutes, which she described as an interrogation of a volunteer team member by a paid staff team member. Mr. Murphy agreed to discuss this issue with her outside of the meeting. Mr. Judge said that he would like his request for information about fireworks activity on the base to be noted as an action item. No changes or additions to the minutes were recommended, and both the April and May IART meeting minutes were approved as written.
Agenda Item #2. Late-Breaking News and Responses to Action Items
No late-breaking news was reported at this time.
Responses to Action Items from the May 27, 2003 IART Meeting
Mr. Hugus referred to Action Item #1, his request that a draft Impact Area Groundwater Study Program (IAGWSP) information fact sheet be made available to the team at this meeting, for review and comment. Mr. Gregson said that while a draft is not available at this time, the intention is to meet with the community involvement group on July 10, 2003, and then begin preparing a draft document, with the goal of having it available to the team by the July IART meeting.
The IART then engaged in a discussion about community outreach activities, and several citizen team members made the following comments and suggestions: that the process for developing an IAGWSP fact sheet has taken too long, and the responsibility should be transferred from the National Guard Bureau (NGB) to the U.S. Environmental Protection Agency (EPA); that a schedule for updating a regularly produced IAGWSP fact sheet be added to EPA's list of required documents associated with the cleanup program, in order to ensure that the public is adequately informed; that EPA should issue monthly news releases on IART progress/happenings following every IART meeting; and that the citizen team members should be provided with funding, possibly through the Technical Outreach Services for Communities (TOSC) program, to produce a periodic citizen-based informational piece to be distributed to the community. Ms. Hayes recommended that the IART not rush to judgement on this issue, and that team members submit their ideas to the facilitator via e-mail. She also expressed some discomfort with EPA being solely responsible for generating public information pieces.
Mr. Borci stated that under EPA's administrative orders, the NGB is responsible for providing adequate public input/information, and it appears to him that the majority of IART members believe that is not happening. He suggested that this topic be scheduled for discussion at the next project managers' meeting. Ms. Grillo offered the idea of having a TOSC adviser work with citizen team members to determine the type of information they think the community needs. Mr. Murphy asked if any team members would disagree that more and better public information is needed. No team members indicated that they would disagree.
Mr. Williams of the Massachusetts Department of Public Health (MDPH) referred to Action Item #8, MDPH's agreement to report back to the team on the date when results of the Bourne Water District newborn screening data study are expected to be available. He said that at this point he's unable to commit to a date; however, MDPH is expecting a report in mid to late July, so he hopes to be able to provide a date at the next IART meeting.
Mr. Mullennix, a citizen team member, said that it's been about a year since the IART was first promised this information. He also noted that a 1996/1997 study was conducted of the incidence of congenital hypothyroidism within seven counties in California and Nevada, both of which have neonatal screening programs in place, and where perchlorate in drinking water has been a known problem for decades. The study looked at 700,000 newborns, and the results, which were published in the Journal of Occupational Environmental Medicine, indicated no increase in the incidence of congenital hypothyroidism, with perchlorate levels at 4 to 16 parts per billion (ppb). Mr. Mullennix also mentioned a study conducted in Chile, which also has a neonatal screening program in place, and where there's naturally occurring perchlorate. He noted that this study, which was authored by eight doctors, found no evidence that perchlorate in drinking water, at concentrations as high as 120 ppb, suppresses thyroid function in newborns or school-aged children.
Mr. Schlesinger, a citizen team member, commented that Mr. Mullennix should have shared these studies with the team prior to discussing them at the meeting. Mr. Hugus questioned whether Mr. Mullennix agrees with the advisories and guidelines set by the regulators, and he asked Mr. Mullennix not to contradict the work of the IART. Mr. Mullennix apologized for not having shared the studies with the team in advance, and said that he would forward the information to team members right after the meeting.
Ms. Hayes said that while she understands erring on the side of caution, she is concerned about alarming the public unnecessarily. She also said that she thinks that the TOSC advisers are the ones who should address the issue of whether the 1-ppb perchlorate level recommended by the Massachusetts Department of Environmental Protection (DEP) is needed. Dr. Dahmani, a TOSC adviser, said that he thinks it should be left up to the experts in the public health/environmental fields to decide what levels are safe.
Mr. Judge implied that Mr. Mullennix had "cherry-picked" two studies out of a multitude of studies on perchlorate. He also said that he would question the validity of the studies based on how they were funded. Mr. Mullennix said that the studies he'd discussed specifically address neonatal screening programs, and are therefore directly applicable to the information sought from MDPH.
Mr. Hugus requested that the IAGWSP provide an organizational chart that outlines all parties having to do with the cleanup, as well as their responsibilities and involvement. He also expressed concern that one of the cleanup contractors, AMEC, has been selected to conduct a study associated with proposed development for Camp Edwards. Mr. Gonser of the IAGWSP agreed to supply the organizational chart that Mr. Hugus requested. He also said that the IAGWSP was not in any way involved with the selection of AMEC to conduct a study having to do with the development of a Department of Homeland Security site at Camp Edwards.
Agenda Item #3. Investigations Update
Northwest Corner Investigation
Mr. Gregson reviewed recent Northwest Corner investigation detections, as follows: a 1.7 ppb perchlorate detection in the third round of sampling at well RSNW03, a private drinking water well located near the Cape Cod Canal, now being sampled on a biweekly basis; a 0.48-ppb perchlorate detection and a 0.25-ppb Royal Demolition Explosive (RDX) detection in well RSNW06, a private well southwest of RSNW03, being used for lawn irrigation; and profile detections in a new well, monitoring well 277 (MW-277), which were a 6.7-ppb perchlorate detection at 4 feet below water table, a 3.86-ppb perchlorate detection at the next 10-foot interval, a 1.65-ppb perchlorate detection at the next 10-foot interval, and a 1.09-ppb perchlorate detection at the next 10-foot interval, with samples from 34 feet below water table down to bedrock testing nondetect for perchlorate. Mr. Gregson noted that two screens were set in MW-277 – one at the water table and one at a depth of about 34 feet. Mr. Gregson also said that wells NWP-2 and NWP-3 will be in a good location for detecting any additional RDX heading toward the downgradient area where RDX had been detected previously.
Mr. Gregson said that monitoring well sampling is ongoing, and pressure transducers were installed in the U.S. Geological Survey (USGS) well and in MW-270 to look at the effects of tidal fluctuations on the water table near the canal and help in understanding the interaction between groundwater and the canal itself. In addition, the IAGWSP has identified four new drilling locations, based on data collected so far.
Mr. Gregson responded to a question from Dr. Dahmani by explaining that soil samples are being collected near Gun Position 19 (GP-19) on base because perchlorate had earlier been detected in soils near GP-16. At this time the focus of the off-base investigation is on sampling the groundwater wells; however, other soil sampling locations would be considered as the investigation progresses. He also said that cross-sections of the Northwest Corner area are starting to be prepared, but are not yet available. Mr. Pinaud commented that he thinks it's almost time to start drawing contours around the detections at the Northwest Corner.
The question was raised as to why more monitoring wells weren't being installed upgradient of the perchlorate contamination near the canal, and Mr. Gregson explained that the investigation approach is to "step back" from known contamination and work toward a source area. He also noted that because of a lack of well screen information from RSNWO3, the particle track from that well doesn't provide specific information on a source area, but is helpful in terms of indicating the direction of travel. Then, the issue of fireworks as a possible source of the perchlorate contamination was raised. Mr. Gregson said that this possibility would be explored further if the investigation leads in that direction. However, the current conceptual site model indicates that the perchlorate contamination is coming from upgradient, and the investigation is being conducted accordingly.
Mr. Cambareri inquired about MW-277, and Mr. Gregson replied that the depth to water table at that location is 106 feet, and that some finer-grained material, or heaving sand, was encountered when the well was being drilled. Mr. Cambareri also inquired about the wells in that area that weren't sampled. Mr. Gregson explained that in some cases, screens weren't thought to be in an appropriate location, and in other cases, similar information could be obtained from a nearby screen. He also said that decisions pertaining to which well screens should be sampled would be reevaluated once data from wells NWP-2 and NWP-3 become available. Mr. Cambareri suggested that it would be prudent to assess the area downgradient of well 95-6, a potential water supply area. Mr. Judge requested that the IAGWSP install a monitoring well upgradient of MW-277, as soon as possible, so that the question of responsibility for the perchlorate contamination near the canal could be put to rest.
Mr. Pinaud informed the IART that DEP received two letters from the Guard in reply to the Notice of Responsibility (NOR) issued on May 13, 2003. In the first letter, received on May 27, 2003, it was noted that the Guard was trying to work through some federal law and policy challenges and constraints in order to determine whether it could take response actions. The second letter, received on June 10, 2003, did a good job of explaining previous, current, and planned actions in the Northwest Corner area, but was not responsive to the NOR in that it didn't include a commitment to eliminate the exposure pathway for the private well on Foretop Road (RSNW03). Mr. Pinaud said that DEP unsuccessfully tried to convince the Army and the Guard to find a way to provide a connection to a public water supply system, a treatment system at the home, or bottled water. Then today DEP notified the Army and the homeowners that it would be starting the procedure to provide bottled water to the homeowners this week.
At this time, Mr. Dow suggested that the flow rate or water height in the canal should be measured in order to validate information provided by the pressure transducers installed in the USGS well and MW-270. Then the conversation returned to the subject of the Guard's response to the NOR, and Mr. Schlesinger requested an explanation of the meaning of the following statement: "Federal law and policies impose certain constraints upon our authority to respond to MCP-based requirements set forth in the NOR. The issues related to this entire perchlorate matter are extremely complex, with significant fiscal law and national policy implications." Mr. Gonser explained that perchlorate is a national issue, and the military is trying to determine what authority it has to address an unregulated substance and spend taxpayers' money on response actions such as providing bottled water.
Mr. Kinney expressed some concern that the effort to install and collect data from the pressure transducers would take away from the effort to determine the source of perchlorate. Mr. Gregson gave his assurance that this activity is being done in addition to, not instead of, other investigation activities, and it's hoped that data collected from the transducers will be helpful in understanding the hydrogeology of that entire area. Mr. Kinney also said that the provision of bottled water seems to make sense in this situation, given that perchlorate does not volatilize and therefore the homeowners would not be at risk from washing or showering with water from their private well.
Mr. Hugus questioned whether DEP's commitment to provide bottled water meant that the Guard no longer had to take responsibility. Mr. Pinaud assured him that DEP's opinion is that the Department of Defense (DoD) remains liable.
Mr. Walsh-Rogalski inquired about the legal hurdle that the Guard seems to be putting forth in terms of not being able to take response actions related to well RSWN03. He said that Section 1431 of the Safe Drinking Water Act (SDWA) provides broad statutory categories of contaminants, and that perchlorate is captured by the emergency order provision. Mr. Gonser said that he'd like to get together with Mr. Walsh-Rogalski after the meeting to hear about any ideas on how to approach this issue. Mr. Pinaud stated that perchlorate is regulated under the Massachusetts Contingency Plan (MCP).
Mr. Judge said that he'd rather see taxpayer money being spent on bottled water than on potential lawsuits down the road. Mr. Gonser replied that the liability issue has been discussed, but the problem is the authority to act. He also said that he doesn't perceive DEP's action to provide bottled water as in any way changing the Guard's obligation to move forward with the investigation and deal with the issue.
Dr. Stahl commented that the request to install a well upgradient of MW-277 might not make sense at this time because it's not now known whether the particle track extends as far back as the road where there would be optimal access for installing a monitoring well.
Mr. Schlesinger voiced his opposition to spending money on downgradient wells to look at the interaction of the contamination with the canal. He also asked whether there's been any investigation of a small range shown on the map. Mr. Borci noted that there are no documented known releases of perchlorate associated with that range. Mr. Gregson clarified that the purpose of the downgradient wells is not to determine how the contaminant flows into the canal, but to acquire a fuller understanding of the plume as a whole. Mr. Borci added that the project managers believe that the technical investigation is proceeding as it should, starting with known contamination and working outward to understand the extent, and working backward to find the source.
Demolition Area 1 Recent Unvalidated Detections
Mr. Gregson reviewed recent unvalidated detections at Demolition Area 1, as follows: a 0.56-ppb perchlorate detection in MW-252, in the second round of sampling; a 0.54-ppb perchlorate detection in MW-255, in the first round of sampling; and perchlorate detections ranging from 0.46 to 0.79 ppb in MW-271, in four intervals of profile sampling. He also reported that perchlorate levels have increased at MW-76 – in one screen levels have gone from 11 ppb, to 290 ppb, to 500 ppb over three sampling rounds, beginning in December 2000. In another screen levels have gone from nondetect, to 11 ppb, to 200 ppb. He said that the increase is likely due to a pulse of higher levels of contamination flushing through that area.
Demolition Area 2 Recent Unvalidated Detections
Mr. Gregson reviewed recent unvalidated detections at Demolition Area 2, as follows: 1.3-ppb RDX detections in MW-259, in the first round of sampling; and 0.74-ppb RDX detections in MW-262, also in the first round of sampling. He noted that there are no current detections above the health advisory, although historically at MW-16 a detection at or just above the health advisory was seen.
The team engaged in a discussion about the Guard having taken responsibility for perchlorate contamination at Demolition Area 1. Mr. Gregson noted that the Guard was conducting response actions for RDX there, and has Rapid Response Action/Release Abatement Measure (RRA/RAM) plans that will address the perchlorate contamination, as well as the RDX. Mr. Gonser added that the contamination appears to be coming from Demolition Area 1, a military site, and so the military is responding, conducting an investigation, and will be cleaning up that contamination, while past activities such as fireworks having been brought into that area can be sorted out later. He said that the Guard clearly is taking responsibility for the investigation and cleanup of Demolition Area 1 soil and groundwater.
Mr. Gregson noted that the regulators had concurred with the IAGWSP that the Demolition Area 1 plume was sufficiently defined for the purpose of proceeding with a feasibility study. He also said that the proposed interim actions include source removal (to begin this summer) and groundwater pump-and-treat (with construction to begin this fall), while, at the same time, the feasibility study is being undertaken. Mr. Borci noted that based on documentation that the use of Demolition Area 1 began in 1974, and the distance that the plume has reached, it appears that the plume has been traveling one foot per day.
Southeast Ranges Recent Unvalidated Detections
Mr. Gregson reviewed recent unvalidated detections at the Southeast Ranges, as follows: a 30.4-ppb perchlorate detection and a 2.49-ppb RDX detection in the deep screen of MW-265, in the first sampling round; and a 4.41-ppb perchlorate detection in the shallow screen of MW-265, also in the first sampling round. He noted that particle tracking from that well leads to the J-1 Range interberm area, and he also mentioned that perchlorate had previously been detected in MW-166, and RDX detected in MW-164. Mr. Gregson further noted that the IAGWSP has proposed drilling well J1P-19 to further investigate this area of contamination.
Inquiries were made about the level of confidence in the particle track from MW-265 and the location of proposed well J1P-19, and Mr. Gregson noted that the groundwater flow is complicated in this area, which is at the top of the groundwater mound. It was also pointed out that the particle tracks aren't parallel to the zone of contribution (ZOC) for Upper Cape Water Supply well #3. Mr. Gregson explained that the model used to establish the ZOCs was different than the model used to run the particle tracking. He also said that the best way to proceed with the investigation is to "step out" from known contamination.
Dr. Dahmani questioned whether a proactive systematic approach is being used to locate perchlorate sources on base. Mr. Gregson replied that base-wide monitoring is being conducted to identify areas of perchlorate contamination, prime candidates for which are areas where demolition, burning, and disposal have occurred.
Mr. Judge expressed his dissatisfaction with the use of two different models in the Southeast Ranges area, and both he and Mr. Hugus requested that the IAGWSP install a monitoring well in the middle of the ZOC to ensure that that water supply is not affected by base-related contamination. Mr. Gonser noted that sentry wells are located such that they would detect any contamination traveling toward the ZOC. Dr. Dahmani said that particle tracks and ZOCs are two different things; therefore, it's important to be careful when comparing particle tracks, which pertain more to the short term, and ZOCs, which pertain more to long-term supply of water to a well. Mr. Gregson said that he would provide the team with more data and sampling frequency information on monitoring wells located near or along the edges of the ZOC.
Agenda Item #4. Central Impact Area Update
Mr. Gregson stated that the extent of perchlorate and RDX contamination at the Central Impact Area has been defined sufficiently for the purpose of proceeding with a feasibility study. He noted that the IAGWSP has proposed a focused investigation of Target 23, a boiler located near Tank Alley, and Target 42, a tank located on the eastern side of Turpentine Road, in order to support potential interim actions at the site. He also mentioned that live firing at the Central Impact Area ended in 1997.
Mr. Gregson noted that the focused investigation of Targets 23 and 42 will include additional soil sampling, an unexploded ordnance (UXO) survey, and the installation of lysimeters, which are devices that will be placed underneath target areas where they'll collect rainwater to be tested for contaminant concentrations. There are 29 other targets in the Central Impact Area, nine of which showed RDX concentrations greater than 1 part per million (ppm). Soil contaminants identified at the Central Impact Area include RDX, High Melting Explosive (HMX), perchlorate, trinitrotoluene (TNT), TNT breakdown products, and PETN, a type of explosive compound. Groundwater contaminants identified there include RDX, 4A-dinitrotoluene (4A-DNT), HMX, and perchlorate. Mr. Gregson reported that perchlorate concentrations up to 5 ppb have been detected in groundwater, as have RDX concentrations up to 15 ppb. He also mentioned that at the nearby Chemical Spill 19 (CS-19) plume, which the Air Force Center For Environmental Excellence (AFCEE) is investigating, an RDX concentration as high as 34 ppb was detected.
Mr. Gregson showed the draft revised RDX plume map and pointed out the nondetect-to-2-ppb contours, the 2-to-10-ppb contours, the greater-than-10-ppb contours, and the CS-19 plume to the south. He then showed cross-section figures of the Central Impact Area RDX plume and pointed out that what in plan view appears to be a contiguous area of RDX contamination is in fact a number of distinct fingers of contamination. He also showed the draft revised perchlorate plume map and pointed out the nondetect-to-1-ppb contour, the 1-to-4-ppb contours, and the 4-to-18-ppb contour. Mr. Gregson said that that perchlorate extent appears to be less than the RDX extent, and noted that this is believed to be due to the difference in timing of the releases. He mentioned that LITR rounds that had perchlorate in the spotting charge didn't come into use until the mid-1980s.
Mr. Gregson then stated that the Phase II reports for groundwater and soil are expected to be finalized by the end of the year, as is the focused investigation of Targets 23 and 42. Also, possible removal actions at the targets would be undertaken in spring 2004, while the feasibility study process for the remaining soil and the groundwater is continued.
Dr. Stahl questioned whether the RDX and perchlorate contamination tracks together, and Mr. Gregson replied that it's believed that there is a similar source area for both contaminants. Mr. Gregson also noted that the IAGWSP would try to have perchlorate cross-sections available for the team by the July IART meeting.
Mr. Kinney inquired about remediation technology to treat perchlorate and RDX. Mr. Gregson replied that the IAGWSP has been researching remediation technologies, including a fluidized bed reactor to treat perchlorate, which might also be effective for treating RDX. He noted that granular activated carbon (GAC), which is effective for treating RDX, TNT, and TNT breakdown products, is being tested to see if it can also treat low levels of perchlorate. He said that it's likely that a combination of technologies will be used.
Dr. Dahmani requested that the IAGWSP provide three-dimensional visualizations of plumes, and that ZOCs depicted on maps be identified either as current or steady state.
Mr. Dow asked whether the perchlorate's faster rate of travel through groundwater was taken into account when it was concluded that the perchlorate plume is smaller because the release occurred more recently than the release of RDX. Mr. Gregson replied that the perchlorate mapping was based primarily on monitoring well data, but the distance of travel between locations also was taken into consideration. Mr. Borci added that some perchlorate may have been deposited earlier than the 1980s, and some may exist farther out than is currently known. He also said that it's being investigated whether all the perchlorate seen in the Northwest Corner came from near the base boundary or whether some might have come from the Central Impact Area. Mr. Borci further noted that there's a good degree of confidence in the date when use of Demolition Area 1 began, and the perchlorate contamination from there has traveled about twice as far as the explosive contamination has.
Mr. Judge asked that the regulators share all their comments on the cleanup effort with the TOSC members and keep them fully informed.
Mr. Schlesinger questioned whether the particle track from Foretop Road in the Northwest Corner investigation points back to a known source area in the Central Impact Area. Mr. Gregson explained that because the depth of that well screen isn't known, the particle track doesn't provide that kind of specific information. He also noted, however, that information that's obtained from the new wells is expected to be more valuable.
Mr. Skelly, an attendee at the meeting, suggested that the RDX and perchlorate plumes would necessarily look different due to the molecular makeup of the compounds. Mr. Gregson agreed and said that because RDX is a larger molecule, "it tends to get stuck on stuff" as it travels along in solution.
Agenda Item #5. Open Discussion/Other Issues
Ms. Hayes read a letter that she had received from Meghan Cassidy of EPA (see below).
Mr. Murphy recommended that the orientation session for new IART members, originally planned for Friday, June 27, 2003, at 10:00 a.m., be rescheduled because only one member would be able to attend at that time. It was suggested that the orientation should occur outside of regular working hours, when both new and long-time members are more likely to be available. Mr. Murphy said that IAGWSP staff would coordinate with IART members via e-mail to schedule a better date for the orientation session.
Mr. Murphy also asked whether team members would prefer to forego one of the summer IART meetings. Those members who responded indicated that they wanted to stick with the regular monthly meeting schedule, and Mr. Murphy stated that the next IART meetings would take place on July 22, 2003, and August 26, 2003. It was also noted at this time that a meeting pertaining to the proposed Massachusetts Military Reservation (MMR) lease extension was scheduled for Monday, June 30, 2003, at 6:00 p.m., at the Falmouth Holiday Inn. Mr. Hugus and Mr. Kinney encouraged IART members to attend this meeting and provide public input.
Agenda Item #5. Adjourn
Mr. Murphy adjourned the meeting at 9:17 p.m.
Letter from Meghan Cassidy of EPA
From: Meghan Cassidy
I have been asked by Bob Varney, Regional Administrator of EPA New England, to respond to your e-mail dated 4/25/03. Your e-mail addresses the posting of information at ponds around the Massachusetts Military Reservation (MMR), specifically Snake Pond. You also mention coordination issues with the Technical Outreach Services for Communities (TOSC) advisors who support the Impact Area Review Team (IART).
TOSC is a university-based technical assistance program available to citizens. TOSC advisors operate independently from EPA offices. For additional information regarding the TOSC program, please contact Jim Murphy, EPA Region I TOSC coordinator, at (617) 918-1028.
Regarding Snake Pond, for several years now, the Massachusetts Department of Public Health (MDPH), in conjunction with the local Boards of Health, the Agency for Toxic Substances and Disease Registry, the Air Force Center for Environmental Excellence, the National Guard Bureau Groundwater Study Program, EPA, and the Massachusetts Department of Environmental Protection, has been providing the public with information related to the recreational use of water bodies on or near MMR. Information for Snake Pond is included in this effort.
Surface water samples from the public beach and Camp Good News areas of Snake Pond have been collected since 1996 for ethylene dibromide (EDB), and since 2001 for RDX and perchlorate. EDB in the Snake Pond area is associated with the Fuel Spill 12 plume being addressed by the Air Force, under EPA's oversight, pursuant to CERCLA. RDX and perchlorate are associated with contamination emanating from the southeast ranges, which is being investigated pursuant to the Safe Drinking Water Act orders. According to preliminary information provided by the MDPH, the 2003 Snake Pond posting information and fact sheet indicate that adverse health effects are not expected from exposure to EDB, RDX, and perchlorate based on recreational use of Snake Pond.