Impact Area Review Team

River River Drops of rain on a leaf

Impact Area Review Team
Christ the King Church
Mashpee, MA
May 27, 2003
6:00 p.m. Ė 9:00 p.m.

Meeting Minutes





Hap Gonser




Ben Gregson



Mike Minior (sitting in for Marty Aker )



Todd Borci



Bill Walsh-Rogalski



Len Pinaud



Ellie Grillo



Dick Judge



Richard Hugus



Bob Mullennix



Judy Conron



Michael Butler



Jim Stahl



Amine Dahmani








Jim Murphy








Tina Dolen



LTC Brian Rogers




Bill Sullivan



Ed Wise




Meghan Cassidy




Jane Dolan



Bob Lim




Dave Williams



Kevin Hood




David Dow

Sierra Club



Mark Harding

Mashpee Wampanoag


Jim Quin

Ellis Environmental Group


Rick Carr



David Heislein




Kim Harriz


Kris Curley



Lori Boghdan



Jennifer Washburn



Jane Moran



Action Items:

  1. Mr. Hugus requests that an initial draft of an Impact Area Groundwater Study Program (IAGWSP) fact sheet (in the style of the Installation Restoration Program [IRP] annual report), including a comprehensive base-wide map, be available for Impact Area Review Team (IART) review by the June IART meeting.
  2. Mr. Judge requests that the IAGWSP provide specific and detailed information regarding efforts to recover cleanup monies from contractors who operated at the Southeast Ranges.
  3. Mr. Judge recommends an investigation to identify compounds that are not mentioned in actual contract documents, but that were detected at the ranges.
  4. Mr. Gregson will check on the date when updated groundwater modeling and associated maps will be available, and will report back to the IART.
  5. Mr. Judge asks that the IAGWSP consider undertaking a Snake Pond fish study similar to the fish study recently conducted by the U.S. Geological Survey (USGS) at Ashumet Pond.
  6. Mr. Mullennix recommends that soil sampling for perchlorate be conducted at the Bourne fireworks display/launch area. Dr. Dahmani recommends that soil sampling be conducted in areas where perchlorate from Bourne fireworks might be found as a result of air transmission/deposition.
  7. Dr. Dahmani requests that the IAGWSP provide the IART with cross-sections and/or three-dimensional graphics of the Southeast Ranges plumes.
  8. The Massachusetts Department of Public Health (MDPH) agreed 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.
  9. Mr. Hugus requested further information on the nature (i.e., whether the deadline is enforceable) of the IAGWSPís agreement to submit a plan for the J-3 Range plume.

Future Agenda Items:

  • Northwest Corner Investigation
  • Program Overview Ė Central Impact Area
  • Gun and Mortar Firing Positions Update

Handouts Distributed at Meeting:

  1. Responses to Action Items from the April 22, 2003 Impact Area Review Team Meeting
  2. Massachusetts Department of Public Health (MDPH) fact sheet: Recreational use of Water Bodies on or near the Massachusetts Military Reservation Ė May 2003
  3. Presentation handout: Investigation Update
  4. IAGWSP data tables
  5. Press Releases, Neighborhood Notices and Media Coverage 4/23/03 Ė 5/22/03
  6. Impact Area Groundwater Study Program Update Ė May 2003

Agenda Item #1. Welcome, Review Draft Agenda, Approval of April 22, 2003 IART Meeting Minutes

Mr. Murphy convened the meeting at 6:08 p.m. and the IART members introduced themselves. He then reviewed the agenda and noted that an update on the Northwest Corner investigation area would be included in the "Program Overview and Investigations Update" section of the agenda.

Mr. Schlesinger directed the teamís attention to the IRP publication entitled "Cleaning Up the MMR Ė Annual Report 2002," and expressed great dissatisfaction that the map contained in the report only shows plumes being addressed by the IRP, and does not include plumes being addressed by the IAGWSP. He said that he thinks the map could be improved so that the public would get "the whole story." Ms. Grillo noted that the regulators raised this issue when reviewing the draft document. She also said that the introductory remarks of Robert Gill, the IRP project manager, include a statement that the report pertains just to that pollution for which the IRP is responsible. She further noted that she thinks that the regulators had asked that the map include a similar notation.

Mr. Judge questioned whether it would be possible for the IAGWSP to publish a similar document of its own. He also said that he agrees that the IRP map is misleading to the general public. Mr. Murphy said that he thinks the IAGWSP produced a fact sheet a while ago, and it may be time for it to be updated. Ms. Dolen stated that up until the end of last year the IAGWSP had been working on a comprehensive document, similar to the IRP annual report, which was to be distributed with the local newspapers. She said that she would like to resume that effort, and work with the U.S. Environmental Protection Agency (EPA) and the Massachusetts Department of Environmental Protection (DEP) to put together a very informative fact sheet. She also clarified that the IART had reviewed a draft of that document after the holidays.

Mr. Judge said that heíd like the IAGWSP document to be six to ten pages long, with color graphics and cleanup goals. He also noted that the arrow graphic used to illustrate cleanup goals in the IRP annual report doesnít appear to him to be accurate, and he would like the IAGWSP publication to be "as slick," but more accurate.

Ms. Grillo noted that DEP hadnít liked the presentation of information in the IAGWSPís draft document and asked the IAGWSP to go back to the drawing board to present "factual information." She also mentioned that because the IRP is a much more mature program, there is more information to be presented in a publication.

Mr. Walsh-Rogalski stated that before Mr. Mullennix became a member of the IART, he (Mr. Mullennix) told the team that he believes that cleanup goals should be driven by levels set by EPA and DEP Ė conservative levels, which he considered appropriate. However, in a letter to Governor Romney that was published in the newspaper, Mr. Mullennix said that he believes that Ms. Rowan West, a risk analyst for DEP, provided flawed analysis and guidance regarding safe perchlorate levels, which were set too low, and created needless fear and expense for the communities. Mr. Walsh-Rogalski then said that heís curious to know whether Mr. Mullennix respects DEPís and EPAís risk analysis, as heíd earlier suggested, or whether he in fact doubts it, in which case heíd like to know the professional basis for Mr. Mullennixís doubt.

Mr. Mullennix replied that itís apparent that DEP and EPA have a difference of opinion regarding what the guidance level for perchlorate should be at this time; DEP has set a guidance level of 1 part per billion (ppb), while the most recent information from EPA is a 4-to-18 ppb guidance level. He said that his letter stated that he thinks the DEP guidance level is flawed, and that the EPA guidance level should be followed.

Mr. Walsh-Rogalski asked Mr. Mullennix to say which part of the analysis he finds flawed. Mr. Mullennix noted that there are more than 950 pages of EPA documentation regarding the very complex issue of a perchlorate standard. He also said that he would be happy to provide a written statement in response to Mr. Walsh-Rogalskiís question. Mr. Walsh-Rogalski asked if Mr. Mullennix had a specific scientific basis for finding the analysis flawed. Mr. Mullennix replied that he had sided with the EPA guidance of 4-to-18 ppb.

Mr. Borci stated that the most recent information on perchlorate would result in a 1-ppb standard. Until that information is finalized, however, EPA recommends continued use of the older set of numbers, which results in a 4 to 18 ppb standard. He also said that DEP has utilized the newer information. Mr. Mullennix said that he does not believe that thatís correct.

Mr. Murphy asked if there were any changes or additions to the April 22, 2003 IART meeting minutes. Ms. Grillo requested that approval of the minutes be postponed until the June meeting in order to provide an opportunity for Millie Garcia-Surette of DEP to submit comments she may have. As there were no objections from the team, Mr. Murphy agreed to postpone approval of the April 22, 2003 IART meeting minutes until the June meeting.

Mr. Schlesinger asked Mr. Walsh-Rogalski to identify the newspaper piece he had mentioned. Mr. Walsh-Rogalski replied that it was a May 24, 2003 editorial published in the Cape Cod Times and entitled "The Perchlorate Principle Ė Local Residents Should Continue to Err on the Side of Caution." Mr. Hugus said that heís interested in discussing that editorial, as well as other published statements made by Hap Gonser having to do with the perchlorate issue and a recent detection in a private drinking water well.

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

Mr. Murphy noted that late-breaking news about the recent perchlorate detection in a private drinking water well would be covered under the "Program Overview and Investigations Update" portion of the agenda. He then asked if there were any comments on responses to action items from the April 22, 2003 IART meeting.

Mr. Judge referred to Action Item #2, his request for an update on efforts to recover cleanup money from contractors that formerly utilized areas in the J Ranges. He noted that heís dissatisfied with the response that thereís no new information, and wants specifics Ė names, addresses, times Ė on what is being done to recover cleanup money from the contractors. He said that he wants to know how far the Army National Guard has pursued this issue, he wants the IART to pursue it as a group, he thinks that EPA also "should be going after these folks," and he wants to create a situation where new information is brought forward.

Mr. Walsh-Rogalski noted that EPA just completed a second set of negotiations with Textron to undertake cleanup work. He also said that EPA does not have any immediate plans to pursue a cost recovery action because the amount of money spent by EPA is not particularly significant, and the real cost recovery case belongs to the Guard. Mr. Walsh-Rogalski further noted, however, that because of its experience in developing potentially responsible party (PRP) cases, EPA has been assisting and sharing information with the Guard.

Mr. Judge said that heíd like to see the Guardís and EPAís dollar estimate of what the contractors would owe were they to be held accountable. He suggested that the contractors might be responsible for a significant portion of the total cleanup cost for which the Guard currently is taking full responsibility.

Dr. Dahmani referred to Action Item #3, his request that the IAGWSP look into modeling/calculating worst-case contamination scenarios. He said that heís dissatisfied with the response stating that this would be addressed in a feasibility study, and wants to know when this action will be taken and why it would occur as part of a feasibility study. Mr. Gregson replied that an answer probably would be provided before the feasibility study. He also explained that the point is that the Southeast Ranges groundwater modeling effort to establish a plume shell is ongoing, and it wonít be possible to calculate a worst-case scenario with respect to contaminant entering Snake Pond until that plume shell has been established. Mr. Hugus inquired about the date when that modeling would be available. Mr. Gregson replied that he would check with the modelers and let him know before the next IART meeting.

Mr. Hugus noted that Snake Pond is affected not only by Southeast Ranges contamination, but also by contamination from an IRP plume, Fuel Spill 12 (FS-12). He then asked if this recreational pond, where a childrenís summer camp, Camp Good News, operates on its shores, has been posted with some kind of advisory for the upcoming summer season. Mr. Minior stated that a posting, as relates to FS-12, has been prepared, and does include mention of the IAGWSP. He also noted that any decision on a posting would be up to the Sandwich Board of Health, which he believes has the posting in hand at this time. Mr. Hugus asked about the IAGWSP information that was included. Mr. Minior replied that he thinks it was just a reference to the IAGWSP and a point of contact there. Mr. Hugus expressed frustration that, as with the map situation Mr. Schlesinger mentioned earlier, the IAGWSP side of the base isnít being represented. He said that the public doesnít distinguish between the IRP and IAGWSP, but has the right to know what Massachusetts Military Reservation (MMR) contaminants might be affecting Snake Pond. He also said that itís his understanding that coordinating this kind of information among the services is the responsibility of a particular on-base environmental office, which is not represented at this meeting, and therefore no answers are being provided.

Ms. Dolen stated that, as was done last spring, a Snake Pond informational social event, which will include informational displays and representatives from the Air Force Center for Environmental Excellence (AFCEE), the IAGWSP, the MDPH, and other agencies, is scheduled to occur the afternoon of June 17, 2003, on the shore of Snake Pond. She said that the event would be publicized through news releases, advertisements, and letters mailed directly to all of the area residents. She also noted that she believes that the Snake Pond posting is a bulletin that states whether or not the pond is safe, lists the agencies that have input into that determination, and provides contact information for those agencies.

Mr. Hugus said that he thinks a greater effort needs to be made, as the social event wonít necessarily reach everyone whoís apt to use the pond. He also said, "of course the base is going to say the pond is safe," so he would prefer that the posting advise members of the public about the chemicals upwelling into the pond so they can make an intelligent decision about whether or not to swim there. Mr. Schlesinger added that he thinks that the parents of Camp Good News campers should be informed about the situation at Snake Pond. He said that relying on the mailing list would reach fewer individuals than ought to be alerted.

Mr. Borci noted that MDPHís annual fact sheet, "Recreational Use of Water Bodies On or Near the Massachusetts Military Reservation," addresses the ethylene dibromide (EDB), perchlorate, Royal Demolition Explosive (RDX) in a question-and-answer format. He said that the fact sheet contains a base level of information "thatís provided to everyone," so the question is whether or not something above and beyond that is required.

Mr. Judge asked how many residents attended last springís social event at Snake Pond. Ms. Dolen replied that 100 residents had attended. Mr. Judge then asked how many copies of the IRP annual report were distributed. Mr. Minior replied that about 64,000 copies were distributed with the local newspapers. Mr. Judge noted the discrepancy in the numbers. Ms. Dolen again stated that the IAGWSP plans to work with the regulators to develop a fact sheet for wide distribution. She further noted that reaching smaller groups is also of great importance, as is information in the newspapers and on the radio, and reaching individuals by telephone. Mr. Judge replied that while he appreciates that, he maintains that the difference between 64,000 and 100 is significant. He also referred to Mr. Gillís opening remarks in the IRP annual report and said that Mr. Gillís mention of catch-and-release fishing in ponds near MMR should have been phrased as "please do not ingest the fish that are in the pond."

Mr. Schlesinger referred to Action Item #4, a request that the IAGWSP and the IRP consider undertaking a study of potential effects on biota in Snake Pond from explosives, perchlorate, and EDB contamination. He noted that the response includes the statement that the IAGWSP would consider undertaking such a study if necessary, and it also provides information specific to EDB, but not to explosives and perchlorate.

Mr. Gregson stated that, as in previous years, the IAGWSP conducts surface water sampling at Snake Pond every two weeks during the summer season, and to date the water has tested nondetect for perchlorate and explosives. He also noted that this summer the IAGWSP would be initiating an ecological risk characterization for the Southeast Ranges, to be done in a format consistent with Massachusetts Contingency Plan (MCP) regulations. The Stage 1 assessment of the characterization is similar to a Phase 1 investigation, and, if required, Stage 2 would involve biota sampling to assess risk to ecological receptors in the pond.

Mr. Pinaud clarified that the first step, the Stage 1 assessment, determines whether a completed exposure pathway exists. If one were found to exist, the next step would be Stage 2, which includes biota sampling. He also said that this explanation should have been the written response to Action Item #4, and he noted that DEP and EPA hadnít been given the opportunity to review the action item responses.

Ms. Dolen made a point of noting that last December the IAGWSP had a 14-page fact sheet ready to be sent to the printer. However, some IART members didnít like it, DEP "wanted to put the brakes on," and, eventually, so did EPA. Ms. Dolen said that the money has been budgeted and the paper is on the shelf at the printers; however, the regulators havenít yet given the IAGWSP the go-ahead to resume working on the fact sheet. Ms. Dolen said that she is ready to make the commitment to produce the fact sheet, and she believes that the IAGWSP can garner enthusiasm from the regulators to put the project back on the table.

Mr. Borci suggested that at the next project managersí meeting with community involvement staff, the group discuss steps for developing an IAGWSP fact sheet in the style of the IRP annual report. He also remarked that the draft document produced last December was a "nonstarter," and added that the project managers would report back to the team on plans for producing an IAGWSP fact sheet.

Ms. Grillo clarified that DEP was not the only party to "put the brakes to" the original draft document. She also said that DEP is "not putting the brakes on getting accurate and substantive environmental information out to the community," but wouldnít sign on to a document that didnít meet that goal.

Mr. Dow noted that the catch-and-release requirement that was mentioned is based on mercury, not on contaminants related to the IRP or IAGWSP, for which fish advisory levels havenít even been developed.

Mr. Judge acknowledged the recent death of Jean Crockerís husband, Buzz Crocker, both of whom have been regular IART attendees and participants.

Mr. Hugus requested that an initial draft of the IAGWSP fact sheet, to include a comprehensive base-wide map, be made available for IART review by the June meeting.

Mr. Mullennix thanked Mr. Dow for mentioning that the catch-and-release issue pertains to mercy levels in the ponds. He noted that there are literally dozens of small ponds and lakes throughout Massachusetts where catch-and-release is recommended because of mercury levels, including a small lake in central Massachusetts where he owns a nearby cottage.

Mr. Schlesinger questioned whether any Snake Pond sampling is being conducted at depth, where fish and biota might be experiencing different levels of upwelling contamination. Mr. Gregson replied that diffusion sampling was conducted in the pond bottom, and no contaminants were detected in the water coming into the pond. He also said that he doesnít think that any deep surface water samples have been collected, but added that that could be considered as part of the investigation. Mr. Judge recommended that the IAGWSP undertake a study at Snake Pond similar to the recent USGS study at Ashumet Pond, which looked at papillomas in brown bullhead.

Ms. Conron asked if there is a MDPH fish consumption advisory that states that the Snake Pond fish shouldnít be eaten. Mr. Williams replied that there is a mercury advisory regarding the consumption of fish from Snake Pond, as well as from Johns, Ashumet, and Peters Pond. The advisory states that consumption should be limited and that pregnant women and children should not eat any fish from these ponds.

Ms. Conron also noted that sheíd like to hear more about EPAís and DEPís differing views on a perchlorate standard, and suggested that this topic be discussed during the "Open Discussion/Other Issues" portion of the agenda. Mr. Murphy agreed to Ms. Conronís suggestion, if in fact this issue was not discussed as part of the "Program Overview and Investigations Update" agenda item.

Agenda Item #3. Program Overview and Investigations Update

Northwest Corner Recent Validated Detections

Mr. Gregson showed an aerial photograph of the Northwest Corner investigation area and pointed out the Bourne Bridge, the Cape Cod Canal, and the U.S. Army Corps of Engineers (USACE) rest stop. He noted that in recent weeks the IAGWSP sampled the five residential wells identified in that area Ė samples from three of the wells, all located on the same street, have been validated, and of those three, two tested nondetect for perchlorate, and one well, identified as RSNW03, showed a perchlorate detection of 1.75 ppb. Test results from the other two wells, which are located closer to the Bourne Bridge, are still unvalidated, but were nondetect for perchlorate.

Mr. Gregson stated that upon learning of the perchlorate detection, the IAGWSP immediately notified the property owner and resampled the well to confirm test results. A sample and a duplicate sample were collected and analyzed, and showed similar perchlorate levels, at 1.65 ppb and 1.7 ppb. The samples were also sent to another laboratory for analysis, and again, the results were similar, at 1.7 ppb and 1.8 ppb.

Mr. Gregson reported that the IAGWSP has checked the Bourne Water Districtís records to ensure that all private wells in the area have been identified. In addition, registered letters were sent to all 44 homeowners in the area to determine whether they might have abandoned private wells or irrigation wells, despite being on town water. Mr. Gregson noted that the IAGWSP would make arrangements to sample any other private wells that might be identified.

Mr. Gregson stated that the Northwest Corner investigation is moving forward. He referred to the aerial photograph, and pointed out monitoring well locations identified as NWP-1, NWP-4, NWP-2, and NWP-3. He also reminded the group that perchlorate had been detected at 6 ppb in well 4036009DC, located near the canal; at 1 ppb in well HW-1, an existing water table well to the north of 4036009DC; and at just above 1 ppb at a well near Gun Position 16 (GP-16) on base property. He further noted that monitoring well 65 (MW-65) and the 95-15 series of wells on base tested nondetect for perchlorate, as did well 4036011, which, however, did show a 0.28-ppb RDX detection several months ago. Mr. Hugus inquired about the RDX detection in the community well at the Schooner Pass development. Mr. Gregson confirmed that that is the well where RDX was detected at 0.28 ppb. Mr. Murphy asked if itís correct that the aerial photograph is not up-to-date and therefore doesnít show all the currently existing streets. Mr. Gregson replied that this is correct.

Mr. Judge asked Mr. Gregson to identify the direction of firing from GP-16. Mr. Gregson replied that firing from that position was to the southeast, toward the Impact Area. He also clarified that artillery rounds, not rockets, were fired from GP-16, and noted that to his knowledge the propellant used for artillery rounds does not contain perchlorate. He further noted, however, that perchlorate was detected in soil at GP-16 and in groundwater at the water table; therefore, itís believed that some type of perchlorate source exists in that area, although it hasnít yet been identified.

Mr. Schlesinger asked Mr. Gregson to discuss particle backtracking from the locations where perchlorate was detected. Mr. Gregson stated that backtracking has been done; however, that effort was somewhat limited by a lack of screen depth information for the wells where detections occurred. He then noted that the backtrack line from well 4036009DC runs through the NWP-2 location, the backtrack line from the private well runs through the NWP-4 location, and the backtrack line from well 4036011 runs through the NWP-3 location. He noted that the NWP well locations were chosen based on particle backtracking.

Mr. Schlesinger asked whether, given the particle backtracking, it could be assumed that the perchlorate came from the base. Mr. Gregson replied that this is a possibility. He also noted, however, that because of the lack of information pertaining to the depth of the contamination, particle backtracking from well 4036009DC, for example, only indicates that the source area could be anywhere from near the well itself all the way back to the Central Impact Area. He said that itís hoped that data from the new monitoring wells on the base boundary will help to refine the search for a source area. Mr. Schlesinger asked why the depth information isnít available. Mr. Gregson replied that the wells that were sampled are either abandoned water supply wells or water table wells, which often are screened from the water table down to depth.

Mr. Dow noted that with mortars and howitzers, excess propellant bags were routinely burned. He then inquired about any excess propellant associated with rockets or flares. Mr. Gonser replied that in order to avoid firing outside of the range, not all the propellant bags that were provided were used, and the excess ones were cut off and burned. Rockets and flares, however, "come as one standard thing," without excess propellant that requires disposal.

Dr. Dahmani asked whether the NWP wells are existing wells. Mr. Gregson replied that the first well, NWP-1 was just completed last week, and NWP-4 is the next location to be drilled. Dr. Dahmani asked if the purpose of the investigation is to determine whether a perchlorate plume exists in that area. Mr. Gregson said that as more data are gathered, it would be possible to make that determination.

Mr. Walsh-Rogalski noted that itís his understanding that when this close to surface water, groundwater travels in a direction thatís perpendicular to the surface water. Mr. Gregson replied that this is the general theory, but the canalís tidal influence and the fact that itís a major groundwater divide may cause complicating factors. He also said that with the currently available data, itís not known what effect the canal might have on groundwater flow in that area.

Mr. Walsh-Rogalski then referred to the aerial photograph and asked Mr. Gregson to point out the Bourne fireworks display area, which he did. Mr. Walsh-Rogalski asked if it would be fair to say that the fireworks display area is cross-gradient to the residential contamination. Mr. Gregson replied that that would be the case, given the assumption that groundwater flows straight into the canal. He also mentioned, however, that in summer the prevailing wind is from the southwest, so there may be a smoke plume from the fireworks that extends in the direction of the detections.

Mr. Mullennix stated that his curiosity led him to measure the distance between the fireworks display area and the spot where perchlorate was detected at "4 or 5" ppb. That distance measured less than 1000 yards and involved a very steep gradient of about a 100-foot difference in elevation. He also noted that he had with him at the meeting some fireworks mortar shells that he collected from the fireworks display area. He further reported that he learned from the web site for Skylighter, the leading source of fireworks in the country, that the big fireworks rockets are 67% perchlorate. Also, the web site offered a special deal Ė five pounds of potassium perchlorate for free with the purchase of $150 worth of fireworks-making material. Mr. Mullennix noted that five pounds of potassium perchlorate could contaminate 500 million gallons of water at a 1-ppb level.

Mr. Mullennix then stated that while he doesnít know whether fireworks are contributing to the contamination being detected, given the proximity of the fireworks activity, he would suggest that in order to be fair, DEP call for sampling at the fireworks display area, in addition to the sampling that the IAGWSP already has undertaken. He also mentioned that sampling had been done in the waters of Lake Tahoe, near a fireworks display area, before and after the 2001 and 2002 fireworks. Prior to the fireworks displays, the water tested nondetect for perchlorate. Sampling conducted immediately after the 2001 display showed test results of 63 ppb for perchlorate, and after the 2002 display, test results of 24 ppb for perchlorate. He also noted, however, that sampling conducted the day after those displays showed results that were nondetect for perchlorate, probably because of the dilution factor. Mr. Mullennix again said that, in order to be fair, the Bourne fireworks display area ought to be sampled.

Mr. Schlesinger asked whether the fireworks mortar shells that Mr. Mullennix brought to the meeting would be considered hazardous waste. Mr. Mullennix replied that he hopes not, given that they can be found lying all around the fireworks area behind the vocational school in Bourne. Mr. Schlesinger inquired about DEPís opinion on whether that material is considered hazardous waste. Mr. Pinaud said that the material would have to be tested to make that determination.

Mr. Schlesinger asked if there is a plan to do testing at the Bourne fireworks display area and the water beneath it. Mr. Pinaud replied that the workplan to determine the nature and extent of contamination in the Northwest Corner investigation area is being implemented; the groundwater contamination will be followed to its source, whether that source is on the base or at some other location.

Mr. Schlesinger also referred to Mr. Gonserís statement that there are no excess propellant bags associated with rockets and flares, and made a point of noting that on numerous occasions buried caches of mortars have been found at unexpected locations on base. He also said that he thinks itís "a little premature" to "discard someoneís question on the basis of military argument."

Mr. Hugus recommended that Mr. Mullennix bring the fireworks perchlorate issue to the attention of the Bourne selectmen. Mr. Hugus also noted that he doesnít believe that the perchlorate detection at RSNW03 could possibly be related to the Bourne fireworks display area, especially given the steep gradient of the aquifer "right down to the canal." He further stated that he found disingenuous and irresponsible Mr. Gregsonís statement in the May 22, 2003 issue of the Boston Globe that he didnít know whether the well contamination was related to the Impact Area, as well as Mr. Gonserís statement in the May 20, 2003 issue of the Cape Cod Times that the IAGWSP had no idea about the source of the contamination. Mr. Hugus also inquired about todayís deadline for the IAGWSP to make its decision regarding whether it would be supplying bottled water to the homeowners whoíve had perchlorate detected in their private drinking water well. Mr. Gregson said that he hadnít meant to imply that the contamination is not coming from the base, only that the source of the perchlorate contamination is not yet known. He noted that the purpose of the ongoing investigation is to determine what that source is.

Mr. Hugus asked for Mr. Gonserís opinion about groundwater traveling cross-gradient. Mr. Gonser replied that, as Mr. Gregson said, groundwater flow in the area near the canal is a little confusing. He also noted that, as Mr. Mullennix had indicated when speaking about perchlorate detections in Lake Tahoe, itís possible that the contaminant might have traveled by air dispersion.

Mr. Hugus then asked if the IAGWSP has taken responsibility for the residential well where perchlorate was detected, and provided the homeowners with bottled water. Mr. Gonser replied that the Northwest Corner investigation is moving forward, and the NWP-1 well already has been installed. He also said that the homeowners have not been provided with bottled water at this point, and explained that the IAGWSP is determining which authorities it has to move forward with any kind of response action. Mr. Hugus made a point of noting that it has been 20 days since perchlorate was detected in that residential well.

Mr. Hugus asked again about todayís deadline for an answer from the IAGWSP regarding the provision of bottled water. Mr. Pinaud stated that a Notice of Responsibility sent out by DEP on May 13, 2003, noted a deadline of May 27, 2003 for the IAGWSP to respond in writing regarding its intention to take response actions to address the contamination in the residential well. He said that as of yet, DEP has not received a response. He also said that if DEP does not receive a response by the end of the day, it would consider next steps to be taken. Mr. Gonser noted that the IAGWSP intends to provide a response by the end of the day, and that effort was under way when he left his office earlier. Mr. Hugus expressed frustration that while everyone considers next steps, homeowners have been "drinking polluted water" for 20 days.

Mr. Walsh-Rogalski asked that in the future Mr. Mullennix refrain from gathering evidence he might find, and instead report it to an authority. He said that while it would be useful to bring in photographs of evidence, "it doesnít help the integrity of the operation to have this kind of evidence tampered with."

Mr. Borci inquired about the figure that shows particle backtrack lines. Mr. Gregson replied that he did not have copies of that with him. Mr. Borci said that the figure is very informative and should be provided to the IART. He also said that the contamination would be followed to its source, "so if it leads us to the Bourne fireworks area, then thatís the case." Mr. Gregson said that he would send copies of the particle backtrack figure to the IART members.

Mr. Gregson continued his presentation by referring to well NWP-1, located southeast of well 4036009DC where perchlorate was detected at 6 ppb. He reported that recent profile results from NWP-1 showed perchlorate detections in every sample from the water table down to bedrock. The detection at the water table was 5.39 ppb, and concentrations increased with depth, with a maximum concentration of 8.8 ppb at 52 feet below water table. Concentrations then began to decrease down to bedrock, at a depth of 111 feet below water table, where the detected perchlorate concentration was 1.27 ppb. Mr. Gregson said that he believes this is the first time at MMR that a compound was detected from water table to bedrock in a single well.

Mr. Hugus asked if the data had been validated. Mr. Gregson replied that profile data do not undergo a validation process. He then noted that three screens were set in well NWP-1: one at the water table, one at bedrock, and one at 52 feet below water table. He also said that Denis LeBlanc of USGS wasnít able to offer an explanation for this kind of contaminant distribution in the well near the canal, but agreed to discuss the situation with other USGS hydrogeologists. Mr. Gregson noted that Mr. LeBlanc also confirmed that groundwater flow at the canal is very complicated and that there arenít a lot of data available in that area in order to understand the hydrogeology there.

Mr. Gregson further noted that fresh water was found from water table to bedrock in well NWP-1 and the well at the Bourne Bridge, which indicates that the situation there differs from coastal areas where fresh water rises up over "a big wedge of saltwater." He said that it appears that there may even be fresh water underneath the canal. Mr. Gregson also said that itís unfortunate that because of the spread of detections in NWP-1, itís not possible to run a particle backtrack that would provide greater focus to the investigation; however, the IAGWSP could "key in on the highest detection and see where that backtracks to." Mr. Gregson further noted that well NWP-4 is the next to be drilled as part of the Northwest Corner investigation.

Ms. Conron inquired about regulations pertaining to fireworks. Mr. Pinaud replied that his understanding is that fireworks launching areas are regulated by the Department of Public Safety.

Ms. Conron also asked if the private well where perchlorate was detected is used for drinking water by the residents. Mr. Gonser replied that the home is not connected to town water, and the residents there have access to their private well for drinking water, although theyíve said that they ordinarily drink bottled water. Ms. Conron asked if it would be possible to connect that home to town water. Mr. Gonser replied that it would, and noted that only three homes in that area, which were built before the water main was installed, are not connected to the town system.

Ms. Conron commented that she finds it scary that thereís so little knowledge about this area, and while she doesnít believe that all the perchlorate contamination came from the fireworks, sheís disturbed by the possible ramifications from any townís fireworks displays. Mr. Gonser noted that perchlorate is a relatively new issue for everyone, but one that certainly needs to be addressed.


Mr. Gregson showed a map depicting particle tracks from wells in the Northwest Corner investigation area. He pointed out the backtrack from well 6011, where RDX was detected; the backtrack from well 4036009DC, which goes back to the Impact Area; the forward particle track from GP-16, and the backtrack from MW-66.

Mr. Judge asked if any fireworks were fired from GP-16. Mr. Gregson replied that he does not know. Mr. Judge said that he thinks itís important to know if fireworks were fired on the base, so it can be determined with certainty whether or not the perchlorate contamination is strictly a rocket fuel problem. He also stressed the importance of taking responsibility for the perchlorate contamination now, rather than sometime in the future, when one might have to say, "Iím sorry you drank all that water, but weíre still not really, really, really sure where it came from."

Mr. Schlesinger asked for some clarity on the party responsible for protecting the public health with respect to perchlorate related to fireworks. Mr. Williams replied that he doesnít have a good answer to this question, but doesnít think that this issue comes under the jurisdiction of MDPH. Mr. Schlesinger expressed some frustration, and questioned whether the legislators might need to make a determination as to whose jurisdiction should encompass this issue.

Mr. Borci said that the conversation is "getting a little off the subject," and noted that while fireworks are an issue, itís important to be aware of the context in which the issue is being raised. He stated that the contamination points back toward the base. Right now thereís no indication that itís coming from the Bourne fireworks area, and until and unless there is such an indication, the fireworks are not an issue for the IART. Mr. Borci said that thereís a logical stepwise process to the investigation, and "jumping to the fireworks as a source is not the appropriate way to conduct the investigation."

Mr. Schlesinger clarified that he is not making that assumption, but simply is wondering which agency is responsible for the perchlorate contamination. Mr. Borci replied that in order to determine if perchlorate contamination exists at the fireworks display area, the issue should be brought to the local selectmen, who can decide whether to appropriate funds to do testing there.

Dr. Dahmani suggested that since some particle tracking was done, there must be enough hydrogeological information to indicate whether thereís any possibility that contamination from the fireworks area actually could migrate in the groundwater to the locations where perchlorate was detected, "which apparently is not the case here." He also said that soil sampling in that area could determine whether deposition of perchlorate might be contributing to those detections. Dr. Dahmani also mentioned the possibility that profile detections throughout NWP-1 might be an artifact of the sampling technique, whereby "contamination may be dragged to deeper levels." He added that if that were not the case, it would seem that a large contaminant plume exists in that area.

Mr. Hood made a point of noting that every summer there are thousands of fireworks displays all over the country, perhaps many of which occur in close proximity to water wells, "yet this is the only place thereís a problem."

Mr. Mullennix said that he agrees that a very large plume could be the cause of perchlorate detections throughout the entire length of a well; however, he also believes that a very localized source of contamination could be the cause. Dr. Dahmani agreed, and noted that the way to make that determination is to investigate the soil in the area. Mr. Gregson mentioned that the phenomenon seen in well NWP-1 hasnít been seen in any other profile samples collected during drilling.

Mr. Mullennix noted that itís common knowledge that the military is banned from using any perchlorate-laden materials on the northern part of the base, which has to do with EPAís 1997 administrative order. Also, because of recent perchlorate detections in the area near the canal, DEP is requiring the military to take a number of actions to define the source of that contamination. At the same time, however, the Town of Bourne has plans to set off fireworks on the Fourth of July, and in fact bring several hundred pounds of perchlorate to the launching area. Mr. Mullennix said that itís a mystery to him why the military is banned from doing anything that might introduce "one iota of perchlorate at all," while the fireworks are freely allowed to be set off with the "tacit approval" of DEP. He said that he thinks this is selective enforcement and a double standard.

Mr. Hugus recommended that Mr. Mullennix bring this issue to the Bourne selectmen. He also noted that the IARTís business is not to discuss all contamination on Cape Cod, but only contamination from the Impact Area at Camp Edwards. Mr. Hugus added that so far thereís no evidence that the recent perchlorate detections came from the fireworks area, and as far as heís concerned that suggestion is "a smokescreen." He also said that he thinks this subject should be dropped, and that it was only raised by the IAGWSP in order to escape liability for the residential well. He further noted that he thinks it is outrageous that the homeowners are caught "in this political issue and have to drink this water." He said that he believes that the IAGWSP should be providing bottled water and should pay for a town water hookup immediately.

Mr. Mullennix clarified that he, not the IAGWSP, was the one who brought up the subject of the fireworks. He also explained that he had raised the issue because heís an environmental scientist who knows that hundreds of pounds of perchlorate are going to be brought onto a site thatís within a thousand yards of some perchlorate detections, and heís curious as to whether the fireworks might be the source of that contamination.

Mr. Borci suggested that the project managers review the Northwest Corner investigation workplan, which had been approved prior to the perchlorate detection in the residential well, the profile sampling conducted at NWP-1, and the recently introduced theory of aerial deposition. He said that there are clear, logical, scientific ways to examine this information and make changes to the workplan, including adding some soil sampling, if necessary. He said that at the next IART meeting the project managers could report back to the team on any revisions to the workplan, and provide some cross-sections to enhance understanding of the investigation area. He also reiterated that right now the investigation is pointing back to the base as the source of the perchlorate contamination, and he noted that the next monitoring well to be drilled is NWP-4.

Mr. Judge noted that heís curious about the J. Braden Thompson plume, which is located off base, and he suggested that more samples from that plume should be collected in order to perhaps "draw direct connections between J. Braden Thompson and base solvents." He also asked that Mr. Mullennix report back to the IART on any discussions about fireworks that he has with the Bourne selectmen, who should have detailed records about such events. He further noted that at this point the idea that recent perchlorate detections are related to the Bourne fireworks has no foundation in fact, and the facts need to be gathered.

Bourne Area Recent Unvalidated Detections

Because the meeting was running late and Mr. Gregson wanted to use the remaining time to briefly review the Demolition Area 1 schedule and provide a detailed presentation on the Southeast Ranges, he quickly noted that as part of the investigation near the Monument Beach wellfield, perchlorate was recently detected in MW-267 at 2.39 ppb, while samples from MW-268 and MW-269 tested nondetect for perchlorate.

Demolition Area 1 Update

Mr. Gregson reviewed the updated schedule for the Demolition Area 1 groundwater operable unit as follows: well installation through July 2003, finalization of the Rapid Response Action/Release Abatement Measure (RRA/RAM) plan by July 2003, engineering design and contracting through September 2003, equipment fabrication/construction through June 2004, and system startup in May 2004.

Mr. Gregson then reviewed the updated schedule for the Demolition Area 1 soil operable unit as follows: anomaly removal from June through November 2003, soil excavation from August to November 2003, soil disposal/treatment from November 2003 to August 2004, draft RRA/RAM Completion Report in August 2004, and site restoration activities from July to September 2004.

Mr. Walsh-Rogalski mentioned that thereís some slippage in the updated schedules. Mr. Gregson stated that for the most part the schedule for the soil operable unit is still within the originally proposed timeframe, although the date for completion of anomaly removal may have slipped a little bit. For the groundwater operable unit, however, there is significant slippage of the system startup date, which originally had been November 2003. Mr. Gregson explained that for a variety of reasons - including refining details of the RRA/RAM plan itself and getting more accurate bid information from the system construction contractor on time required to fabricate components Ė it became apparent that the November 2003 date wouldnít be met, and so the revised schedule was provided. Mr. Walsh-Rogalski inquired about the level of confidence in meeting the May 2004 startup date. Mr. Gregson replied that the IAGWSP is confident that that schedule can be met.

Southeast Ranges

Mr. Gregson showed an aerial photograph, and pointed out the northwestern part of the J-3 Range, some test buildings, the J-1 Range, the 1000-meter berm, the 150-meter berm, and the inter-berm area. He also showed a map of the Southeast Ranges, and pointed out Snake Pond, the Impact Area boundary, and the ranges that are the focus of the Southeast Ranges investigation: the J-1 Range, the J-3 Range, the J-2 Range, and the L Range. He noted that both the Army and the Army National Guard used the J Ranges for training activities in the 1940s and 1950s, and used the L Range up until the late 1990s. In addition, the ranges were used by defense contractors as test sites. Archive Search Report activities were helpful in identifying former users of the ranges, and it was determined that beginning in the early 1950s and 19060s, the J Ranges were leased to a number of defense contractors, including AVCO/Textron, MIT, Raytheon, Atlantic Research, Kerr-McGee, Hesse Eastern, National Fireworks, and others. Contractors used the ranges to test a wide variety of munitions: some inert, some containing small amounts of explosive compounds in the fuses, and some high-explosive rounds that contained RDX, High Melting Explosive (HMX), and other explosive compounds.

Mr. Gregson noted that the Southeast Ranges are situated at the top of the aquifer, also known as the top of the mound. Groundwater flows radially in all directions from the top of the mound, which also shifts seasonally and over longer periods of time, making the investigation of this area very difficult. Mr. Gregson noted that the Southeast Ranges investigation began in 1997, in response to EPA administrative orders, and a comprehensive sampling and assessment program was initiated in 2000. Contaminants of potential concern in groundwater identified at the Southeast Ranges are RDX, trinitrotoluene (TNT), HMX, 2,4-di-amino-nitrotoluenes (DANTs), and perchlorate. The same contaminants, plus nitroglycerin, were identified as contaminants of potential concern in soil.

Mr. Gregson then showed an RDX plume map, one of several preliminary draft plume maps, which, he noted, were recently provided to the regulators for review, so some minor changes may be forthcoming. He said that the general shape of the plume is similar to past versions, but slightly wider in the middle area. He also mentioned that a source area is located in the central part of the J-3 Range, and that groundwater flow in that part of the base is almost due south, toward Snake Pond. He pointed out the location of a monitoring well on a spit of land in the northern part of Snake Pond, and noted that RDX was detected there at depth, below the pond bottom. He also pointed out two plumes of low-level RDX concentrations that appear to be coming from the L Range, as well as an area of RDX contamination that originates from the inter-berm area, and another area of RDX contamination at Disposal Area 2 in the J-2 Range. Mr. Gregson again mentioned the radial groundwater flow from the top of the mound, and pointed out that the J-1 Range plume flows to the northwest, the J-2 Range plume flows to the northeast, and the southern plumes flow to the south.

Mr. Gregson then showed the preliminary draft plume map for perchlorate contamination, pointed out a source area at the central part of the J-3 Range, and noted that detections appear to end at a row of monitoring wells at the northern edge of Snake Pond. He also pointed out a smaller area of lower levels of perchlorate off to the east, and noted that perchlorate was detected in the inter-berm area and at Disposal Area 2. Mr. Gregson then pointed to a monitoring well location to the northwest, off the map, and reminded the team that at the last meeting heíd reported that a relatively high concentration of perchlorate was detected there. He said that that contamination might track back and tie into the J-1 Range perchlorate contamination. Mr. Gregson then stated that the Southeast Ranges investigation is ongoing and 36 additional monitoring wells have been proposed: 14 at the J-3 Range, 10 at the J-2 Range, and 8 at the J-1 Range.

Mr. Schlesinger noted that in plan view the two plume shells overlap, and then asked whether the two contaminants form separate plumes in three dimensions. Mr. Gregson replied that perchlorate tends to migrate faster than RDX does, so conceivably that could be happening. He also said that much depends on the timing of the release of the compounds; for example, if RDX was released earlier and perchlorate was released later, there would be a separation of the plumes. Mr. Schlesinger then questioned whether the two higher-concentration perchlorate areas depicted on the map indicate two separate source areas. Mr. Gregson replied that the assumption is that thereís a single source area from which higher-concentration releases occurred at different times.

Mr. Gregson noted that the J-1 Range initially was used for training in the mid-1930s, and then became a defense contractor range in the late 1950s. He showed an aerial photograph of the J-1 Range and pointed out firing points in the lower right-hand side of the figure, the 1000-meter and 150-meter berms, the area where some targets are located off the figure, and the location of a 2000-meter berm. He also mentioned that some berms located near a firing point had tunnels through which rounds were fired in order to keep them on course.

Mr. Gregson stated that 1,100 mortar rounds were discovered on the J-1 Range in 1997. Also found at the range were a popper kettle, which is metal box where munitions were burned; a steel-lined pit, used for disposal of munitions; a J-3 Range operations wastewater discharge location, near the inter-berm area; and buried paint pails. Companies that used the J-1 Range were American Potash and Chemical, Atlantic Research, and AVCO, and the items that were tested there included 105-mm high-explosive anti-tank rounds, an experimental tungsten penetrator, howitzer ammunition, mortars, and 20-mm, 37-mm, and 50 cal to 8-inch rounds.

Mr. Gregson then showed an aerial photograph of the J-2 Range and reported that it was first used for contractor test operations in about 1953. He noted that Hesse Eastern, which eventually became Norris Industries, conducted work on the J-2 Range. He reported that there was an industrial area in the southern part of the range, which included a melt-pour facility where rounds were loaded with explosives. Other features of the J-2 Range were an ammo storage magazine area, a drop tower where munitions were tested, a loading/conditioning area, other buildings, and some firing points along the southern boundary.

Mr. Gregson reported that the magnetometer survey of the J-2 Range led to the discovery of a buried Sherman tank. Also found at the range were Disposal Area 1, Disposal Area 2, and a couple of brick-lined pits filled with munitions. Mr. Gregson pointed out the up-range location from which munitions were fired, and also mentioned that there are a couple of berms located to the south. He also said that munitions tested on the J-2 Range included LAW rockets, 81-mm mortars, tank rounds, artillery rounds, and fuses for 30-mm cartridges.

Mr. Gregson showed an aerial photograph of the J-3 Range, and reported that contractor use of the range began in 1968 by AVCO, which later was sold and became Textron Systems Corporation. He said that AVCO/Textron tested and developed tactical weapons systems, and loaded, assembled, and tested munitions at MMR. Mr. Gregson then referred to the source area of the J-3 Range plumes that emanate to the south, and pointed out the locations of a burn box and a detonation pit.

Mr. Hugus mentioned the Minuteman test area at the J-3 Range and asked if itís true that Minuteman missiles were powered by perchlorate. Mr. Gregson replied that he believes that is true. He also noted that while some sampling has been done there, additional investigation is needed to better define whatís occurring at the Minuteman test area.

Mr. Gregson then pointed out the location of the J-3 Range melt-pour building, believed to be the source of some soil and groundwater contamination (mostly HMX) emanating from that area. He also pointed out a workshop building, a firing range for 20-mm rounds, a small artillery testing range, a Gauntlet test area used to track how rounds travel through air, and two geophysical survey study areas Ė the barrage rocket study area and the hillside study area, which were impact areas into which mortar rounds and rockets were fired. Mr. Gregson noted that itís not certain where the associated firing points for those areas were located, but they may have been at the Former H Range, a Formerly Used Defense Site (FUDS) currently being addressed by the USACE. He also reported that items tested at the J-3 Range included 20-mm, 40-mm, and 105-mm projectiles, as well as fuses, anti-tank rounds, anti-armor munitions, and 60-mm mortars.

Mr. Gregson showed an aerial photograph of the L Range, which he noted is located between the J-3 Range and J-1 Range. He said that the L Range was used for military training, but is not known as a defense contractor testing area. Originally the range was used in the 1940s as an infiltration course, whereby troops would learn how to crawl underneath and around machine gun fire and TNT detonations. In the late 1970s and the 1980s, it was used as a grenade launcher range, where both 40-mm practice grenades and live high-explosive grenades were launched. Mr. Gregson also pointed out the firing points and targets depicted on the L Range figure.

Mr. Gregson stated that some contamination detected to the south appears to be coming from the L Range, and additional monitoring well locations to determine that source have been proposed. He also noted that RDX contamination detected in shallows wells just to the south of the firing points is thought to be emanating from that vicinity. Additional sampling also is proposed for an area to the north, where there appears to be another contamination source.

Mr. Gregson reported that all the Southeast Ranges have been flown using the aerial magnetometer, and many geophysical investigations have been conducted. He then showed a figure depicting magnetic anomalies identified at the J-2 Range, and pointed out the two anomaly groupings referred to as Polygon 1 and Polygon 2. He noted that after theyíre discovered, polygons are investigated by the intrusive method of digging. However, archive search information is also helpful in understanding what occurred in those areas.

Mr. Gregson noted that the largest disposal/burn area found was Polygon 2. He also said that 64 polygons were excavated at the Southeast Ranges: 17 at the J-1 Range, 35 at the J-2 Range, and 12 at the J-3 Range. Approximately 27 burn and burial pits were found, located mainly in the northwest and center portions of the J-2 Range. Investigation of these sites led to the discovery of approximately 85,000 munitions. Of those, just under 26,500 - including 10,000 small caliber items - contained explosives and were destroyed either in a contained detonation chamber or by open detonations. The remaining rounds were either inert or expended.

Mr. Gregson then reviewed current and future actions pertaining to the Southeast Ranges, as follows: the drilling program to continue plume delineation is ongoing, 36 additional wells are proposed, and the IAGWSP is working with the USACE and contractors to develop RRA/RAM plans to accelerate cleanup, and has presented the regulators with this information in a conceptual form.

Mr. Gregson reported that proposed interim actions at the J-2 Range include soil removals at Disposal Area 2, at the twin berms near the firing points, at berm #2 in the center of the range, at fixed firing points #3 and #4 near the entrance of the range, and at Disposal Area 1. He said that the estimated total amount of soil to be removed from these areas is 1,700 cubic yards. Proposed interim actions at the J-3 Range include soil removals at suspected source areas, the detonation pit and the former burn box area.

Mr. Gregson noted that the IAGWSP intends to develop draft interim action plans by mid-June, for delivery to the regulators and the IART, after which a detailed discussion of the plans would occur at the July IART meeting. He said that the IAGWSP hopes to contract the work by September so that soil removal actions can proceed this fall. In addition, the IAGWSP is contracting with ECC and Jacobs Engineering to look at the feasibility of using the FS-12 treatment system for J-3 Range remedial actions. That work will be ongoing through the early part of the summer, and based on the conclusions, in late summer/early fall the IAGWSP will put together either a workplan that involves the FS-12 treatment system or one that involves an alternate method to clean up the J-3 Range plumes.

Mr. Gregson stated that the Southeast Ranges make up a very complicated area, and the IAGWSP does not expect the interim actions to complete the work that needs to be done there. Rather, the plan is to conduct additional remedial investigations of each range and undergo a full feasibility study process to determine what additional work will be required to address the soil and groundwater contamination.

Mr. Judge recommended that the IAGWSP undertake an investigation to identify compounds not mentioned in actual contract documents associated with defense contractors that utilized the J Ranges, but which were in fact detected at the ranges. He suggested that the IAGWSP could then pursue compensation from the contractors for cleanup work having to do with those compounds not mentioned in contract documents.

Mr. Walsh-Rogalski asked whether the IAGWSP knows what will be done with the excavated soil from the J Ranges. He also suggested that unless the plan is to remove it all to an off-site location for disposal, he would urge that early on in the process, the IAGWSP have its lawyers contact EPA lawyers to talk through Resource Conservation and Recovery Act (RCRA) compliance issues. Mr. Gregson replied that that action is at the forefront of the IAGWSPís considerations for disposal. He also noted that while he doesnít know if itís likely, off-site disposal is a strong option.

Mr. Dow asked if thereís a correlation between Polygon 2 and the plume that emanates from the J-2 Range. Mr. Gregson replied that Polygon 2 is thought to be the likely source area for RDX and perchlorate contamination coming from part of the J-2 Range. Mr. Dow inquired about the specific items found at Polygon 2. Mr. Gregson replied that he doesnít have that information offhand, but could see that itís provided later.

Mr. Hugus noted that the base-wide map, which is dated July 2002, doesnít include a depiction of Southeast Ranges contamination that looks anything like the draft preliminary plume map shown tonight. He requested that the draft preliminary plume map be taken out of draft status so it can be incorporated into the base-wide map. Mr. Gregson said that the team could work toward the finalization of the current Southeast Ranges figure, with the understanding that 36 additional monitoring wells are going to be installed and the figure would have to be changed again in the future. Mr. Gregson also reported that the highest perchlorate detection in the Southeast Ranges occurred near the source area in the J-3 Range, at a concentration as high as 300 ppb. More recent sampling, however, shows perchlorate detections there in the 150-ppb range.

Mr. Hugus expressed concern that time will have been wasted should efforts to look into the feasibility of utilizing the FS-12 treatment prove fruitless. He then suggested that, in order to ensure that no time is wasted, the IAGWSP simultaneously pursue plans for an alternate treatment system. Mr. Gregson noted that the FS-12 feasibility assessment involves many considerations, including whether the system would be able to treat perchlorate, whether the piping is adequate to handle increased flow, whether the existing FS-12 treatment system scheme would be affected, whether thereíd be ecological impacts, and so forth. He noted that the results of the assessment are expected to be available in mid-summer, and added that in the meantime the IAGWSP could "certainly be thinking about Plan B."

Mr. Hugus expressed doubt about the feasibility of utilizing the FS-12 treatment system, and said that he thinks the IAGWSP should not "waste too much time talking to the IRP" about treating the plume. Mr. Gregson noted that the IRP already has a multi-million-dollar treatment plant in place, and if feasible, the IAGWSP should take advantage of that. Mr. Hugus said that he thinks that "a lot of time has been wasted on this particular plume," which he considers to be more demanding of attention than the Demolition Area 1 plume, given its proximity to a recreational pond. He then urged the IAGWSP to come up with a treatment plan so that detailed discussions can begin as soon as possible.

Dr. Dahmani requested that the IAGWSP provide the IART with cross-sections and/or three-dimensional graphics of the Southeast Ranges plumes, which he noted would be particularly helpful in terms of understanding the depth of contamination, the size of the plumes relative to Snake Pond, the potential danger that the plumes might pose to receptors such as ponds and rivers, and the interaction of perchlorate and RDX contamination. Mr. Gregson replied that he would check to see if the cross-sections have been updated to match the new plume maps, and would report back to the team.

Mr. Borci said that everything possible would be done to ensure that updated plume maps are available as handouts for all future presentations. He also noted that Polygon 2 at the J-2 Range appears to be an undocumented demolition area, used from the early 1960s to 1974, while Demolition Area 1 was used from 1974 on. The question that remains is where demolition activities occurred prior to the early 1960s. Mr. Borci also noted that the standard handout entitled "Impact Area Groundwater Study Program Update" is available at every IART meeting and contains information on the various items that were found and where they were found, which should answer Mr. Dowís earlier question about Polygon 2 items.

Dr. Stahl remarked that he would have liked to hear more in this presentation about the FS-12 treatment system, in order to confirm whether it might be a feasible option for treatment of the Southeast Ranges contamination. He also noted that the draft preliminary Southeast Ranges plume maps show both perchlorate and RDX in the zones of contribution for water supply wells #2 and #3, and suggested that this issue needs to be addressed.

Mr. Mullennix noted that about a year ago, Suzanne Condon of MDPH spoke to the IART about the stateís newborn screening program, which tests newborns for various conditions, including thyroid conditions or hypothyroidism. At that time, Ms. Condon indicated that she would report back to the IART within two to three months regarding thyroid conditions in Bourne residents. Mr. Mullennix said that heís made several unsuccessful attempts to find out about the results of that study, and cannot understand why thereís been such a delay, especially since one of the more sensitive areas around the perchlorate question is its possible effect on prenatal conditions, or infants. Mr. Williams replied that the final report is expected shortly, and he anticipates that it will be an IART agenda item in the near future. Mr. Mullennix asked that Mr. Williams look into the date when the report is expected to be available, and then report back to the team. Mr. Williams agreed to do so.

Mr. Borci stated that two weeks ago EPA was told that the IAGWSP would provide a plan for the J-3 Range plume by September 1, 2003 Ė whether or not that plan includes the use of the FS-12 treatment system. Mr. Hugus asked if that is an enforceable date. Mr. Borci said that according to his notes, the IAGWSP was supposed to get back to EPA with a firm date. Mr. Judge noted that he also is interested in knowing whether the date for submitting a J-3 Range plan is enforceable.

Agenda Item #4. Agenda Planning

Mr. Murphy recommended that the discussion on EPA and DEP positions on perchlorate standards, as requested by Ms. Condon, be added to the June IART agenda. He also asked team members to give some thought as to whether they might want to forego either the July or August IART meeting, depending on upcoming agendas.

Mr. Hugus requested that a follow-up discussion on the Northwest Corner investigation be included on the June IART agenda, and that a draft information sheet on the workplan be available for the teamís review at that time.

Mr. Hugus also commented that while he understands that there are new members on the team, he finds the program overviews to be slow and not worthwhile. He said that he would prefer if the presentations focused on the investigations themselves, as there is much to discuss in terms of new detections and future treatment of the plumes. Mr. Murphy informed Mr. Hugus that the IAGWSP is planning an orientation day for new IART members, and he said that his point is well taken; the team shouldnít "be spending time just going back over all the old stuff when thereís a lot of new information."

Agenda Item #5. Adjourn

Mr. Murphy said that the IART would meet next on June 24, 2003, at a location to be determined. He then adjourned the meeting at 9:15 p.m.

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