Impact Area Review Team

River River Drops of rain on a leaf

Impact Area Review Team
Bourne Best Western
September 23, 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
LTC Dave Cunha HQ Camp Edwards 508-968-5883
Todd Borci US EPA 617-918-1358
Margery Adams US EPA 617-918-1733
Len Pinaud MA DEP 508-946-2871
Evelyn Hayes IART/Yarmouth Port 508-362-1785
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
Jim Stahl TOSC 781-255-5537
Amine Dahmani TOSC/UCONN 860-486-2781
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
Mike Minior AFCEE/MMR 508-968-4670  
Meghan Cassidy US EPA 508-968-4670  
Jane Dolan US EPA 617-918-1272
Will Kingkade MDPH 781-774-6611
Kevin Hood TOSC/UCONN 860-486-2546  
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
Pat Skelly Citizen 508-524-3948
George Seaver CCA 508-564-4404  
Amanda Lehmert Cape Cod Times 508-548-9300
Dave Heislein MACTEC 781-245-6606  
Richard L. Waxman ASW 402-488-3983
Mike Krokosz ECC 402-202-1229
Rob Paine ECC 508-229-2270
Paul Nixon ECC    
Darren Smith ECC
Mike Goydas Jacobs Engineering 508-743-0214  
Carolyn Fordham Terra Tech/Ellis 303-526-1991
Diane Short DSA/Ellis 303-271-9642  
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. Judge asked for a map that identifies all cranberry bogs surrounding the base, and that the topic of potential threat to the bogs from perchlorate be included on the October Impact Area Review Team (IART) meeting agenda. Mr. Schlesinger asked that that agenda item be expanded to include perchlorate effects on all ecological receptors.
  2. Mr. Judge requested that the U.S. Environmental Protection Agency (EPA) provide a legal opinion regarding the difference between cleanup standards and substantive cleanup standards.
  3. Mr. Mullenix asked that EPA provide an answer to his query about the imminent and substantial endangerment to human health from lead in groundwater.
  4. Meeting attendee George Seaver asked to be provided with information about timeframes associated with recovery of soils that have undergone thermal desorption treatment.
  5. Meeting attendee David Dow asked that it be determined whether any areas of "different" vegetation exist in the Northwest Corner area, which might suggest a burial site/source area.
  6. Mr. Mullennix made a formal request that EPA and the Massachusetts Department of Environmental Protection (DEP) work with the National Guard to receive permission from the tech school to conduct soil sampling and groundwater monitoring at the fireworks launch area.
  7. Ms. Pepin asked to be provided with a verbatim transcript of the August 26, 2003 IART meeting minutes.

Future Agenda Items:

  • Massachusetts Department of Public Health Update
  • Gun and Mortar Firing Positions Workplan
  • Cranberry/MMR Issues
  • WS-2 Zone of Contribution
  • Meaning of Zones of Contribution
  • Mass Flux Approach to Assessing Potential Threat to Snake Pond

Handouts Distributed at Meeting:

  1. Responses to Action Items from the August 26, 2003 Impact Area Review Team Meeting
  2. Presentation handout: Investigation Update
  3. Map: RDX in Groundwater Northwest Corner
  4. Data Tables
  5. Presentation handout: Groundwater Flow Near the Cape Cod Canal
  6. Press Releases, Neighborhood Notices, and Media Coverage: 8/27/03 9/18/03
  7. Impact Area Groundwater Study Program Update: September 2003

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

Mr. Murphy convened the meeting at 6:07 p.m. He noted that the August IART meeting had run significantly over the allotted time and asked the team members to strive toward more efficient discussion this evening. He also noted that the decision was made to continue videotaping IART meetings, with the video camera directed at the presentation screen and not focused on any individual team members. He said that videotapes of the meetings would be made available to anyone who wants to see them.

Review Draft Agenda

Mr. Murphy reviewed the meeting agenda. Mr. Judge noted that he'd requested that the agenda include an item on cranberry bogs surrounding the Massachusetts Military Reservation (MMR). He said that he'd like all the bogs to be identified, and wants to inform the Cape Cod Cranberry Growers' Association that the IART is looking into perchlorate issues regarding cranberries, just as ethylene dibromide (EDB) in cranberry bogs had been investigated. He asked that this topic be included on the October IART agenda. Mr. Schlesinger mentioned his concern about perchlorate getting into food supplies, and suggested expanding this topic to encompass the question of whether all ecological receptors to perchlorate are being assessed accurately.

Ms. Hayes questioned the mandate for discussing cranberry bogs off base. Mr. Murphy said that the project managers would discuss the appropriateness of the item and how such a presentation would be crafted. Mr. Hugus noted that EDB contamination from MMR had been detected in cranberry bogs in Falmouth. He also suggested that a first step toward looking into possible perchlorate contamination would be to have the bogs plotted on a map, relative to contaminant plumes. Mr. Judge said that he wants that map ready for the next IART meeting, and asked for assurance that this item would be on the October IART agenda. Mr. Murphy assured him that it would be included, but said that it remains to be seen exactly what the item will be.

Approval of August 26, 2003 IART Meeting Minutes

Mr. Murphy asked if there were any comments on the August 26, 2003 IART meeting minutes.

Ms. Pepin referred to the last line in the fifth paragraph on page 5, "Ms. Pepin echoed that concern." She said that she did more than echo Mr. Judge's concern about legal loopholes, and had in fact said that she didn't want any party looking for loopholes, didn't want any base contamination coming into her home, and thought that the number of attorneys who attend IART meetings versus the number of citizens who attend is unfair, causing her to be concerned about "who is advocating for who." Ms. Pepin also referred to the first full paragraph on page 6 and noted that the minutes do not, but should, include Mr. Gregson's answer to a question posed by Mr. Judge. She further noted that on page 5, just before the "Investigations Update" portion of the agenda, Mr. Murphy had asked the team to come to consensus on a topic, and that also is not reflected in the minutes. Mr. Murphy said that he didn't recall asking the team to come to consensus on a topic at that time. Ms. Pepin assured him that he had, and explained that she's sensitive to such occasions as she's gone through three years worth of IART minutes looking for times when Mr. Murphy has asked for the team's consensus.

Mr. Judge referred to page 5 and said that an opinion he'd solicited from the Air Force attorney was not included in the minutes. Mr. Murphy clarified that the attorney to whom Mr. Judge is referring is in fact an attorney for the Impact Area Groundwater Study Program (IAGWSP). Mr. Judge asked that the attorney's name and response be included in the minutes. He also said that half the discussion about substantive cleanup standards and half the individuals involved in that discussion are missing from the minutes. Mr. Judge further noted that he considers the word "substantive" to be "very much a huge legal loophole." He said that the two lawyers at the August IART meeting were unable to provide the team with a straight answer to the question of the difference between cleanup standards versus substantive cleanup standards, and therefore he's now asking that EPA provide the team with its legal opinion on this matter.

Mr. Dow of the Sierra Club, a regular meeting attendee, referred to the first full paragraph on page 13, which reflected his question about the effect of thermal desorption technology on organic matter in soil. He said that the minutes do not, but should, include his point that the removal of organic matter from soil influences the soil's productivity and water-holding capacity such that it's unable to support plant life.

Mr. Murphy said that the revised version of the August IART minutes would be provided to the team members, who could then reconsider them for approval at the October IART meeting.

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

LTC Cunha announced that, effective yesterday, he was transferred from his position as Deputy Commander of Headquarters Camp Edwards, where he'd been for the past two years. He stated that everyone at Camp Edwards works hard to ensure technical and tactical training for soldiers while ensuring environmentally sound practices. LTC Cunha said that he's been transferred to the Environmental & Readiness Center (E&RC), where he'll serve as an administrative officer, probably focusing on the "readiness" side, given his operations background. He also acknowledged that there have been some contentious times working with the IART, but added that he thinks that "people pushing forward for what they believe" is a good thing.

Mr. Hugus said that he learned today, by way of a phone call from the press, that Governor Romney is expected to sign the MMR lease extension tomorrow. He noted that a number of citizen IART members commented on the lease extension, most objected to it, and none received any response to their comments. Mr. Hugus said that he only learned that the extension would be granted because the press contacted him, and so he wanted to let other people know.

Ms. Hayes remarked that LTC Cunha has been a very positive factor on the IART, and has poise and balanced judgment. She said that she thinks the National Guard has done a superb job, although many positive things that happen on the base don't seem to be identified at the IART table. Ms. Hayes said that she very much appreciates the work of LTC Cunha and his team.

Responses to Action Items from the August 26, 2003 IART Meeting

Mr. Mullenix referred to Action Item #7, and said that he is satisfied with EPA's response to his question regarding whether perchlorate levels identified in the Northwest Corner are believed to pose an imminent and substantial endangerment to public health. He also noted, however, that he'd like an update on EPA's position on the imminent and substantial endangerment to public health posed by lead in groundwater. He said that he's heard no discussion about lead over the past two years he's been attending IART meetings, yet in EPA's original Administrative Order (AO), lead was cited as a contaminant of imminent and substantial concern or endangerment. Mr. Murphy asked if Mr. Mullennix was looking for a written response. Mr. Mullennix replied that it's his understanding that lead has been was found in surface soils, but not in groundwater. Therefore, he's interested in information pertaining to lead fate and transport, and would be looking for a little more than a written response, unless it's a fate and transport report.

Mr. Borci stated that a significant amount of lead was removed from soil during the lead berm removal project, a main effort of the cleanup program when it began in 1997. He explained that many actions under the program and the Safe Drinking Water Act (SDWA) are preventative. Therefore, if modeling indicates that lead contamination could reach the water table in 200 years, actions to prevent that should be taken, especially when the most cost-effective method is to remove the contamination immediately. Mr. Borci said that he believes that AO#1 asked for that specifically, and he thinks that the IAGWSP could pull that report out of the archives. He also invited Mr. Mullennix to contact him if that report didn't answer all his questions.

Mr. Mullennix noted that he's aware of the lead berm project, but is really looking for a reassessment by EPA of the lead situation today, and is wondering about the possibility of using lead bullets again on the base. He said that he's looking for a judgment as to whether or not lead is still considered to be an imminent and substantial endangerment to human health.

Agenda Item #3. Investigations Update

Demolition Area 1 (Demo 1)

Mr. Nixon showed a figure entitled "Demo Area 1 Anomalies," pointed out the 100-foot grids, and noted that the colors represent metal anomalies detected by an EM61 magnetometer survey. He reported that field crews, including trained unexploded ordnance (UXO) technicians, have removed the metal objects from 22 of the 45 grids. He noted that progress is expected to slow down a bit as the removal effort moves toward the center of Demo 1, where more explosives detonations occurred. He also mentioned that a U.S. Army Corps of Engineers (USACE) specialist is performing quality-control checks of the grids after the removal of metal objects.

Mr. Nixon reported that to date 13,000 metal anomalies have been identified and removed from Demo 1. Most of the objects are small arms munitions, and four items (three 3.5-inch rockets and one 40-mm rifle-launched grenade) had to be blown in place, which occurred without any problems. He explained that the UXO clearance, which should be completed by late October/early November, is a prerequisite to excavation and thermal desorption treatment of Demo 1 soil. He also reported that by weight 1,500 pounds of ordnance/explosives scrap and 1,300 pounds of metal waste have been removed. He said that 511 ordnance/explosives items, including 406 small arms munitions, have been recovered so far.

Mr. Schlesinger inquired about the depth of extraction. Mr. Nixon replied that right now clearance is being done to a 2-foot depth, but where excavation will be more extensive, clearance will be done to a foot below excavation depth. At times it will be an iterative process. For example, at the center of the kettle hole, where an 8-foot excavation depth is anticipated, clearance and excavation will be done alternately until natural undisturbed soil is reached. Mr. Schlesinger asked if magnetometers would be run during that process. Mr. Nixon replied that hand-held magnetometers would be used during the process, and after excavation is complete, the EM61 magnetometer, which has a deeper penetration depth, will be run again over the entire area. He also noted that the plan is to do excavation to one foot on the outside perimeter of the area, to two feet closer to the center, and to a minimum of eight feet in the center of the kettle hole, although more excavation might be required, depending on soil sampling results.

Mr. Nixon stated that in the next few weeks the IAGWSP anticipates receiving final approval from the regulators on the Rapid Response Action (RRA) plan for Demo 1 soil, which was sent out on September 11, 2003. He noted that the plan deals with soil excavation, treatment, and restoration, which includes bringing topsoil from other areas on base to cover the treated soil after it's returned to Demo 1. He said that it would be a long time before the treated soil could support any vegetative growth, and something like hydro-seed probably would be used to help start that process. Mr. Nixon also noted that copies of the draft RRA plan were sent out to IART members.

Mr. Nixon stated that an internal review of the perchlorate treatability study occurred on September 12, 2003. A literature search confirmed that perchlorate should be very treatable by thermal desorption. The treatability study will be conducted in Colorado, where MMR soils will be tested for perchlorate concentrations before and after undergoing thermal desorption.

Mr. Schlesinger inquired about the source of MMR topsoil to be used for restoring the Demo 1 area. Mr. Nixon replied although the restoration plan hasn't yet been finalized, the understanding is that a lot of the topsoil would be available from work being done near the runways. Another potential source of topsoil is from an area just off MMR, at the Bourne landfill.

Ms. Hayes asked about the timeframe for results of the treatability study. Mr. Nixon replied that after the RRA plan is approved, MMR soils will be sent to Colorado, probably sometime during October, and he thinks results probably should be available in early November.

Mr. Seaver asked why treated soil wouldn't support vegetative growth for a very long time. Mr. Nixon replied that thermal desorption heats soil to a temperature high enough to degrade all of its organic matter. Mr. Seaver noted that microbes that support vegetative growth are everywhere. Mr. Nixon agreed that eventually microbes would reestablish themselves in the soil. Mr. Seaver suggested that with rain, it would be a matter of weeks before cyanobacteria would begin to rejuvenate. Mr. Nixon said that he couldn't name the exact timeframe, which is probably site-specific. He also noted that vegetation is growing back at Mount St. Helen's, following the volcanic eruption there. Mr. Seaver questioned the point of a cleanup that destroys "the most fundamental unit of life," cyanobacteria. Mr. Nixon replied that it's a tradeoff between doing the cleanup and the microbes at Demo 1, which is about four acres in size. Mr. Seaver asked that someone determine the timeframe for when the microbes would restore themselves. Mr. Nixon agreed to see what information is available. Mr. Seaver said that he'd provide Mr. Nixon with contact information for a person at Boston University who is an expert in this field.

Dr. Dahmani said that he'd like to see thermal desorption report, and asked whether there's a public comment period associated with it. Mr. Nixon replied that copies of the report either were sent today or would be sent tomorrow, and he thinks there will be a two-week comment period. Dr. Dahmani asked if the treatability study could be fast-tracked so it would be completed before the RRA plan is reviewed. Mr. Nixon said that if the study indicates that perchlorate can't be treated by thermal desorption, it would be necessary to go back to square one and reevaluate. He also said that the expected timeframe for study results is a fairly optimistic date already, but it would be done as soon as possible. Dr. Dahmani also asked if the treatability study pertains to contaminants other than perchlorate. Mr. Nixon replied that it does not, and noted that thermal desorption already has been demonstrated to treat explosives contamination successfully.

Mr. Nixon then reported that the IAGWSP received conditional approval from EPA and DEP on groundwater treatment systems planned for Demo 1. He noted that drilling of the extraction well for the Pew Road system could begin as soon as next week, pending final approval. He also said that the IAGWSP has met with the regulators to discuss scoping the Demo 1 feasibility study. A couple issues need to be resolved, after which modeling will be done, and it will be determined what other actions are needed to clean up Demo 1, ideally in a 10-year timeframe.

Mr. Hugus asked when the Pew Road extraction well is expected to begin pumping. Mr. Nixon replied that initially the Pew Road well will be used to supply water for a treatability study to determine the best kind of filter for treating perchlorate contamination at low concentrations. This should occur in spring 2004, and several months later—probably in the summer or fall—the well will be used as the Pew Road system extraction well. Mr. Hugus inquired about other plume contaminants. Mr. Nixon replied that perchlorate is the only contaminant that's reached that area, while Research Department Explosive (RDX), other explosives contaminants, and additional perchlorate farther upgradient will be treated by the Frank Perkins Road system. He also noted that the feasibility study will look at whether more wells are needed closer to the source area. Mr. Hugus inquired about the timeframe for the upgradient effort. Mr. Nixon replied that while the construction schedule can't be laid out until it's determined what that system will be, the feasibility study should be done in January 2004. Mr. Gonser clarified that although perchlorate is now the only contaminant of concern at the Pew Road, upgradient RDX beyond the Frank Perkins Road system is expected to reach Pew Road eventually. Therefore, the IAGWSP is looking to develop a system at Pew Road that can handle both types of contamination.

Ms. Adams asked Mr. Nixon to explain why the deadline for the RRA groundwater system was delayed from November to a May/June timeframe. Mr. Nixon replied that getting concurrence on design and finalizing the RRA plan held up the date, as did the discovery of very low-level perchlorate contamination in one of the injection wells that was being drilled.

Mr. Borci said that he was expecting a quick update from the IAGWSP on the Military Construction (MILCON) issue. Mr. Gonser stated that the goal is to overcome the MILCON obstacle so it won't cause any delays in the program. He explained that money for construction of large projects must be appropriated from Congress's MILCON Committee. Operations & Maintenance (O&M) money can't be used, and there are certain dollar limits, one of which is $1 million, an amount that the Demo 1 treatment plant cost exceeds significantly. He noted that when faced with this issue a couple years ago, the Air Force Center for Environmental Excellence (AFCEE) was granted a waiver by Congress for remediation projects so that MILCON committee approval was not required. It's been determined, however, that the waiver applies only to Environmental Restoration Account (ERA) funds under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) program, and does not apply to the IAGWSP, which uses O&M funds under the SDWA program.

Mr. Gonser noted that the IAGWSP is working to deal with this issue on three fronts. The National Guard has been asked to submit a request form for a MILCON project. A request has been made for submittal to Congress of a legislative package that would extend relief beyond the CERCLA program and ERA funding to cover other programs, such as the SDWA and the Resource Conservation and Recovery Act (RCRA) program. In addition, the IAGWSP has asked the USACE to reexamine the contracting process to look at the purchase of services for cleaning up the water, versus actual construction. He said that the latter solution would probably be the fastest, while the legislative fix would be the best. He also noted that as many aspects as possible of the Demo 1 contract work have been awarded so that the project can move forward while the MILCON issue is being addressed. He further commented that it's unfortunate that the IAGWSP is the first to run up against this issue, although its resolution should ultimately benefit others. Mr. Nixon added that $1.7 million for soil excavation work was awarded recently.

Mr. Judge asked how long MILCON has been in existence. Mr. Gonser said that it's been existence for a long time, and in fact ten years ago he was the MILCON programmer for all the Army's MILCON in the Pentagon. Mr. Judge stated that the IAGWSP manager should have been prepared ahead of time for the possibility of a MILCON delay, which could be perceived as "a convenient excuse." He also said that it seems to him that there's been some resistance to moving forward with the cleanup, and it appears that the reality is that the funding isn't there. Mr. Judge then asked whether there are any EPA fines that go along with this situation.

Mr. Borci stated that EPA agrees that the MILCON situation shouldn't have occurred, but trusts that the IAGWSP is going to work through the issues. He also said that the reason the enforceable milestone date of November 14, 2003 hasn't been formally changed to a May/June 2004 date is because EPA is waiting to hear that the MILCON issue has been resolved and the spring date is solid. If the November date passes, and it's known that there will be a solid date, EPA could use enforcement discretion, not take any penalty action, and change the enforceable milestone date to one that can be met. Or, EPA could continue to wait until the MILCON issue is settled, evaluate the overall delay, and then decide what to do.

Mr. Judge said that he wants to go on record as saying that fines should start on the November date. He said that he wants EPA to demonstrate that "it does hurt" when milestone dates aren't met, especially given the MILCON situation, which he considers inexcusable.

Mr. Hugus stated that he agrees with Mr. Judge. He also said that there are National Guard employees whose job is to foresee problems and ensure that schedules are met. He further noted that he thinks this is one of the reasons why there have been so many delays, and he believes that in the long run EPA's willingness to possibly extend the deadline until May won't give the National Guard any incentive to meet deadlines. He said that he thinks enforcement action is needed, and a precedent should be set that cleanup should be accomplished in a timely manner, given that Demo 1 is the first major attempt at cleanup of a plume under the IAGWSP.

Mr. Schlesinger noted that he concurs with both Mr. Judge and Mr. Hugus. He also asked, if the contracting approach doesn't work as a solution, whether it will be necessary to go through the MILCON process for every cleanup project, or whether it might be possible to develop a situation that allows the IAGWSP to go through that process just once. Mr. Gonser replied that that is a possibility. He also said that the IAGWSP certainly doesn't want to go through the MILCON process, which can take up to five years, for every major project. He said that he thinks that before that would happen, the IAGWSP would be able to prevail upon Congress to grant relief, which would affect not only MMR, but also sites being addresses under RCRA or other non-CERCLA programs. Mr. Gonser added that the contracting side would be pursued first, and then Congressional relief would be sought. He also explained that the MILCON program doesn't deal in lump sums, but is project-specific. Mr. Gonser said that he's confident that some kind of relief would be granted, and added that, if need be, an attempt could be made "to get our own Congressional delegation involved to do that."

Mr. Schlesinger said that he thought that money was earmarked for the cleanup, and he questioned whether that money is really there or whether someone else's approval is required first. Mr. Gonser explained that the money is available, but, unfortunately it's O&M money because the cleanup is being conducted under the SDWA, whereas the AFCEE cleanup program uses remediation money. The problem is that the IAGWSP doesn't have the authority to do a major construction project using O&M funds, which Congress has specifically restricted to certain types of projects. He explained that O&M funds can be used for maintenance and repair; a certain point triggers minor construction, and a certain point, which he believes is $1 million, triggers major construction. The MILCON committee decides whether those funds will be used for a certain project or used in a different district. Mr. Gonser stated that the Army is putting together legislative language to request relief from Congress, and he feels confident that some kind of long-term relief ultimately will be granted.

Dr. Dahmani asked how other bases have handled this kind of problem. Mr. Gonser replied that virtually all other cleanup projects are being conducted under the CERCLA program, and were granted relief from the MILCON process a couple of years ago. He noted that air pollution or sewage treatment projects ordinarily have to undergo the MILCON process, whereas cleanup projects are normally conducted using ERA funds. He added that although the IAGWSP is the first to come up against this problem, it's going to need to be fixed nationwide, particularly if there are major RCRA cleanup projects.

Mr. Judge asked EPA to pay attention because he thinks this is a situation where funding for SDWA is being stopped. He also questioned what EPA is going to do about it.

Mr. Butler said that he doesn't understand why the IAGWSP is coming up short on funds, with the new federal year beginning on October 1, 2003. Mr. Gonser clarified that the program is not coming up short on funds; it has all the funds it has requested, and is going to obligate every cent it has. He also noted that in fact, by saving some money, the IAGWSP was able to add a few more projects to the program this year. He said that the MILCON issue is just one of authority to use a particular kind of fund. Mr. Butler replied that it is not then a funding issue, but a planning issue, and he thinks it's poor planning when the program has funds available that it cannot use.

Ms. Hayes asked Mr. Borci to reiterate his previous statement, which she thought was in agreement with Mr. Gonser's analysis of the MILCON situation and indicated that nobody was really responsible for it. Mr. Borci stated that EPA is concerned about the MILCON problem, trusts that the National Guard doesn't want another delay and will work to resolve the issue, and is hopeful that a May/June startup date for the Demo 1 system will be met. He also said that the IAGWSP has the money to do the work that the regulators want done next year, and the parties have sat down together to plan how the money will be spent. He further noted that he thinks that tonight's discussion has to do with policy issues, as opposed to legal issues, and added that he believes that the IAGWSP is as anxious as everyone else to have "the system in the ground."

Mr. Mullennix asked if any regulatory deadlines have been missed because of the funding issue. Mr. Borci replied that the November 14, 2003 "is the one that's on the hook right now." Mr. Mullennix noted that that date has not yet been missed. Mr. Borci agreed and said that when that date comes, EPA will consider all the reasons why it wasn't met. Mr. Hugus confirmed with Mr. Nixon that the November 14, 2003 date is not going to be met, and said that he's asking EPA to take enforcement action because of that and not grant a May/June extension.

Northwest Corner Recent Detections

Mr. Gregson showed a new map entitled "Perchlorate in Groundwater Northwest Corner" and pointed out the Cape Cod Canal, the base boundary, Canal View Road, the nondetect contour, the 1-part per billion (ppb) contour, the 4-ppb contour, and 18-ppb contour. He reported a new sampling result of 0.4 ppb perchlorate in well 4036011, at the condominium complex, and reminded the team that the method detection limit (MDL) for perchlorate is 0.35 ppb, the reporting limit is 1 ppb, DEP's advice level to the Bourne Water District is 1 ppb, and EPA's interim guidance level is 4 to 18 ppb. He noted that the water supplier and DEP were notified of the 0.4-ppb detection, and the IAGWSP has offered to resample the well and continue sampling it on a monthly basis.

Mr. Gregson reported that perchlorate was recently detected at 0.36 ppb in a residential well that had tested nondetect for perchlorate in the four previous sampling rounds. The IAGWSP notified DEP and the homeowner of the detection and offered to resample the well. He also stated that perchlorate was detected at just above 3 ppb in monitoring well 284 (MW-284), located in the northern part of the skating rink parking lot near the canal. Also, profile results from MW-283, located at the canal, showed perchlorate detections from 1 ppb to 1.38 ppb, and unvalidated well screen results that became available today showed a perchlorate detection there at about 1.5 ppb.

Mr. Gregson then reported that the IAGWSP worked with the regulators to come up with 35 soil sample locations. He said that 11 grids along Canal View Road will include 20 sample locations south of former Gun Position 19 (GP-19), and four locations south of GP-16, in a cleared area there. Additional well locations are being sited, including two upgradient locations along an existing road, and a location along the road at the scenic overlook at the canal. Other sites include a location south of the skating rink; a location outside of the tech school entrance, for which the IAGWSP is seeking access from the condominium complex and the tech school; and a location south of MW-279 and MW-278.

Mr. Schlesinger asked whether the detections at MW-278, MW-279, MW-277, and MW-66 are close to the water table. Mr. Gregson replied that they are, and noted that the highest detections have occurred at the water table. He also pointed out the plume boundary that was based on the deeper particle tracks and pointed out the area where it's suspected the source of contamination may exist. Mr. Schlesinger asked why the source is thought to be there. Mr. Gregson replied that the water table detections indicate a nearby source of contamination, assuming that it would go straight down through the soil before it reaches the water table. He said that based on what's being seen in the water, there's a fairly extensive sampling program for soil in that area. Mr. Schlesinger suggested that there had to have been some sort of range or target there. Mr. Gregson replied that there wouldn't have been a target area because it's right on the base boundary, but noted that possible perchlorate sources are smokes, flares, or pyrotechnics that could have been used in that area, or the annual fireworks display at the tech school.

Ms. Pepin asked if it's correct that well 4036011 is a public supply well, as noted on the map's legend. Mr. Gregson replied that it's actually a community water supply for a limited number of residents who live in the condominium complex. Ms. Pepin noted that at the August IART meeting, she'd inquired about the SDWA terminology for that particular well. Ms. Adams said that it's her understanding that 4036011 would be called a community water supply well. Ms. Pepin said that she thinks there are three or four different labels in the SDWA. Ms. Adams clarified that there are two: a community water supply system or a non-community system. Ms. Pepin asked whether there is still no zone of contribution (ZOC) for that well. Mr. Gregson replied that for that well DEP's files contain no official ZOC, as required for larger public water supply wells. He also noted that the IAGWSP has begun modeling work to generate a ZOC for that well, based on the existing pumping rate and well construction details. Ms. Pepin remarked that there's some differentiation then between a well that only serves a small number of people and wells such as water supply well 1 (WS-1), WS-2, and WS-3. Mr. Gregson confirmed that there's a big difference in permitting requirements for those two types of wells.

Mr. Hugus asked whether the Northwest Corner plume would be depicted on the new plume map to be included in the IAGWSP fact sheet. Mr. Gregson replied that it would. Mr. Hugus then commented that he thinks that the IAGWSP should provide an alternate water supply to the residents of the condominium complex, in whose well both RDX and perchlorate have been detected. He also said that the 0.36-ppb perchlorate detection in a private well, RSNW01, prompted DEP to send the IAGWSP a notice of responsibility (NOR) to provide safe drinking water to that homeowner, and he thinks that DEP should issue a similar NOR regarding the condominium complex community well.

Mr. Pinaud clarified that at this point the DEP has not issued an NOR to either the Army or the condominium complex owners; however, he's spoken to the water supplier about this issue many times over the past few weeks. He also said that that it's important to note that both detections in the well were just above the MDL, below the reporting limit of 1 ppb, and below DEP's 1-ppb advisory level to the Bourne Water District. He said that no adverse human health effects from ingestion are expected from those kinds of concentrations. He also said that if the levels go over 1 ppb, the issue is an issue of long-term monthly monitoring, and he believes that right now the condominium complex well is on quarterly monitoring. Mr. Pinaud further noted that DEP sent the condominium complex water supplier a letter requesting a resampling of the well and access to install additional wells there so that perchlorate concentrations in the immediate area can be determined. DEP has not yet received a response to that letter.

Mr. Minior of AFCEE reminded the team that the condominium complex does in fact have a public water supply connection to the Bourne Water District, but chooses not to use it. Mr. Pinaud confirmed that this is true, but added that it's his understanding that there are some problems with the way it's plumbed. He said that there might still be an issue regarding how much water that source can provide.

Mr. Hugus questioned whether the condominium complex residents agreed that it's okay that RDX and perchlorate are in their drinking water. He said that he doubts they would accept that if they knew they could get clean water from some other source. He also said that the IART never got a clear answer about outreach efforts at the condominium complex, and he can't accept the implication that the residents know about the other water supply but choose not to use it.

Dr. Dahmani remarked that there don't seem to be any data to ascertain the limit of the upgradient part of the plume as shown in the depiction. Mr. Gregson stated that a couple of proposed monitoring wells in the upgradient position are going to be installed to prove the depiction. He also explained that the upgradient extent was drawn based on tracking backward particle tracks from the depth of detections at the base boundary, at about 30 feet below water table, back to the top of the water table. Dr. Dahmani asked if the "hotspots" were based on just one detection. Mr. Gregson replied that profile sampling was done down to bedrock in all the new wells, and screens were set based on those results. He said that contamination was detected only at the water table at those locations. Dr. Dahmani indicated that it would be helpful to see cross-sections. Mr. Gregson agreed, and said that he doesn't know if the cross-sections have been updated yet.

Mr. Schlesinger said that because well 4036011 is only 30 to 40 feet away from perchlorate detections greater than 1 ppb, he thinks that the minimum action that should be taken is to increase the monitoring frequency of that well. Mr. Pinaud said that there's no question that higher levels of perchlorate exist upgradient from that well.

Mr. Seaver asked if MW-278 and MW-279 are located beneath the area where perchlorate was detected at 7,500 ppb in soil. Mr. Gregson confirmed that the higher detections in groundwater correspond to the areas where higher detections occurred in soil, based on the soil sampling conducted in early July 2003.

Mr. LeBlanc noted that profile sampling in MW-270 showed perchlorate detections from top to bottom, and asked Mr. Gregson to describe what was seen in the new boreholes. Mr. Gregson replied that, unlike at MW-270, at both those locations perchlorate detections were seen only in the shallower profile intervals—not right at the water table, but a little bit deeper.

Mr. Dow suggested that aerial magnetometry (air mag) might point to a burial area upgradient from the perchlorate hotspot. Mr. Gregson stated that this area wasn't included in any air mag surveys done in the past because the height needed to fly over the trees there would significantly reduce the ability to discriminate magnetic signals. He also said that other than actually looking at that area out in the field, the most valuable tools probably are archival information and historical aerial photographs. Mr. Dow asked if there are any areas where the vegetation might be "different," suggesting the existence of a burial area underneath. Mr. Gregson replied that he's not aware of any areas like that, but could look into that possibility.

Mr. Mullennix stated that in terms of trying to find the source of perchlorate contamination at the Northwest Corner, what is known is that soil sampling prior to the Fourth-of-July fireworks display showed very low levels of perchlorate in soils along Canal View Road, and soil sampling shortly after that display showed several thousand ppb of perchlorate there. He noted that the fireworks display site is located southwest of the plume along the "30" groundwater elevation contour line shown on the map, and the prevailing winds during the summer are from the southwest. He then asked whether EPA and DEP, which participated in the selection of additional soil sampling and monitoring well locations, had addressed the question of the potential for fireworks contamination when helping to select those sampling sites.

Mr. Borci said that it hasn't changed over the months that the Northwest Corner has been studied—"We are following the investigation, looking where the contamination is..." He also mentioned that training diary entries note that the National Guard conducted training along Canal View Road, specifically in that area, and perchlorate contamination has been detected in groundwater at GP-16. He said that the investigation is trying to determine exactly what is contributing to the perchlorate contamination and what the multiple causes are.

Mr. Mullennix questioned why soil sampling and groundwater monitoring, which are being conducted at the gun positions, aren't also being conducted at the fireworks display area. He said that that would be a potential source, given that several thousand pounds of perchlorate-laden fireworks were brought to that site and set off on July 5, 2003, after which high-level concentrations of perchlorate were detected on Canal View Road. Mr. Borci replied that the source of groundwater contamination appears to be at the base boundary or on the base, which is where the investigation is focused. He said that if someone wants the state or the town to look off base, at this point that would be another issue for a different forum. He also noted that well CWNW01, which is downgradient of the fireworks launch area, tested nondetect, so there is no reason to collect soil or groundwater samples there at this time. Mr. Borci further stated that if the investigation leads there, "so be it," and added that right now the investigation is following the data and using the standard scientific method. Mr. Mullennix said that he's formally requesting that DEP and EPA work with the National Guard to receive permission from the tech school to conduct soil sampling and groundwater monitoring at the fireworks launch area.

Mr. Pinaud noted that there isn't a lot of literature regarding perchlorate in fireworks. However, DEP is doing its own research on fate and transport and the interaction of perchlorate in fireworks. When that research is complete, probably within the next few months, it will be made available to the team. Ms. Hayes said she has found quite a bit of information about perchlorate on a Web site, and would let Mr. Pinaud know which site it is if he'd like.

Ms. Hayes then asked if Mr. Borci is convinced that the fireworks at the tech school have nothing to do with the contamination at the Northwest Corner area. Mr. Borci replied that he has never said that, but is saying that the investigation will go where the data lead. He also noted that the National Guard has stated that it's not saying that all of the perchlorate contamination in the Northwest Corner is the result of the fireworks, and EPA agrees with that conclusion. Mr. Borci further noted that RDX has been detected in two of the Northwest Corner wells, which leads to the belief that a there's definitely a source on base, as does historical information on nearby training, and some of the data collected on the base—all of which indicate that there could be multiple sources. Ms. Hayes said that she doesn't recall the National Guard having made such a statement, but she would review the meeting minutes.

Northwest Corner Hydrology Update by USGS

Mr. LeBlanc of the U.S. Geological Survey (USGS) showed the Northwest Corner perchlorate plume map and reminded the team that map views should be looked at very carefully because they don't show what's happening in the third dimension. He noted that the map contains a great deal more information on the hydrology and geology near the canal than was ever available before. He also mentioned that he recently read a book on the Cape Cod Canal and learned that it was first opened as a sea-level canal in 1914, and was later enlarged by the USACE in the 1930s.

Mr. LeBlanc stated that his presentation is organized to address the following questions: Is there groundwater flow across the canal? How is the canal simulated in the flow models? Where does the perchlorate discharge from the aquifer? What is the groundwater flow pattern near the canal?

To begin answering the question of whether there's groundwater flow across the canal, Mr. LeBlanc showed a map of the Cape Cod aquifer system, and pointed out the Sagamore groundwater flow cell, which is separated from the mainland by the Cape Cod Canal. He then displayed a topographic map depicting groundwater contour measurements on both sides of the canal. He noted that the freshwater mounds on either side of the canal slope and flow toward the canal, which is at sea level. He said that the water tables are quite steep on both sides of the canal, and that the Cape Cod aquifer is at its thinnest (about 100 feet thick) right at the canal. He stated that for all practical purposes, there's no chance that fresh groundwater flows under the canal—a 500-foot wide, 30-foot deep penetrating saltwater body, and a very clear boundary.

To begin answering the question of how the canal is simulated in flow models, Mr. LeBlanc showed a figure depicting the Sagamore groundwater flow cell that was made from a computer model grid that has a zero altitude water level around the outside of the cell, representing sea level. He noted that the aquifer in map view is completely surrounded be a sea-level boundary with a zero hydraulic head, and the canal is part of that boundary. Mr. LeBlanc then showed a diagram of a hydrologic cross-section of Western Cape Cod and pointed out the water table mound, the aerial recharge, the circulation flow out from the top of the mound toward the coast, and freshwater/saltwater interface at the coast. He noted that the USGS's work over the years has indicated that, except in areas like the Outer Cape where the aquifer is truncated by bedrock, the saltwater boundaries on Cape Cod are very steep. He said that at the Cape Cod Canal, where lots of flow is traveling to a defined place, the freshwater/saltwater boundary would be very steep.

Mr. LeBlanc then stated that in the 1970s the USGS drilled a series of multi-level wells to try to understand the saltwater/freshwater interface on Cape Cod. One of those boreholes is located almost directly beneath the Bourne Bridge, and includes four wells at that location, to depths of almost 100 feet. Mr. LeBlanc then displayed a line chart showing chloride concentrations in water samples taken from those wells, which illustrates that there's freshwater almost all the way down at that location, which is within about 150 feet from the edge of the canal. He said that this supports the idea that if there is saltwater beneath the canal, it really doesn't extend underneath the mainland at all. Also, as earlier noted, the aquifer becomes thinner toward the north, because the bedrock is rising and the water table is sloping downward. This tends to pinch off the aquifer, making it thinner, and causing all of that recharge to be forced out through a thinner section, which tends to push the saltwater back. The result is a dynamic balance between the freshwater trying to go out, and the saltwater, which is denser, trying to come in. Mr. LeBlanc said that it's possible that there's no saltwater beneath the canal, or if there is, it's only a small area.

Mr. LeBlanc then showed a USGS cross-sectional groundwater flow model, running generally south to north, and pointed out that the model cells that represent the Cape Cod Canal were put in as a fixed zero water level. He also noted that beneath the canal, it's "either a saltwater/freshwater interface or it's actually where the flow lines from the two sides converge." He said that the canal is called a no-flow boundary. The water is forced to come in and then it discharges to the canal. Mr. LeBlanc stated that the canal is represented as what is called a specified head, with no flow below it to the base of the aquifer.

To answer the question of where the perchlorate discharges, Mr. LeBlanc noted that it's quite clear that all the groundwater coming toward the Cape Cod Canal is discharging to the canal. However, it would be difficult to say exactly where in the canal the perchlorate is discharging, given the many local conditions that could affect that. He also noted that the perchlorate concentrations being seen at the Northwest Corner would not be detectable in the canal.

Mr. LeBlanc then referred to the final question, about the groundwater flow pattern near the canal, and noted that detailed information isn't really available. He showed a MODFLOW cross-sectional model and pointed out the "stream tubes," which show conceptually how recharge comes in at various locations and takes paths that go deeper into the system as they move toward the coast, but then rise up as they approach the canal, and discharge into it. Mr. LeBlanc noted that the models were created such that that has to happen, because it's assumed that there's no flow past the point of the canal. He also said that the top-to-bottom detections in MW-270 are very puzzling since it would seem that the bottom contamination had to have originated from a fairly far distance. Mr. LeBlanc further stated, "Obviously the shallow stuff follows a shallow trajectory and goes to the canal," and added that he doesn't think anyone has an answer for what's happening at MW-270.

Mr. LeBlanc stated that the Northwest Corner area is located at the junction of the Buzzards Bay moraine and the Buzzards Bay outwash, geologically a very complex area. He said that the USGS driller's log for the well at the Bourne Bridge notes various materials at different depths: fill, fine to medium sand and cobbles, clay, silt, gravel, sand and cobbles, and boulders. Mr. LeBlanc said that the area is very heterogeneous and not well understood, and so there's great uncertainty about local flow patterns. He displayed a line graph showing water level measurements over time at MW-270S, MW-270M1, and MW-270D, and noted that changing water levels in the canal create pressure waves that go back up into the aquifer, causing levels there to vary on the same time-scale as the tidal cycles. He said that this makes it "tricky" to look at water table mass in that area. Mr. LeBlanc stated that the varying saltwater is not included in modeling; rather, it's assumed that the canal is at zero. He said that it's quite difficult to say what's happening right at the canal, except for in the very general sense that flow must rise up and discharge to the canal.

Mr. LeBlanc concluded his presentation by noting that groundwater does not flow from Cape Cod to the mainland or vice versa, the canal is simulated as a constant sea-level hydrologic boundary in all USGS models, perchlorate ultimately must discharge to the canal, and flow lines intersect the canal, but precise flow patterns near the canal are unknown.

Mr. Schlesinger inquired about the increased speed of groundwater flow near the canal. Mr. LeBlanc replied that the water table slope is very steep near the canal, so the hydraulic gradient increases. He explained that total flow crossing any given point increases as it gets near to the canal because of incoming rainfall, and so the water tables gets steeper. He also referred to the aquifer getting thinner near the canal, and said that the transmissivity of the aquifer decreases. He said that all of these factors conspire to make the hydraulic gradient quite steep near the canal. He further noted that it's possible that the hydraulic conductivity, or permeability, of the materials there is different, unlike in the moraines, where hydraulic conductivity is thought to be somewhat lower.

Mr. Schlesinger then inquired about the distance from the canal where groundwater flow becomes complex. Mr. LeBlanc replied that conceptually the place "where it really gets tricky" is right near the canal. He mentioned the puzzling top-to-bottom perchlorate detections in MW-270, which would seem to imply that there's perchlorate from the top to the bottom of the aquifer that could be traced back. He said that no mechanisms have been identified there, such as pumping wells or septic tanks, which would explain why the perchlorate could spread through the whole thickness of the aquifer, and he doesn't think that the geology is the answer either. Mr. LeBlanc also said that rather than focusing on the complex area near the canal, he would suggest looking upstream and tracking the contamination backward from there. He further noted that he thinks that the complex area will be sorted out eventually, given the additional data that are becoming available as more holes are being drilled.

Mr. Seaver inquired about the thickness of the acceleration boundary layer near MW-270. Mr. LeBlanc replied that he hadn't looked at it in that kind of detail. Mr. Seaver said that he'd guess that it's on the order of a few hundred feet, which would encompass MW-270. He also noted that more mixing results from accelerating flows. Mr. LeBlanc agreed that more mixing occurs, and said that one thought was that perhaps the tidal cycles caused mixing in the aquifer such that the perchlorate spread out over a full 200 feet, but "that water doesn't move that much." Another thought is that where the flow converges upward at the canal, it's almost vertical, and the hole drilled at MW-270 could have gone through the axis of the plume. Mr. LeBlanc added that there aren't enough data at this time to say that that's the case.

Dr. Stahl inquired about the difference between MW-270S, MW-270M1, and MW-270D. Mr. LeBlanc replied that MW-270S is the shallow well screen, right at the water table; MW-270D is the deepest well screen, and MW-270M1 is one of the two middle well screens. He also noted that MW-270 is shown on cross-section F-F' in the presentation handout, and mentioned that all three of the well screens show tidal influence. Dr. Stahl asked if all three were sampled during the same timeframe. Mr. LeBlanc said that he believes that pressure transducers were installed in all three and run at the same time. Mr. Gregson confirmed that statement. Dr. Stahl said that he finds it interesting that two are in phase and one isn't, and then asked what Mr. LeBlanc makes of that fact. Mr. LeBlanc replied that he'd noticed that the deepest one has the largest response. He said that this probably means that there are lenses and layers of semi-confining material, i.e., clays, that give the aquifer what's called an artesian response, so as the ocean water weighs down the aquifer, the pressure is more effectively transmitted at the deep layers than at the shallow layers. He also said that he hadn't tried "to make more of it than that."

Dr. Dahmani asked whether Mr. LeBlanc thinks it's a fair assumption to treat the bedrock as a no-flow boundary. Mr. LeBlanc replied that it is a granitic bedrock, which, when it's been cored, has shown good integrity to it. He said that the hydraulic conductivity of the bedrock ought to be several orders of magnitude—if not more—than the unconsolidated materials above it. With that kind of permeability contrast, there's usually very little flow in the deeper material. Mr. LeBlanc stated that from a regional flow perspective, he thinks it's reasonable to assume that the bedrock is a no-flow boundary. Dr. Dahmani asked if there's been a good study of the bedrock on Cape Cod, and he inquired about the possibility of high-permeability fractures. Mr. LeBlanc replied that there's always the possibility of high-permeability fractures. He also said that there are a number of places on Cape Cod that have been cored to bedrock, but in terms of a study of bedrock from a hydrogeologic perspective, that has not been done. Dr. Dahmani concluded that there is then no estimate of how much of the water right next to the canal might be going to bedrock. Mr. LeBlanc agreed and said that the judgment has been that it wouldn't be worth the effort to make that determination.

Dr. Dahmani also inquired about information on vertical gradients right next to the canal. Mr. LeBlanc replied that the information is very minimal, just what he had shown. He also said that none of the wells near the canal flow because of thick unsaturated zones there, but there are definitely heads that are significantly above the canal. He added that even those that are responding tidally are quite high above the canal stage.

Dr. Dahmani then inquired about the availability of information on the permeability or hydraulic conductivity of the bottom sediment of the canal. Mr. LeBlanc replied that he's not aware of any such information. He also said that if what he's read is correct, the canal is not lined, and natural scour from the currents keeps it clean. Dr. Dahmani observed that there are many assumptions. Mr. LeBlanc agreed, but also indicated that he thinks they are safe assumptions compared to others that could be debated.

Mr. Hugus asked for Mr. LeBlanc's opinion on whether there might be a reason—having to do with the moraine or the canal—why a particle in the Northwest Corner investigation area would travel cross-gradient at about the 30-foot level of the aquifer. Mr. LeBlanc replied that some sort of anisotropy, or difference in permeability in "X" and "Y," could cause the water to flow off at an angle to the water table contours. He also noted, however, that he doesn't have that kind of information, and he hasn't seen such a case anywhere on Cape Cod. Mr. LeBlanc then said that the simplest answer is usually the right one, and his guess is that ultimately the answer will be pretty simple.

Mr. Schlesinger asked whether the area is likely to flush itself out in a period of time, if in fact the plume turns out to be self-confined. Mr. LeBlanc replied that given the high groundwater flow rates there, and given that perchlorate is "relatively conservative," he thinks that the area would flush itself out fairly quickly if there were no continuing source. He noted that the trailing edge of the Ashumet Valley sewage plume, with gradients that are dwarfed by those at the Northwest Corner area, can be tracked, and he questioned why the same wouldn't be true of the perchlorate plume. He said that his gut feeling is that there has to be some sort of continuing source, "especially when it's shallow near the water table." Mr. LeBlanc also mentioned the possibility that the plume depiction could be inaccurate.

Southeast Ranges

Mr. Gregson stated that MW-289, where profile sampling results showed a 370-ppb perchlorate detection, has been developed and groundwater sampling results are expected later this week. He also reported that profile sampling at MW-321, which was drilled east of MW-289, showed a maximum perchlorate detection of 2.1 ppb, and had a 50-foot thick interval with detections ranging from 0.44 to 0.79 ppb. He said that because it appears that the perchlorate contamination doesn't extend very far in that direction, the proposed location for well J2P-19 probably would be moved. Mr. Gregson also noted that MW-63 and MW-55, toward WS-2, tested nondetect for perchlorate, as did the chemical monitoring wells that are about five years upgradient of WS-2.

Mr. Gregson stated that the model is being updated based on some recent groundwater level measurements. He also said that planned drilling locations include a well just east of MW-12, one at Wood Road, and one at Jefferson Road, depending on results from the Wood Road well. Drilling of the next location should begin within the next few weeks. Mr. Gregson said that six additional wells have been scoped for this investigation into the detection at MW-289.

Mr. Gregson noted that the feasibility assessment pertaining to the use of the Fuel Spill 12 (FS-12) treatment plant for treating J-3 Range perchlorate and RDX contamination is ongoing, and a status meeting with the regulators occurred on September 11, 2003. He said that the IAGWSP has been working with AFCEE to look at capture capabilities of the well, the capacity of the infrastructure, and modifications that might be needed to treat the levels of RDX and perchlorate in the J-3 Range plume. Also, ecological thresholds and other aspects of the FS-12 treatment plant are being considered to ensure that the IAGWSP's use of the plant would not interfere with AFCEE's success in collapsing the FS-12 plume. Mr. Gregson said that the regulators will be provided with another update in early October, and the feasibility assessment should be completed in late October/early November.

Mr. Gregson stated that IART members should have received copies of the draft RRA plans to remove sources of contamination at the J-3 and J-2 Ranges, which appear to have impacted groundwater. He showed a map of the J-3 Range area and pointed out the three locations in the middle of the range, which are the focus of the J-3 Range RRA and are the suspected source area for the perchlorate and RDX plumes heading toward the base boundary and Snake Pond. He noted that additional assessment is being done to refine those areas, which might be expanded a little to the north and over toward the Minuteman missile test area. He said that the IAGWSP intends to complete the J-3 Range RRA plan and begin the work next spring. He also noted that last week the IAGWSP received EPA's conditional approval of the J-3 Range RRA plan, and that details of both the J-2 and J-3 RRA plans would be discussed at the October IART meeting. Mr. Gregson further reported that the J-2 Range RRA plan pertains to five areas, including Disposal Area 2, Disposal Area 1, Firing Points 3 and 4, and the twin berms area. He said that additional data are being collected to refine the extent of the excavation planned for the RRA.

Mr. Hugus observed that there are no monitoring wells between MW-289, where perchlorate was detected at 370 ppb, and MW-63 and MW-55, which are located close to WS-2, and which tested nondetect for perchlorate. Mr. Gregson agreed that there are no monitoring wells currently located within that approximately two-mile distance, and noted that the focus of the IAGWSP's work is to fill in that gap. Mr. Hugus remarked that because of the high levels of contamination and the water supply well involved in this situation, he thinks that one of the IART's first priorities should be to push investigation inside that zone.

Central Impact Area

Mr. Gregson stated that the investigation at Targets 23 and 42 would look at the distribution of UXO and the density of any low-order detonations, which are thought to be the most significant impact to soil and groundwater in the Central Impact Area. The investigation also will involve the installation of lysimeters at the sites to obtain information on leaching rates to groundwater. Information from the investigation would aid in cleanup of not only the two targets, but also the entire Central Impact Area, where another dozen or so targets have been identified as possible candidates for cleanup. Mr. Gregson said that over the next month the regulators would review the RRA plan for cleanup of the two targets. A presentation on the workplan will be given at the October IART meeting, when an informal public comment period also will begin.

Mr. Schlesinger asked if the perchlorate contamination from the Central Impact Area is considered non-point source or point source. Mr. Gregson replied that from a traditional sense it's probably considered non-point source, as is the RDX contamination. He then referred to a map and said that the purple boundary depicts the overall area of contamination in the Central Impact Area. He noted that the contamination area is based on several lines of evidence: aerial photographs that show target cratering, the air mag survey that shows distribution of metallic objects, and chemical data from soil and groundwater sampling.

Mr. Schlesinger noted that it isn't clear to him what is causing the perchlorate contamination there. Mr. Gregson said that one of the leading theories is based on LITR rounds, which are training rounds that started to be used in the mid-1980s. He explained that a LITR round contains perchlorate in the spotting charge, a puff of smoke that's released when the round hits so it's visible to soldiers at the observation points. Mr. Schlesinger asked if the perchlorate contamination is residue from the LITR round itself. Mr. Gregson replied yes, assuming that the LITR round functioned properly. He also noted, however, that it might not have detonated, but just cracked open. Mr. Schlesinger asked if the perchlorate contamination resulted through deposition from the smoke. Mr. Gregson said that the contamination could be either from residue from the smoke or from a round that malfunctioned and just broke open, exposing perchlorate. He also said that there are other possible sources of perchlorate contamination in the area. Mr. Borci agreed, and noted that some detections farther out in the Central Impact Area aren't explained by LITR rounds. He said that the source is probably a combination of everything: training, high explosives, pyrotechnics, flares, and residue that accumulated over the years.

Mr. Dow asked whether the amount of perchlorate in the plume could be used to calculate the mass of perchlorate in soil required to generate that groundwater contamination. Mr. Gregson replied that that information probably could be plugged into a model to come up with an estimate. He also said that he believes that the estimated mass of perchlorate in the Central Impact Area is about 20 to 30 pounds. Mr. Dow said that if the target studies lead to the discovery of a small amount of the total contamination, he wonders what kind of plans there would be for expanding the search to see if there's an area of concentrated contamination, or contaminant distribution over the entire area. Mr. Gregson replied that the hope is that this will be determined when the target areas are investigated. He also noted that the targets are relatively isolated, and that soil samples will be collected to see if there's any drop in concentrations as the distance from the targets increases. Mr. Dow said that it would be easier to clean up the source area if the contamination were concentrated in hotspots, rather than spread all over. Mr. Gregson agreed.

Mr. Borci noted that the investigation is going to look at an approximately 100-meter radius around each target. He also noted that the air mag data, which will be shown at the October IART meeting, include magnetic signatures for all the targets that were in the Central Impact Area, primarily centered around Turpentine Road and Tank Alley. Mr. Borci also noted that the target study would address the issue of whether there are multiple point sources, which can be excavated more easily, or whether there's just a vast area of low-level soil contamination.

Western Boundary

Mr. Gregson showed a map of the Western Boundary area and reported that perchlorate was recently detected in MW-276 at about 1.7 ppb. Also, in well WS4P-6, profile sampling showed perchlorate in one interval at about 0.6 ppb. Profile sampling results from well CBP-6 showed no perchlorate detections, but some below 1-ppb RDX detections, which might prove to be the result of interference. Mr. Gregson also noted that the next well to be installed as part of the Western Boundary investigation is CBP-7, which was scheduled to begin last week.

Mr. Hugus asked whether the Western Boundary plume would be included on the fact sheet map. Mr. Gregson replied that the intent was not to include it because plume boundaries won't be drawn until more data are available. He also noted, however, that the fact sheet map does indicate areas where perchlorate was detected by highlighting those areas in a box. Mr. Hugus said that he thinks it's important that the public be provided with a graphic that shows that a plume exists in that area, and he expressed his dissatisfaction with just "square boxes" being shown. He also asked whether there have been any perchlorate detections in the Monument Beach wellfield since the IART last heard from Ralph Marks of the Bourne Water District. Mr. Gregson replied that there have been no further detections. Mr. Hugus asked if it's correct that the last perchlorate detection was around 0.4 ppb. Mr. Gregson confirmed that it was, and said that he knows of no other perchlorate detections in the wellfield since that one.

Mr. Schlesinger mentioned that it's difficult to read the labels on the Western Boundary figure. Mr. Gregson said that the IAGWSP would look into finding a way to fix that problem.

Mr. Mullennix asked if it's correct that there have been no perchlorate detections greater than 1 ppb off base. Mr. Gregson confirmed that it is. Mr. Mullennix then reminded the team that DEP's advice level to the Bourne Water District for perchlorate in drinking water is 1 ppb, and that EPA's perchlorate investigation guidance level of 1.5 ppb no longer holds, since the January 2003 letter from EPA Headquarters (which noted an interim guidance level of 4 ppb to 18 ppb). He said that he feels very strongly that it should not be communicated to the public that there's a plume of perchlorate emanating from the base and into the Bourne water supply wells, because levels there have never been above 1 ppb. He added that he wouldn't want to create fear and worry among Bourne residents in this case.

Mr. Hugus said that a plume does exist there, whatever the levels are, and added, "It was enough for the Town of Bourne and DEP to close down water supply wells the summer before last." He said that he totally disagrees with Mr. Mullennix's position. Mr. Pinaud clarified that DEP did not close down any water supply wells.

Mr. Schlesinger took exception to the statement that there are no perchlorate detections greater than 1 ppb off base, and he mentioned the Northwest Corner perchlorate plume. Mr. Murphy said that he thinks Mr. Gregson was referring to the Western Boundary area. Mr. Gregson clarified that west of Route 28, in the Monument Beach wellfield, perchlorate has not been detected at levels above 1 ppb.

Agenda Item #4. Future Meeting Dates, Agenda Planning, Open Discussion, and Adjourn

Mr. Murphy stated that the IART would meet next on October 28, 2003, in Mashpee. He also noted that the scheduled November and December IART meeting dates conflict with upcoming holidays, and he suggests having just one early December meeting, or moving each of the two dates back one week. He said that he'd e-mail team members to get their opinions on this matter.

Mr. Hugus requested that the October IART meeting agenda include an item on the ZOC for WS-2. He also mentioned that a number of citizens on the team had addressed a letter to Mr. Gonser, but haven't received a reply.

Ms. Pepin asked to be provided with a copy of the verbatim minutes from the August IART meeting. She also said that she wants to renew her objection to the video camera at IART meetings, and doesn't want to be videotaped without knowing when a tape is going to be released. She asked that team members be notified if copies of tapes are made and distributed to others. Mr. Murphy said that team members who are uncomfortable about being videotaped might want to sit away from the presentation screen, upon which the video camera is focused. He also acknowledged Ms. Pepin's request to notify team members if copies of tapes are released. Ms. Pepin also inquired whether a sign-in sheet had been sent around the table at this meeting. It was noted that the sign-in sheet had only made its way around one half of the table. Ms. Pepin also asked why Mr. Murphy hadn't asked team members to introduce themselves at the start of the meeting. Mr. Murphy replied that he had forgotten to do so.

Dr. Dahmani noted that there seems to be some misunderstanding among IART members about what ZOCs mean, and asked that educational presentation on this topic be scheduled for an IART meeting in the near future. He also recommended a future IART meeting agenda item on a mass flux approach to assessing the threat of contamination to Snake Pond. He said that he thinks that an educational presentation of some type, perhaps 20 minutes or so at every other IART meeting, would help team members better understand the science behind the cleanup program.

Mr. Schlesinger said that he'd definitely like to have a "science explanation" at every IART meeting, given the complexity of the issues being discussed. He noted that he'd found Mr. Gregson's description of perchlorate in LITR rounds to be very useful, and would be interested in learning more about potential sources. Mr. Murphy said that he thinks it would be helpful if the technical team developed a list of suggested topics for future meetings, and added that suggestions from the citizen members also would be helpful.

Ms. Conron thanked Mr. Murphy for running the meeting so that it's ending at "a decent hour."

Agenda Item #5. Adjourn

Mr. Murphy adjourned the meeting at 9:10 p.m.

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