Impact Area Review Team

River River Drops of rain on a leaf

Impact Area Review Team
Quashnet Valley Country Club
October 28, 2003
6:00 - 9:00 p.m.

Meeting Minutes

Members: Organization: Telephone: E-Mail:
Hap Gonser IAGWSP 508-968-5107
Ben Gregson IAGWSP 508-968-5821
Marty Aker AFCEE/MMR 508-968-4670
Todd Borci US EPA 617-918-1358
Margery Adams US EPA 617-918-1733
Len Pinaud MA DEP 508-946-2871
Ellie Grillo MA DEP 508-546-2866
Kevin Hood TOSC/UCONN 860-486-2546  
Tom Cambareri IART/CCC 508-362-3828  
Peter Schlesinger IART/Sandwich 508-888-0262
Richard Hugus IART/ABC/Falmouth 508-540-6034
Janet Pepin IART/Falmouth 508-548-8182  
Michael Butler IART/Bourne 508-564-6972
Bob Mullennix IART/Bourne 508-759-8319
Judy Conron IART/Bourne 508-759-1559
Dick Judge IART/Sandwich 508-833-0532
Facilitator: Organization: Telephone: E-Mail:
Jim Murphy US EPA 617-918-1028
Attendees: Organization: Telephone: E-Mail:
John McDonagh IAGWSP 508-968-5636
Kris Curley IAGWSP 508-968-5626
Pamela Richardson IAGWSP 508-968-5630
Paul Nixon IAGWSP    
David Margolis USACE 978-318-8627
Mike Minior AFCEE/MMR 508-968-4670  
Bill Sullivan E&RC 508-968-5147  
LTC Dave Cunha E&RC 508-968-5908
Mary Sanderson US EPA 617-918-1381
Meghan Cassidy US EPA 617-918-1387  
Jane Dolan US EPA 617-918-1272
Bob Lim US EPA 617-918-1392  
Minos Gordy PACERS 508-775-3839
David Dow Sierra Club 508-540-7142  
Will Kingkade MDPH 781-774-6611
Dave Jacobson MAARNG 508-968-5148  
Denis LeBlanc USGS    
Kathy Hess USGS 508-490-5029
Mark Harding Mashpee Wampanoag    
David Dow Sierra Club 508-540-7142  
Martin Greene Bourne firefighter 508-759-9178
Kim Harriz AMEC
Mike Goydas Jacobs Engineering 508-743-0214  
Dave Heislein MACTEC 781-245-6606  
Jim Quin Ellis Environmental Group 303-963-9346
Lori Boghdan CH2M HILL 508-968-5635
Jennifer Washburn CH2M HILL 508-968-5631
Jane Moran CH2M HILL 508-759-9114

Action Items:

  1. Mr. Mullennix requested that EPA Region 1 invite EPA Region 2 to a future IART meeting to discuss its publication regarding best management practices for lead at shooting ranges.
  2. DEP said that it would provide a copy of the EPA Region 2 publication to the Environmental Management Commission.
  3. Minos Gordy requested information on RDX and perchlorate contaminant mass in the Demolition Area 1 plume.
  4. Mr. Butler asked that the IART be provided with information on the IAGWSP’s fiscal year 2004 budget.
  5. Mr. Gregson agreed to report back to the team on existing and planned monitoring wells that would better define contamination within the WS-3 zone of contribution.

Future Agenda Items:

  • Cranberry Bog Locations Surrounding MMR
  • IART Process Check-in/Groundrules
  • Rapid Response Action for Central Impact Area Soil
  • Massachusetts Department of Public Health Update
  • Gun and Mortar Firing Positions Workplan
  • Zone of Contribution
  • Mass Flux Approach to Assessing Potential Threat to Snake Pond

Handouts Distributed at Meeting:

  1. Responses to Action Items from the September 23, 2003 Impact Area Review Team Meeting
  2. Map: Cranberry Bogs in the Vicinity of the Massachusetts Military Reservation
  3. 9/30/03 Letter from IAGWSP to DEP re: Substantive Cleanup Standards
  4. Presentation handout: J-2 and J-3 Ranges Rapid Response Actions
  5. IAGWSP fact sheet: J-2 and J-3 Ranges Rapid Response Actions
  6. Presentation handout: Investigation Update
  7. Data Tables
  8. Press Releases, Neighborhood Notices, and Media Coverage 9/24/03 – 10/24/03
  9. Impact Area Groundwater Study Program Update – October 2003
  10. Impact Area Groundwater Study Program – Overview and Update

Agenda Item #1. Welcome, Review Draft Agenda, Approval of August 26, 2003 and
                           September 23, 2003 IART Meeting Minutes

Mr. Murphy convened the meeting at 6:05 p.m. and the Impact Area Review Team (IART) members introduced themselves. Mr. Murphy noted that issues not included on the prepared meeting agenda would be covered under “Open Discussion.” He also referred to the IART groundrules and reminded the team that one of the team members’ responsibilities is to avoid speaking on behalf of the team as a whole. He explained that this groundrule was established in response to past discussion about team members’ communications with the news media, public officials, or other organizations. Individuals may identify themselves as members of the IART but should make it clear that they’re speaking as individuals and not on behalf of the team.

Mr. Schlesinger noted that he doesn’t think there’s a groundrule that addresses where members must live in order to participate on the team. He said that if someone is going to be asked to leave the IART because that member no longer lives on Cape Cod, he thinks that the team as a whole should discuss that issue. He also said that he thinks it would be a travesty to deny IART representation to the many people who are not residents, but who visit Cape Cod. Mr. Murphy recommended that this issue be discussed under “Open Discussion.”

Mr. Hugus asked whether a specific incident occurred recently where an IART member spoke on behalf of the team. Mr. Murphy replied that he saw some recent e-mail communications where it could have been interpreted that an IART member was speaking on the team’s behalf, and so he wanted to provide a general reminder of that groundrule. Mr. Hugus asked if the e-mails had to do with the fireworks issue. Mr. Murphy replied that they pertained to a different issue.

Ms. Conron asked if it’s correct that someone who no longer lives on Cape Cod had been asked to leave the team. Mr. Murphy replied that it is. Ms. Conron encouraged Mr. Murphy to make certain that this issue is discussed later at tonight’s meeting because she wants to be heard on it.

Mr. Murphy then reviewed the agenda. Mr. Hugus made the general comment that IART meeting agendas allow limited time for free discussion among team members. He noted, for example, that the RRA presentation was allotted 70 minutes on tonight’s agenda, while “Open Discussion” was allotted 15 minutes. Mr. Murphy noted that the RRA presentation itself is expected to take about 10 minutes, and the remainder of the allotted time would be used for questions and comments. Mr. Hugus also asked whether the recent missed deadline for Demolition Area 1 (Demo 1) system startup would be discussed tonight. Mr. Borci clarified that the deadline is November 14, 2003, and has not yet passed.

Mr. Murphy asked if there were any comments on the August 26, 2003 or the September 23, 2003 IART meeting minutes. Mr. Judge said that LTC Cunha’s assertion that he (Mr. Judge) had made personal remarks about Mr. Gonser was not reflected in the September minutes, and he thinks it should be. He explained that he thinks it’s important that anyone reading the minutes see that he hadn’t “said anything blasphemous against Mr. Gonser.”

Ms. Pepin referred to a handout that described revisions made to the August meeting minutes in response to team members’ comments at the September meeting. She said that although the handout indicates that Mr. Gregson responded “Okay” to Mr. Judge’s concern about the Sandwich power plant’s potential to draw in perchlorate-contaminated water that would be discharged through the plant as steam, her recollection is that Mr. Gregson responded, “Okay, we’ll keep that in mind.” She also acknowledged that Mr. Gregson might not have spoken those words into the microphone. Ms. Pepin further noted that although the handout indicates that she was mistaken about Mr. Murphy having asked for consensus before the “Investigations Update” presentation, her recollection is that he had asked for consensus from the team regarding moving on from the topic of sovereign immunity.

Ms. Pepin then inquired about the purpose of having both verbatim and summary meeting minutes. Mr. Murphy replied that it’s his understanding that several years ago IART members requested a move away from verbatim transcriptions of meetings, which were typically about 60 pages long, in favor of a summary format. He said that he thinks team members have generally been happy with the summary format, and he also noted that Ms. Pepin had asked to be provided with a verbatim transcription of the August IART meeting.

Ms. Pepin asked why the regulators delayed approval of meeting minutes on past occasions. Ms. Grillo replied that in one instance the Massachusetts Department of Environmental Protection (DEP) held up approval because she hadn’t determined in time whether DEP’s Millie Garcia-Surette had any comments on minutes from a meeting where she (Ms. Garcia-Surette) had provided several answers to questions raised at that time. Mr. Murphy confirmed that there were no further comments on the August and September 2003 IART minutes.

Agenda Item #2. Responses to Action Items

Mr. Schlesinger referred to Action Item #1 and inquired about the map that shows cranberry bogs within a one-mile radius of Camp Edwards. It was noted that the map was distributed to team members in tonight’s handout package, and would be discussed later during “Open Discussion.”

Mr. Hugus noted that a group of IART citizen members is still waiting for a response to a letter sent to Mr. Gonser about two months ago. Mr. Gonser replied that a response is in the mail and IART members should be receiving it within the next couple days.

Mr. Mullennix referred to Action Item #3 and asked the U.S. Environmental Protection Agency (EPA) to confirm whether it’s true that it still considers lead at the Massachusetts Military Reservation (MMR) to be an imminent and substantial endangerment to human health. Mr. Walsh-Rogalski replied that EPA looked at the totality of circumstances at MMR when it issued its original Administrative Order (AO). At that time EPA made a legal determination, which is believed to hold true – that “there’s still an imminent and substantial endangerment.”

Mr. Mullennix explained that he raised this issue because his research indicates that there has been no mention of lead over the past approximately four years of IART meeting minutes. He said that his understanding is that lead is not being found in groundwater at all, and that past analyses of lead in soil at the training ranges and berms showed lead at depths of 10 to 11 feet below ground surface. He also said that it’s his understanding that fate and transport modeling indicates that it would be 200 years before lead would show up in groundwater, which doesn’t seem to him to be an imminent and substantial endangerment. Mr. Mullennix then noted that EPA Region 2 published a document on best management practices for lead at outdoor shooting ranges, which describes different methods for preventing lead contamination from entering the ground and the groundwater. He said that he thinks it might be time to consider resuming the use of lead ammunition at MMR. He then asked that EPA Region 1 invite the experts from EPA Region 2 to a future IART meeting to make a presentation on best management practices for lead.

Mr. Walsh-Rogalski replied that EPA would consider his request. He also said that Mr. Mullennix should look to the case law that defines “imminent and substantial,” which he believes would show that the facts, as they exist, meet that determination. He noted that EPA believes that “any use of lead in this aquifer presents a risk.” Mr. Walsh-Rogalski further stated that the AOs were based on data that indicated that lead was found in groundwater in concentrations as high as 18 parts per billion (ppb).

Mr. Mullennix said that in 1997, when there was a rush to investigate contamination in the northern part of the base, concern about lead might have been added in with other concerns. However, since that time, more information has become available, and he’s simply saying that he’d like to see a presentation to the IART on EPA Region 2’s best management practices for lead. Mr. Walsh-Rogalski asked whether EPA Region 2’s document refers to best management practices over sole-source aquifers. Mr. Mullennix replied that that question could be asked when EPA Region 2 made its presentation. Mr. Walsh-Rogalski asked Mr. Mullennix to provide EPA Region 1 with a copy of his research, and Mr. Mullennix agreed to do so.

Ms. Pepin noted that the date at the top of the September IART meeting minutes is incorrect, and should be changed to September 23, 2003. She also asked if the regulators prefer verbatim transcripts of IART meetings, while citizen team members are provided with summaries. Mr. Borci explained that the regulators requested a verbatim transcript of the August minutes to compare with the summary document, but do not ask for verbatim transcripts on a regular basis.

Mr. Hugus stated that he supports EPA Region 1’s position on protecting the citizens of Cape Cod from lead contamination. He said that he would oppose the Guard resuming the use of lead ammunition, which he’d consider equivalent to knowingly contaminating soil at the firing ranges. He also noted that the Guard cooperated with the effort to end the use of lead ammunition. Mr. Judge agreed with Mr. Hugus and added that he thinks that examining this issue now would be a waste of time and of the taxpayers’ money. Ms. Conron said that she isn’t at all interested in hearing a presentation like Mr. Mullennix described, and doesn’t think it would fit in with the team’s efforts toward cleanup progress. She noted that the IART’s time is limited, and suggested that the information that Mr. Mullennix obtained could be distributed to team members.

Mr. Mullennix noted that EPA Region 2’s manual refers to practices that “have been proven to effectively reduce or eliminate lead contamination.” He said that he thinks that allowing the use of lead at shooting ranges—without contaminating the groundwater—is an important issue for military readiness.

Mr. Walsh-Rogalski said that the National Guard Bureau seems proud of its transition to the use of environmentally safe ammunition and is applauded by EPA for that. He said that the transition is also happening elsewhere in the country, and he doesn’t know whose interests would be served by pulling back from the environmental advancements the Guard has made.

Ms. Grillo stated that she would see that the Environmental Management Commission receives a copy of the EPA Region 2 document.

Mr. Cambareri noted that the area in question was established as the Upper Cape Water Supply Reserve by the state legislature, with agreement by the Department of Defense (DoD) and the Governor. That agreement includes environmental performance standards, as well as provisions for land use activities, which would seem to make resumption of the use of lead ammunition on the training fields difficult – with the goal of protecting the water supply.

Agenda Item #3. RRAs for Soil at the J-2 Range and J-3 Range Demolition Area

Mr. Hill stated that while the Demo 1 area is a relatively compact and well-defined operable unit where investigations are essentially complete, such is not the case at the Southeast Ranges, a larger area where investigations are ongoing. He said that through the J-2 and J-3 Range RRAs, the IAGWSP will make use of existing data and attempt to address known areas of contamination while continuing to evaluate incoming data from ongoing sampling.

Mr. Hill reported that five point sources were identified for excavation at the J-2 Range: Disposal Area 1, Disposal Area 2, the twin berms, and Firing Points 3 and 4. About 1,000 tons would be excavated from the twin berms, about 100 tons from the Firing Points, about 10 tons from Disposal Area 1, and about 500 tons from Disposal Area 2. He displayed a map that depicted magnetic imaging at the J-2 Range Disposal Area 2 and noted that some of the anomaly areas represent waste disposal through burning and burial. He also said that Disposal Area 2 is the presumed source of recently detected groundwater contamination emanating to the north from that area.

Ms. Adams asked if Mr. Hill is referring to tons of soil or tons of debris. Mr. Hill replied that the numbers pertain to the volume of soil, which is calculated based on the boundary lines shown in the graphics and an excavation depth of one or two feet. Ms. Adams then asked whether the numbers are based on soil concentrations. Mr. Hill replied that they’re based on the contaminants seen in the areas to be excavated versus the clean soil that surrounds them. He also noted that the intent of the J-2 and J-3 RRAs is to make use of the thermal desorption unit (which is being brought to the base to treat Demo 1 soils) while it’s on site. Ms. Adams asked how the excavation areas were delineated. Mr. Hill replied that they are based on contaminated soil grids versus clean soil grids, and in fact the excavations will scale part way into clean areas. Ms. Adams then inquired about the definition of “contaminated” versus “uncontaminated.” Mr. Hill replied that the areas slated for excavation have relatively high contaminant concentrations that generally exceed 500 ppb. He also said that the IAGWSP, along with the regulators, would evaluate new data as they become available and determine whether the volume of soil to be excavated should be increased. Ms. Adams also asked if one contaminant is driving the numbers. Mr. Hill replied that the numbers are driven primarily by explosives and perchlorate, and added that the J-2 Range is primarily explosives and propellant compounds.

Mr. Hill continued with his presentation by showing an aerial view graphic of the J-3 Range. He said that the J-3 RRA focuses primarily on the J-3 Demolition Area, which includes a detonation pit and burn area, a former burn box, and an area north of Target 2. He noted that expansion of the excavation areas would be considered as more data become available. He also noted that the J-3 Demolition Area is the presumed source of the J-3 Demolition Area plume, which travels south to Snake Pond.

Mr. Hill reported that the RRAs involve excavating the soil and screening it to remove materials larger than two inches. Soils considered non-hazardous according to Resource Conservation and Recovery Act (RCRA) standards would be treated in the thermal desorption unit, and soils deemed hazardous would be taken off site. Corollary plans are pending with the regulatory agencies to set the parameters on the hazardous soil waste stream, as well as the ordnance and explosives (OE) debris waste stream. Waste streams will be established and in place for all material pending removal at Demo 1, the J-Ranges, and elsewhere on post. Mr. Hill noted that post-excavation sampling would be conducted.

Mr. Hill stated that the public comment period on the J-2 and J-3 Range RRA workplans opens tonight. Comments can be submitted by phone, by e-mail, on the web site, or by speaking into the microphone at this meeting. The IAGWSP will incorporate comments based on the public comment period and regulatory review, then finalize the RRA workplans, and aim to begin excavating by spring 2004. The results of this work should establish any baseline for the follow-on processes of the feasibility study and remedy selection.

Mr. Borci informed the team that EPA’s basic comment on both the J-2 and J-3 RRA workplans was that they lacked flexibility. The areas slated for excavation seem very limited, and some lack sufficient data to bound the contamination and understand what volume is truly contaminated. Before even drafting its written comments, EPA brought its concerns to the IAGWSP, which was very receptive and understood that through the comment resolution process and after the public comment period, the workplans would be revised in order to build in more flexibility. Mr. Borci noted that excavation areas currently shown on the maps are not necessarily exactly what will be excavated and addressed, and that flexibility should appear in the revised draft workplans that are produced following the public comment period.

Mr. Schlesinger asked what would happen if thermal desorption could not address perchlorate in the soil. Mr. Hill replied that a treatability study is being pursued to evaluate the efficacy of the thermal desorption process with respect to treating perchlorate. If it’s demonstrated that thermal desorption cannot treat perchlorate, a separate waste stream would have to be used. Mr. Nixon added that he could address this question further during his presentation on Demo 1.

Mr. Schlesinger inquired about propellants being found in Disposal Area 2. Mr. Hill explained that at Disposal Area 2 excess and energetic materials were dumped and burned in pits as a means of disposal, which differs from other areas where there was surface deposition. The excavation at Disposal Area 2 is intended to go below the bottom of any pit that’s discovered, and the waste streams will be set up to manage whatever materials are excavated.

Mr. Schlesinger also inquired about the fate of hazardous waste that’s taken off site. Mr. Hill replied that it would be transported to a hazardous waste disposal facility permitted by EPA. He also noted that there are no such facilities on Cape Cod.

Mr. Schlesinger then asked if any steel plates had been found at the ranges. Mr. Hill replied that a number of steel plates (which were used as targets for penetration tests conducted by weapons testing contractors) have been found and managed as scrap.

Mr. Dow noted that areas to be excavated were determined based on contaminant concentrations of 500 ppb. He also inquired about state or federal cleanup standards for explosives or propellants. Mr. Hill replied that most of the areas to be addressed by the RRAs have contaminant concentrations quite a bit higher than 500 ppb, the mechanism used to differentiate between relatively clean and relatively contaminated material.He said that the IAGWSP hadn’t gone through the cleanup level development process for these RRAs, but wants to use the thermal desorption unit to the greatest extent possible and address known high-concentration areas.Mr. Dow explained that he’s concerned that if a high cutoff level is used, even after the hotspots are removed, a broad contaminant source area would remain. Mr. Hill replied that post-excavation sampling would indicate how well the source areas have been remediated.

Mr. Dow also said that it’s his understanding that there are no RCRA standards for most of the explosives and propellant contaminants being addressed by the IAGWSP. Mr. Hill explained that RCRA regulations prescribe certain hazardous characterization test methods, and if material meets the criteria for hazardous under RCRA, it would be managed as hazardous waste. Mr. Dow mentioned a leaching test. Mr. Hill replied that a whole battery of tests, including a leaching test, would be run. He said that excavated burn material would be presumed hazardous, handled separately, and evaluated per the battery of RCRA hazardous characterization test methods.

Mr. Dow then asked whether the treated soil would be returned to the excavation sites at the J-2 and J-3 Ranges. Mr. Hill replied that it would be brought to the Demo 1 depression, as would the Demo 1 soils that are excavated and treated.

Mr. Borci referred to Mr. Dow’s question about cleanup standards, and noted that EPA had commented that using an “arbitrary number” is “not the way to define a site.” He said that EPA is comfortable with a 120-ppb level, which is the reporting limit for RDX, and which has been used in past removal actions. He said that there’s been no agreement on a cleanup number, and EPA commented that the Guard should build in flexibility so that the true source of contamination to groundwater could be removed – and EPA believes that means going to 120 ppb.

Mr. Judge said that he wants to thank all involved for initiating the work at the J Ranges. He also noted, however, that he’s concerned that contamination has been detected in the zones of contribution (ZOCs) for water supply well 3 (WS-3) and WS-2. Mr. Judge said that alternate water supplies must be sought quickly if the areas of contamination at the ranges are found to be expanding quickly.

Mr. Hugus questioned why RCRA standards would be used for the contaminated soil, when the driving standards for the cleanup are under the Safe Drinking Water Act (SDWA). Mr. Walsh-Rogalski explained that the RCRA standard is just being used to determine one of two remedies for the excavated materials: off-site disposal for materials that fail a RCRA characteristic test, or thermal desorption for materials that are not considered hazardous under RCRA.

Mr. Hugus then asked how many of the anomalies shown on the map of Disposal Area 2, Polygon 2 are still anomalies. Mr. Hill replied that the magnetic signature areas within the black outline have been excavated, and most of that magnetic ferrous material has been removed from the site. He also noted that the IAGWSP will consider looking at a couple areas outside of that outline as part of the J-2 RRA. Mr. Hill also said that while dozens of magnetic anomalies still exist at the Southeast Ranges, very few remain unidentified at Polygon 2. Mr. Hugus noted that if something becomes known it’s no longer an anomaly. Mr. Hill agreed, and said that unknowns do still exist. Mr. Hugus inquired about the percentage of knowns versus unknowns. Mr. Hill replied that he can’t say for certain, but perhaps about 25% of the anomalies have been dug up. Mr. Hugus then asked whether any radiological testing was done on the steel plates that were found. Mr. Hill replied that the plates were tested and no evidence of radioactive contamination was found.

Mr. Hugus also inquired about the high levels of perchlorate in soil. Mr. Hill replied that they exist primarily in the J-3 detonation pit area, although most of the contamination there is RDX. He said that perchlorate is found there in localized areas, not widespread like at the rest of the J Ranges. Mr. Hugus questioned why the perchlorate would remain in shallow soil, given that it dissolves so quickly. Mr. Hill said that the perchlorate being seen at the detonation pit is the result of intensive burning of rocket motors with solid propellant. He also noted that much of that mass probably has reached the groundwater. Ms. Dolan stated that witness interviews indicate that the burning activities occurred there during the 1970s and 1980s. Mr. Hugus said that he would assume that there were massive quantities of perchlorate there if 30 years of rainfall hasn’t dissolved it past the shallow soils.

Mr. Walsh-Rogalski said that it would be useful if public comments on the J-2 and J-3 RRA workplans focused on two issues: cleanup levels that the excavations should reach, and the notion of increased flexibility so that the plans can address larger areas of contamination as necessary.

Ms. Pepin asked if the RRAs came about because of high-level contamination in groundwater or in soil. Mr. Hill replied that the J-2 and J-3 RRAs are for soil. Ms. Pepin observed that only three monitoring wells appear on the J-2 and J-3 maps provided in the handouts. Mr. Hill noted that hundreds of monitoring wells exist in the Southeast Ranges; however, tonight’s maps focus primarily on the soil RRAs. Mr. Borci added that at J-2 Polygon 2, the J-3 detonation pit, and the J-2 twin berms, groundwater contamination has been documented at the source.

Ms. Pepin asked whether other contaminants, such as volatile organic compounds (VOCs), were detected in monitoring wells near the contaminated soil. Mr. Hill replied that very minor and sporadic detections of VOCs have occurred in a very small number of samples, and are thought to be the result of the use of accelerants to initiate burning activities.

Ms. Pepin noted that the J-2 and J-3 Range fact sheet states that the purpose of the RRAs is “to reduce or eliminate an apparent source of groundwater contamination. Mr. Hill confirmed that the majority of the proposed excavation areas are either documented or potential sources of contamination to groundwater. Ms. Pepin also asked if any contamination from the ranges has been detected in WS-1, WS-2, or WS-3. Mr. Hill replied that no contaminants have been detected in the water supplies themselves; however the ZOCs extend toward the apex of the aquifer, the J Ranges are located at the apex of the aquifer, and investigations are ongoing.

Mr. Borci clarified that removal of all the contaminated soil would not mean that the groundwater would be cleaned up instantly, as it would take some time for the remainder of the contamination to flush through the system. He also noted that the plumes that exist downgradient of the J-2 and J-3 ranges show further cause for why the RRAs are going to be done, and he asked Mr. Gregson to point out those plumes and their source areas later during the “Investigations Update.”

Mr. Schlesinger remarked that he definitely thinks that flexibility should be built into the RRA workplans in order to accommodate further contamination that’s identified. Mr. Hill noted that the RRAs are essentially a starting point, and the intent is to evaluate data that come in over the winter, as well as post-excavation sampling, and treat as much material as possible while the thermal desorption unit is on site.

Mr. Mullennix asked whether some soil is so contaminated that it would be trucked immediately off site. Mr. Hill replied that any soil with burnt ash material would be presumed hazardous, run through the battery of hazardous characterization tests, and managed accordingly.

Mr. Minior of the Air Force Center for Environmental Excellence (AFCEE) asked whether the intent of the RRA project is to achieve a “clean closure” result, or if it’s to remove sources of high-level contamination and then later conduct a feasibility study to determine further actions based on post-closure sampling. Mr. Hill replied that unlike the Demo 1 RRA, which proposes a large-scale closure style removal action, the J Ranges investigations are ongoing, and the IAGWSP is not pursuing total closure for the J-2 and J-3 sites as part of that RRA project. Rather, the intent is to knock down the highest concentrations and, in so doing, attack the presumed source areas for groundwater contamination.

Mr. Borci remarked that that statement is not completely consistent with conversations between EPA and the Guard. He indicated that it’s his understanding, for example, that the intent of the J-2 RRA is to remove the source of contamination for the plume that’s emanating from J-2 Polygon 2, which is primarily RDX, perchlorate, and some TNT breakdown products. Mr. Hill said that it’s hoped that the flexibility would achieve that. Mr. Borci stated that cleanup work at the entire site known as J-2 would not be complete after the RRA, but the intent is to stop any source of contamination to groundwater from the specific source areas there.

Mr. Judge questioned whether the IAGWSP would “go after” more contamination if it’s found. Mr. Hill replied that the IAGWSP would act on the data that are available. Mr. Judge stated that it’s now known then that “the more you find, the more you’re going to go after.” Mr. Hill agreed and added “whether it be during this round of RRAs, or in a subsequent effort.” Mr. Judge said that this tells him that cleanup of any additional contamination that’s identified would become part of some future RRA, and he is not in favor of that type of cleanup. He said that he doesn’t consider the proposed effort to be a rapid response, but “an initial 10% rapid response of something that may be 100%.”

Mr. Hill stated that the RRA workplans are scoped, funded, and on contract. However, there appear to be some additional monies that might become available and the IAGWSP will attempt to use those monies to expand what’s in the workplans, in concert with whatever agreements are reached with the regulators. Mr. Judge asked that those monies be secured now so they’ll be ready when further soil removal is required, and the need to find new water supplies can be avoided. Mr. Hill said that that’s not really the intent of the expandability and flexibility that’s being discussed. Mr. Judge then asked that EPA demand that flexibility and expandability immediately, given the importance of being able to clean up contamination that could threaten the drinking water supply wells. He also said that he doesn’t think that a lack of funding can be used as an excuse.

Mr. Borci clarified that EPA has asked the Guard to build flexibility into the RRA workplans, and the Guard has agreed to do so. Therefore he thinks Mr. Judge’s concerns will be addressed. He also noted that EPA is not expecting the RRAs to run for years and come across every bit of contamination that exists at the J-2 and J-3 Ranges. However, it’s believed that the source of contamination causing the plume that’s headed toward WS-2 has been identified, and the RRA workplan will address that source. He said that that’s the kind of flexibility that EPA wants to see built into the workplans, and suggested that Mr. Judge might want to make that comment on the plan. He also noted that EPA thinks that the Guard should approach the J-3 and J-2 sites in the same way, by knocking out the sources of contamination coming from them. Mr. Judge confirmed with Mr. Murphy that the comments he makes tonight will go on record, and said that he wants an “expandable Rapid Response Action to get this thing taken care of.”

Mr. Walsh-Rogalski asked Mr. Gregson to clarify the approach to the RRAs, as discussed and agreed to during a meeting that Mr. Hill hadn’t attended. Mr. Gregson stated that Mr. Borci accurately described how the J-2 and J-3 RRAs would work, with flexibility built into the excavation – similar to past RRA excavations at the armored personnel carrier and Mortar Target 9.He said that he discussed this with Mr. Borci, Mr. Pinaud, and Mr. Walsh-Rogalski, and is in agreement that the plans will be structured in order to remove contamination identified in areas on the J-2 and J-3 Ranges. He also noted, however, that what makes these RRAs different than the Demo 1 RRA, is that once these are done, additional investigation and cleanup work will be required at other areas yet to be identified on the ranges. Those will be handled either in future RRAs or as part of the feasibility study process.

Mr. Minior commented that “rapid response” means removing the root of the problem, not necessarily eliminating all contamination at a site, which would mean a formal cleanup plan.

Mr. Schlesinger asked Mr. Gregson to spell out exactly what the flexibility is, and suggested that it might be a certain percentage of the project cost. He also said that he supports Mr. Judge’s comments because he too believes that the groundwater must be protected promptly, without having to wait extended periods of time because of contracting issues or funding issues. Mr. Gregson replied that the flexibility is the flexibility to respond to what’s seen in the field when the excavations are being conducted. Closure samples will be collected as excavation is being done, and if it’s found that agreed-to cleanup levels haven’t been reached, the excavation will continue.

Mr. Pinaud said that it seems that the question was whether the flexibility is a function of cost. Mr. Gonser said that the project would be limited by cost in that there’s only so much money available. However, a lot of funds have been dedicated to it, there is flexibility to move funds among sites, and the IAGWSP anticipates being able to handle the contamination that’s identified. He also noted that the IAGWSP was able to initiate these RRAs by using money from savings on other aspects of the program. He said that the IAGWSP has been quite successful in rearranging funds to cover the RRAs, which are a high priority for everyone. Contracts were awarded at the end of September with last year’s money, and more money can be added this year – not only what was programmed, but perhaps some additional.

Mr. Hugus said that he thinks that the investigations at the rest of the J Range areas should occur in parallel with the RRAs. He then noted that he supports EPA’s request for flexibility, but also thinks that the citizens should be apprised of the “real controlling factors” in decisions made by the IAGWSP. He said that he wants an open-ended cleanup and, as a citizen and a taxpayer, wants to be kept informed about how funding issues are affecting the progress of the RRAs.

Ms. Pepin asked Mr. Gonser to identify the source of the savings that were used to fund the RRAs. Mr. Gonser indicated that the funds hadn’t come from one specific project, but from savings on initial estimates for various projects throughout the program.

Mr. Gonser then stated that from the IAGWSP’s perspective, it’s cost effective to do as much source removal work as possible now. He explained that the treatment equipment is available, the contractors are mobilized, and removing more contamination now means spending less money for cleanup later. He said that it’s not only better for the environment, but also would save money that could be used elsewhere.

Agenda Item #4. Investigations Update

Demolition Area 1

Mr. Nixon stated that the goal of the Demo 1 RRA for soil is to address the hotspot contamination and reduce any potential impacts to groundwater. He noted that the anomaly removal effort is about two-thirds finished, and he displayed a map that showed the forty-five 100’ x 100’ grids at the Demo 1 area. He said that the clearance work has been completed at the yellow grids, and at the red grids, which also have been quality control checked by a U.S. Army Corps of Engineers (USACE) unexploded ordnance (UXO) specialist. He also pointed out that the number of excavations and the number and types of items found are listed on each grid. Those items include OE and small arms ammunitions that were taken to the contained detonation chamber (CDC), as well as OE scrap metal.

Mr. Nixon then pointed out the excavation area, and noted that excavation is expected to begin in about two weeks, following completion of UXO clearance. He explained that at the kettle hole in the center of the Demo 1 area, where excavation will be done to about 8 feet, clearance and excavation will be done alternately until natural, undisturbed soil is reached. He reported that 15,000 cubic yards, or about 25,000 tons, of soil would be removed from Demo 1, and noted that this amount is equivalent to about 850 full-size dump trucks. He also pointed out the 1-foot depth and 2-foot depth excavation areas outside the kettle hole.

Mr. Nixon stated that the excavated soil would be screened at the site before being transported to the nearby thermal desorption treatment unit. Although the original RRA involved soil washing technology, it was decided that thermal desorption was preferable because of cost and the difficulty of dealing with water during winter months. The regulators are on board with this decision, but with some reservations, including whether the technology will be able to treat perchlorate. Mr. Nixon noted that a treatability study is scheduled to begin next week at a Colorado laboratory. The study will look at RDX-contaminated and perchlorate-contaminated MMR soils, mix them together, determine the concentrations of both contaminants, and, if necessary, spike the design concentrations of the study, which are 100 ppb and 100,000 ppb for the two separate runs. The runs will be done at different temperatures within the operating range of the thermal desorption system, at different resonance times, and under different oxygenated conditions—normal atmospheric and oxygen-depleted—to determine what will work. Mr. Nixon noted that the highest perchlorate concentration at Demo 1 is 27 ppb. He then stated that if thermal desorption doesn’t work, the plan is to conduct a backup laboratory-scale treatability study that involves adding another chemical (which he thinks is some kind of lime additive) to the soil as a catalyst.

Mr. Schlesinger expressed concern about excavated soils from the J Ranges, which he understands are going to be brought to the Demo 1 area. Mr. Nixon assured him that if J Range soils couldn’t be treated for perchlorate, they would not go into the hole at Demo 1. He also noted that J-2 Polygon 2 is one of the sources for soils that will be used in the treatability study.

Mr. Nixon then stated that the soil would be analyzed before and after treatment to determine removal efficiencies. He also noted that so far one burn pit has been encountered, and material from that area will be analyzed for RCRA constituents and be transported to an off-site landfill if determined to be RCRA hazardous waste. Mr. Nixon said that he believes the landfill is located in New York State, and added that there are no such landfills on Cape Cod.

Mr. Nixon also stated that the thermal desorption system will be regulated under an air discharge permit from DEP. The permit application has been filed and is currently under a 120-day review period. Mr. Hugus inquired about the treatment train for emissions. Mr. Nixon began describing the entire treatment system by noting that 20 to 30 tons of soil (per hour) goes into a tumbler where it’s in contact with propane-driven flames at temperatures around 500 to 1200 degrees, which drive off the contaminants and any organic materials. The treated soil goes into a pugmill where it’s rehydrated with clean water, and then goes out through a long conveyor belt into separate piles. Samples from each pile are collected and analyzed for each day’s run, and if determined to be clean, the soil is returned to the Demo 1 hole.

<>Mr. Nixon stated that the first step in the off-gas treatment train is a cyclone where particulates are removed and then transported to the pugmill with the clean treated soil. He noted that one of the regulatory agencies questioned whether the particulates would really be clean, and the IAGWSP is considering conducting some sampling to prove that. He then said that the gasses proceed to a chemical oxidizer, at a temperature of about 2000 degrees, where the contaminants are destroyed. The next step is a baghouse filter, where any remaining particulates are removed and also transported to the pugmill. Then, the air is quenched and cooled before being emitted to the atmosphere through the vent stack.

Mr. Hugus said that in order to provide comment, the team should know the removal efficiency of the system. He also asked if the system includes a carbon filtration unit for the air emissions. Mr. Nixon replied that it does not. Mr. Hugus said that he thinks there should be carbon filtration unless it can be demonstrated that the emissions will be clean enough. Mr. Nixon stated that that demonstration would be part of the proof-of-performance tests at startup. He also said that the chemical oxidizer would destroy anything that a carbon filter would be able to remove.

Mr. Dow inquired about the schedule for using the thermal desorption unit. Mr. Nixon replied that treatment of Demo 1 soils is scheduled to begin in early January 2004 and last about 10 weeks, and treatment of J-2 and J-3 Range soils is expected to begin in the spring, sometime in late March or early April. Mr. Dow asked when the treatability study results would be available. Mr. Nixon replied that the study starts next week, and if a backup study isn’t required, results should be available about two or three weeks after that.

Mr. Schlesinger inquired about a stack filter associated with the propane power source. Mr. Nixon explained that the exhaust, which is what drives the contaminants off the soil, goes with the entrained contaminants through the treatment system he described. He said that no organics would be left, and the cyclone and the baghouse would remove any particulates. Mr. Schlesinger asked what happens to the material collected in the baghouse. Mr. Nixon replied that the material is pulsed out and goes into the pugmill with the treated soil. He then reiterated that one of the regulatory agencies raised the question of whether the particulate material would really be clean, and the IAGWSP is considering doing some sampling from the cyclone and the baghouse during the proof-of-performance period.

Mr. Nixon also mentioned that the exact same thermal desorption unit was used successfully at the Kansas City Army Ammunitions plant to treat 6,000 cubic yards of RDX-contaminated soil (at higher concentrations than those seen at Demo 1 and the J Ranges), resulting in below detectable concentrations in the effluent. Mr. Schlesinger expressed concern about the fate of the baghouse material that remains at the end of the operation, given his understanding that that material is looped through the unit with soils entering the system. Mr. Nixon clarified that the particulate material in the baghouse would already have gone through the system, and therefore should be as clean as the soil that goes to the pugmill. He also noted that once the system is shut down, any remaining treated material is cleaned out of the unit. Mr. Nixon further noted that detailed information and a diagram of the thermal treatment unit are contained in the soil treatment plan that was distributed to IART members.

Mr. Nixon then stated that the IAGWSP has received regulatory approval for the Demo 1 RRA groundwater treatment system, which is designed to capture the bulk of perchlorate and RDX contamination in a relatively quick manner – faster than the feasibility study.

Mr. Nixon reported that an innovative technology evaluation (ITE) is scheduled to begin in January 2004 at the Pew Road system, located toward the downgradient end of the Demo 1 plume. The purpose of the ITE is to determine which of several different media is most effective at removing low concentrations of perchlorate (probably less than 5 ppb at Pew Road). RDX has not reached that part of the plume, and it’s hoped that the Frank Perkins Road system will prevent that from ever happening. The ITE will involve pumping the Pew Road extraction well (EW-2) at 9 gallons per minute (gpm) and running that water through three separate treatment trains: two types of ion exchange resin and one type of carbon. An extra carbon-polishing step will follow, after which the water will be discharged to the ground. Mr. Nixon stated that the ITE is scheduled to take about six months, and once it’s completed, the IAGWSP will bring in a containerized treatment system that handles roughly 100 gpm coming from EW-2. He noted that EW-2 has been drilled, and well screen installation there begins tomorrow.

Mr. Nixon then showed a cross-section figure depicting the Pew Road system and pointed out the clay layer that underlies the plume. He noted that EW-2 was drilled through the clay layer. The planned injection well has not been drilled yet, and so it hasn’t yet been confirmed whether that clay layer extends to that location.

Mr. Nixon displayed a figure showing the Frank Perkins Road system, which is made up of an extraction well and two injection wells – one north of the plume and one south of the plume in plan view. He pointed out the RDX plume and the perchlorate plume outlines, and noted that the zone of influence will extend downgradient beyond the extraction well, which will be pumped at 220 gpm initially. He explained that the extracted water would be transported through a pipeline to the treatment system and then to the two injection wells.

Mr. Nixon showed a cross-section figure depicting the Frank Perkins Road system and pointed out the lines that represent the static hydraulic head, or the effect on groundwater elevation from pressure exerted by the extraction well. He also pointed out the injection wells and noted that the well screen in one of them was relocated deeper in the well casing after it was discovered that low-level perchlorate concentrations existed at the originally planned screen depth. He noted that each injection well would handle 110 gpm. Mr. Nixon said that the goal of the system is to capture as much of the plume as possible, 98%, and if necessary, the flow rate would be increased in order to meet that goal.

Mr. Nixon stated that two drill rigs would be working to install the extraction and injection wells. He also noted that the contract has been awarded, a pre-construction meeting with the contractor occurred about two weeks, and installation of the Frank Perkins Road system pipelines is scheduled to begin in about two weeks. Construction of the Pew Road system pipelines would begin after that.

Mr. Nixon also said that the ongoing Demo 1 feasibility study would determine what other actions need to be taken in order to adequately capture the plume in accordance with criteria set by AO#3, good engineering practice, and other applicable things, such as the Massachusetts Contingency Plan (MCP). He said that this might entail more extraction wells or higher flow rates at the existing extraction wells, and the flexibility to take such actions will be built into the RRA systems. He noted that the feasibility study is due in January, and the IART would be provided with an update around that time.

Mr. Nixon reported that the IAGWSP is pursuing several different avenues with respect to the Military Construction (MILCON) issue. One is to actually go through the MILCON process, which would take longer than is desirable. Another is a legislative exemption that the Army drafted and sent to DoD, which is currently taking it up through the federal government. Another is handling the project as a service contract through the USACE, and an answer is expected this week on whether that would be legally feasible. Mr. Nixon mentioned that this option would take a lot of the control away from the program. He also said that another possibility being considered is to build a temporary system that would not be subject to the MILCON process. Mr. Nixon said that progress is being made on this issue and the IAGWSP is now waiting for some answers. He said that if the legislative exemption and service contract fall through, the temporary system is an option, and the IAGWSP would keep looking at other ways to use whatever funding is available.

Ms. Pepin asked for a definition of “innovative technology evaluation.” Mr. Nixon explained that because perchlorate is a relatively new contaminant of concern, the development of treatment technologies lags behind that for other contaminants, such as benzene and PCBs. He said that the IAGWSP is trying to find different methods that will efficiently remove perchlorate concentrations from groundwater and soil. He also noted that at some huge systems in California, ion exchange wellhead treatment is being used to treat drinking water supplies. However, as far as treating low-level concentrations of perchlorate, there is still much work to be done to determine the most efficient method. Ms. Pepin asked which methods would be evaluated under the ITE. Mr. Nixon replied that three different treatment media—a reusable ion exchange resin, a disposable ion exchange resin, and a carbon—are going to be evaluated. Mr. Gonser clarified that the technologies themselves are in fact existing, proven technologies; they are considered innovative from the standpoint of using them to treat lower perchlorate levels. Mr. Nixon added that if the treatment trains that are evaluated don’t work, the extracted water would be treated with granular activated carbon, which is effective, but not very efficient. Ms. Pepin also asked if “construction issues” noted on one of the presentation slides refers to funding. Mr. Nixon replied that it does.

Ms. Adams inquired about permitting with respect to groundwater discharge. Mr. Nixon replied that the IAGWSP has asked DEP to look at exemptions in its groundwater discharge permit. He said that at this point the permitting issue is unresolved, but the IAGWSP will be talking with DEP soon to determine what the outcome will be. Ms. Adams asked how long the permitting process would be expected to take. Mr. Nixon replied that it would probably take a couple months to prepare the permit, but he doesn’t know how long it would take for DEP’s review and approval. Ms. Adams said that this should be factored into scheduling issues. Mr. Nixon agreed.

Mr. Hugus inquired about the intention of the November 14, 2003 milestone date associated with Demo 1. Mr. Gregson said that when the Demo 1 RRA was first proposed, the IAGWSP was asked to established a milestone date for startup of a groundwater system, and November 14, 2003 was established as that date. Since that time, however, a number of occurrences required pushing out that date, and the IAGWSP is currently working to establish a reasonable startup date for the RRA groundwater systems.

Mr. Hugus asked to hear about the funding problems that affected the startup date. Mr. Gonser replied that funding was not a constraint for this particular project, and noted that when he took over as manager of the IAGWSP he determined that the time estimate to achieve startup was inaccurate. He said that in fact the struggle last year was to get the project far enough along that the money that was budgeted for it could be obligated by September 30, 2003, which it was. He also said that he doesn’t think that all the complexities of building the IAGWSP’s first pump-and-treat system were anticipated. Mr. Gonser stated that right now the MILCON issue is not delaying the project, and the hope is that the issue can be addressed in time to prevent that happening. Mr. Nixon added that the need to respond to unexpected occurrences such as the discovery of low-level perchlorate contamination in the injection well caused project delays.

Mr. Hugus said that he recalls Mr. Gonser having said at last month’s IART meeting that funding through MILCON was a problem. He also said that he was under the impression that the original startup date was going to be missed because of poor planning associated with the cost required to get the project done on schedule. Mr. Gonser clarified that it’s been known for quite some time that next summer was a more likely startup date. He also said that what was discussed at last month’s meeting was not that funds aren’t available. The funds are available, but the issue is the authority to use the funds for this type of project, which the USACE determined to be a construction project. He noted that the IAGWSP is looking into different approaches to solve the problem. It’s hoped that the project won’t be affected, and people in Washington are hustling to make sure that it won’t.

Mr. Hugus stated that it wouldn’t make sense to the public that the cleanup program has money for the Demo 1 project but can’t spend it. He said that he thinks there’s only one recourse if the IAGWSP can’t meet the November 14, 2003 date, and that is a penalty imposed by EPA. He said that he doesn’t have the patience to wait another six months to discuss actually treating groundwater at Demo 1, especially when a funding matter such as this should have been anticipated and resolved by people whose job is to do just that. Mr. Hugus said that he’d like EPA to enforce the milestone.

Mr. Nixon stated that, as Mr. Gonser pointed out, the money issue has not delayed the project thus far, although it’s possible that it could in the future. He noted that contractors are starting work on the pipeline next week, well drilling is under way, and the project is moving ahead. Mr. Hugus mentioned the timing of the six-month ITE as an example of poor planning, and suggested that it should have been done this past spring, rather than next year.

Mr. Borci noted that when the deadline for system startup was first set, the plan was for an extraction well at the toe of the plume and a cutoff extraction well at the center of mass. Project delays began, however, when the IAGWSP put forward a system that did not include a well at the toe of plume, but at Pew Road, farther back from the most downgradient perchlorate detections. That was one of the issues that caused delay over the course of the past year. Mr. Borci said that if that hadn’t occurred, "the train would have just been farther down the tracks before it got derailed" by the MILCON problem. He also said that when the deadline passes, EPA would look at the big picture and examine all the reasons why it wasn’t met. He said that there might have been some short delays that could have been programmed into the startup date, but EPA thinks there are some major issues here that should have been avoided.

Mr. Schlesinger stated that he too believes that EPA should enforce the milestone date. He questioned the purpose of having milestone dates if they are not met or enforced, and suggested that EPA assess a penalty that would make the IAGWSP improve its management of this project. He also said that while he agrees that some progress is being made, "letting it go" is not the way to handle this situation.

Mr. Gordy remarked that he thinks the IAGWSP did a good job of delineating the plume, both in the vertical and horizontal. He also said that it would be enlightening to the public to know how much contaminant is actually there in terms of concentrations, weight, and volume. He then noted that the main mechanism of contaminant distribution is dilution and a certain amount of rainfall occurs at the area of the plume. Mr. Gordy noted that it should then be possible to determine whether the plume is actually advancing to a point where it could cause problems, or whether it is actually retreating. He suggested that before spending money on a pump-and-treat system, the IAGWSP should first think about whether that will really accomplish anything, and he doesn’t think that it will. He said that if rainwater is diluting the contaminant concentrations to well below dangerous levels, then the IAGWSP is just wasting money.

Mr. Nixon replied that offhand he doesn’t know the numbers for perchlorate and RDX contaminant mass in the plume, but could provide that information in the future. He also noted that some sporadic low-level detections have occurred in the three monitoring wells at the toe of the plume. After several more sampling rounds at those wells, which haven’t existed for very long, it should be possible to look at trends over time and determine whether the leading edge of the plume is static. Mr. Nixon said that he doesn’t have the data yet to say, but he thinks there’s a good chance that that front is more or less static.

Mr. Butler asked to be provided with the fiscal year 2004 budget for the cleanup program, since funding issues seem to be raised at every IART meeting. He also remarked that a glossary of Guard terms would be helpful, given that "innovative technology" appears to mean "old and proven," "construction issues" appears to mean "lack of MILCON funding," and "November 14, 2003 milestone" appears to mean "summer of 2004." Mr. Butler further remarked that although the IAGWSP may have money appropriated, since it doesn’t have the authorization to spend it, he thinks that saying that it has the money is nonsense. Mr. Murphy said that he thinks Mr. Gonser could respond to Mr. Butler’s request for the 2004 budget.

Mr. Dow stated that beyond arguing about enforceable milestones with respect to the letter of the law, he has a more fundamental concern, which is the spirit in which the agreements are made. He noted that when the military extended its base lease for 25 more years, it made a commitment to try to expedite the cleanup process, and he’d like the Army, EPA, and DEP to "come up with something to move forward in the spirit." He also said that he thinks the military has been opposed to conducting the cleanup under the SDWA, and consequently seems to be "dragging its feet."

Ms. Conron inquired about progress made on the MILCON issue since last month’s IART meeting. Mr. Gonser replied that in an effort to obtain permission to use the existing funds for the Demo 1 construction project, individuals at the Pentagon drafted legislative language. That language was run through the staffing of all the Army organizations, approved by the Secretary of the Army, and sent up to the DoD to include in the package that the President sends to Congress with the fiscal year 2005 appropriations and authorization bills. With respect to the service contract option, the USACE has done a complete legal analysis of the fiscal law issues. That analysis was sent to USACE headquarters in Baltimore and then forwarded to Washington, where it’s been under review for a couple weeks, and the IAGWSP expects to hear this week whether that situation is doable. Also, the USACE already has prepared a service type contract so that it can be launched quickly, should it be approved. Mr. Gonser noted that the IAGWSP also is looking at some fallback options, but does anticipate that the project won’t be delayed at all by the funding issue. He also mentioned that a different source of funds is used for all other military cleanup projects across the country, and use of those funds has been exempted from the MILCON process. Ms. Conron asked Mr. Gonser to provide another update at the next IART meeting. Mr. Gonser replied that he hopes to be able to report at that time that the issue has been resolved.

Mr. Mullennix said that he thinks everyone shares the frustration of the funding difficulty, but he also thinks that everyone wants to have that funding, and immediately. He also said that he appreciates all the hard work that’s being done to try to find a way to move past the funding roadblock and get the Demo 1 system built.

Mr. Walsh-Rogalski asked if it’s correct that the Office of the Secretary of Defense (OSD) had approved the legislative language. Mr. Gonser clarified that the language was approved by the Army and is now being reviewed at the OSD. He said that the OSD has not yet signed off on the language, but he’s gotten feedback that indicates that no problems should be expected. Mr. Walsh-Rogalski then asked whether the language, if approved by OSD, would become part of the DoD appropriations bill. Mr. Gonser replied that if DoD approves it, it would be submitted along with the entire DoD budget package to the Office of Management and Budget, and assuming no changes are made there or by the President, it would be forwarded to Congress as part of the 2005 appropriations. Mr. Walsh-Rogalski asked when in the year the DoD appropriations bill is typically enacted. Mr. Gonser replied that it’s normally not until the end of the fiscal year, so it could be as late as September 2004 before construction could begin. He explained that submittal of the legislative package could be helpful in the future, but the IAGWSP doesn’t want to have to rely on it for the Demo 1 project, and this is why other avenues, such as service contracts or other sources of funds, are being pursued.

Mr. Walsh-Rogalski asked whether the legislative language that’s been drafted could be part of a different piece of legislation, other than the DoD appropriations budget. Mr. Gonser replied that while that wouldn’t be the normal process, it is a possible that a member of Congress could introduce it into some other legislation. He also noted that even the fiscal year 2004 appropriations bill hasn’t been passed yet. Mr. Walsh-Rogalski said that he thinks it would be helpful to attach this legislative fix to whatever legislation will move through most quickly. Mr. Gonser replied that the IAGWSP is certainly going to look at that possibility. It will also explore the approach of making specific requests to certain Congressional committees for authority to use the funds – an approach previously used on the Environmental Restoration Account (ERA) side before programs using ERA funds were granted exemption from the MILCON process.

Mr. Schlesinger asked whether the IAGWSP has tried to enlist the aid of Congressman Delahunt, Senator Kennedy, and Senator Kerry to resolve this issue, or whether he’d like the citizen team members to contact them. Mr. Gonser explained that it wouldn’t be appropriate for his organization to carry that message to the local representatives, but the language has been prepared and certainly could be used in any number of forums. Mr. Schlesinger said that if the IAGWSP would provide him with the legislative language, he’d be very willing to initiate contact with the representatives. Mr. Gonser said that the IAGWSP certainly would respond to any inquiries from the congressional staff about what’s happening with the cleanup program.

Western Boundary

Mr. Gregson reported that after 13 sampling rounds with nondetect results, a low-level perchlorate concentration was detected in a monitoring well near water supply well #6, which itself is sampled and a weekly basis and continues to test nondetect.

Northwest Corner

Mr. Gregson reported that profile sampling at MW-287 yielded perchlorate detections at 1.66 ppb to 0.3 ppb in five intervals, from zero to 35 feet below the water table, with the highest concentration at the water table.

Mr. Gregson also noted that low-level RDX concentrations, from 0.31 to 0.88 ppb, were detected recently in the M2 and M1 screens at MW-284. He reminded the group that the health advisory for RDX is 2 ppb, and also reported that RDX was detected at 0.41 ppb in the shallow screen at MW-270, the well that had perchlorate detections from water table to bedrock.

Mr. Gregson then stated that some preliminary results have come in from soil sampling being conducted along Canal View Road. He pointed out the grid where perchlorate was detected between 15 ppb and 18 ppb and the grid where it was detected at 64 ppb. He said that concentrations seem to drop off toward the north, and noted that additional results are expected.

J-2 Range

Mr. Gregson showed a map of the J-2 Range and pointed out Disposal Area 2 and MW-289, which had a 270-ppb perchlorate detection in profile sampling, and a recent perchlorate sampling result of 140 ppb. He noted that the well to the east had significantly lower perchlorate detections, between 0.43 ppb and 1.1 ppb, and that the downgradient well, J2P-29, is in the process of being drilled. He also noted that the groundwater model for that area was recalibrated and particle tracks were run to help determine the projected migration of contamination there. He pointed out the approved well locations on the map and said that the next well will be drilled either to the east or downgradient, on Jefferson Road, depending on results from well J2P-29.

Mr. Gregson also mentioned that low-level perchlorate and RDX concentrations were detected in two new wells at the L Range. He said that 33 additional wells are planned to continue investigations at the Southeast Ranges.

Ms. Pepin inquired about the high-level detections of VOCs and SVOCs in Western Boundary wells, which she saw in the data table handout. Mr. Gregson replied that he doesn’t recall seeing such data, but would take a look and get back to Ms. Pepin with an answer.

Mr. Judge asked about the timeline for drilling monitoring wells in the ZOC for WS-2. Mr. Gregson referred to the map, pointed out the wells in the ZOC, and noted that they are a top priority and are being drilled right away.

Mr. Schlesinger questioned whether sampling for perchlorate and RDX would be done in the ZOC for WS-3. Mr. Gregson noted that, based on available data from wells in that area, it appears that any perchlorate and RDX contamination is "off the edge" of that ZOC. Mr. Schlesinger indicated that the ZOC, as drawn, might not accurately reflect present conditions. Mr. Gregson replied that this could be discussed as part of a future agenda item on how ZOCs are generated, and what a ZOC is. He also noted that the WS-3 ZOC is based on a one million gallons per day (1 mgd) pumping rate. Mr. Schlesinger asked if there are no plans to pump WS-3 at greater than 1 mgd. Mr. Gregson said that he doesn’t think there’d be a need to exceed that rate at this time, but couldn’t commit to that, as he is not the manager of the water system. Mr. Schlesinger noted that he sees no data points on the map to back up the assumption that the perchlorate contamination is off the edge of the ZOC and not in fact going right down the center of it. Mr. Gregson agreed to report back to the team on existing and planned monitoring wells that would better define contamination within the WS-3 zone of contribution.

Agenda Item #5. Open Discussion

Mr. Murphy noted that he’d called Mr. Judge to set up a time to discuss his membership on the IART and EPA’s flexibility in that regard. He said that while EPA is not looking to ask people to leave the team, the concern is that Sandwich be adequately represented, especially given the ongoing issues that affect that town. Mr. Murphy then suggested scheduling a “process check-in” item for the next meeting agenda to review the team groundrules. He also mentioned the possibility of extending the length of that December meeting by 30 minutes.

Mr. Judge said that the first time he heard that he was being asked to leave the team was earlier this evening when Ms. Conron inquired whether someone was being asked to leave. Mr. Murphy tried to explain that he’d wanted to discuss a transition with Mr. Judge. However, Mr. Judge continued by expressing his great displeasure about this situation, and saying that he’d like a letter (from the person at EPA who issued the directive) requesting that he leave the team, and would like to discuss that letter at the next IART meeting. Mr. Murphy noted that he’d asked to schedule a meeting with Mr. Judge to talk about the process that EPA envisioned, and he said that he thinks it’s premature to advance to the next stage before having that meeting. Mr. Judge insisted that he wanted a letter from EPA asking him to leave.

Ms. Conron stated that the composition of citizen members on the IART is very critical to her. She said that she’d like to have a discussion about this at the beginning of the next meeting, rather than at the meeting’s end, when she’s tired. She also said that she hopes that in the meantime no one from EPA writes that letter to Mr. Judge.

Mr. Schlesinger said that he too hopes that letter isn’t written before the team’s discussion at the next meeting, and he hopes that Mr. Murphy doesn’t have any conversations with Mr. Judge about this issue before hearing the IART’s opinions. Mr. Schlesinger then noted that for five years the IART has been trying to find people who take an interest in the team’s activities, and Mr. Judge is “one such gentleman.” He also said that people who don’t live on Cape Cod, but who vacation and own property on Cape Cod, have as much interest in what’s happening here as do full-time Cape Cod residents. He added that he thinks it would be ludicrous for EPA to suddenly institute guidelines to “sideline” a person who shows interest, attends meetings, participates, reads all the materials, and stays abreast of all the information pertaining to the cleanup program.

Mr. Mullennix stated that he’d like to echo Mr. Schlesinger’s comments. He said that he would hope that Mr. Judge, who has put a tremendous amount of commitment and effort into the IART, could remain on the team, perhaps as a member at large.

Ms. Pepin questioned the grounds on which EPA would ask Mr. Judge to leave the team. She noted that Paul Zanis was a team member while living in New Hampshire, and that neither Ms. Hayes nor Mr. Kinney, who are currently team members, live in one of the four towns that surround the base. Mr. Murphy said that this topic needs to be discussed at the next IART meeting. He also noted, however, that the design was for Cape Cod citizens to be on the team. He also said that he probably misspoke when he said Mr. Judge was being asked to leave, and had actually talked to Mr. Judge about transitioning out, which “might mean a different thing.” He also assured that team that Mr. Judge would not be getting a letter from EPA before the next IART meeting.

Agenda Item #6. Adjourn

Mr. Murphy adjourned the meeting at 9:22 p.m.

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