Impact Area Review Team
Future Agenda Items:
Handouts Distributed at Meeting:
Agenda Item #1. Welcome, Review Agenda, Approval of December 9, 2003 IART Minutes
Mr. Murphy convened the meeting at 6:05 p.m. and the Impact Area Review Team (IART) members introduced themselves. Mr. Murphy asked if there were any comments on the agenda. Mr. Schlesinger noted that there was a discrepancy between future items listed on the agenda that was mailed to the team, and those included on the agenda provided at tonight's meeting. Mr. Gonser explained that the items missing from the latest version of the agenda are in fact being carried over, but were not listed because they won't be discussed until meetings in the more distant future.
Mr. Murphy asked if there were any comments on the December 9, 2003 IART meeting minutes. Mr. Hugus noted that the word "and" should be changed to the word "an" in the last sentence of the second full paragraph on page five. The minutes were approved with this change.
Agenda Item #2. Late-Breaking News and Responses to Action Items
Ms. Cassidy announced that U.S. Environmental Protection Agency (EPA) Regional Administrator Bob Varney had provided certificates of appreciation and letters of thanks to the citizen IART members, and a news release would be issued tomorrow. She read the certificate, as follows: "In appreciation of your dedicated participation as a member of the Massachusetts Military Reservation Impact Area Review Team, which manages the unprecedented issues challenging the cleanup of Camp Edwards and serves as a citizen force for safeguarding the public health and environment of the people of Cape Cod." She said that she would distribute the documents during the break in the meeting, and she noted that certificates would be forwarded to the families of Joel Feigenbaum and Dick Prince - two IART members who had passed away, and to Paul Zanis, a former IART member who moved away from the area.
Mr. Murphy asked if there were any comments on the responses to action items from the December 9, 2003 IART meeting. Mr. Schlesinger inquired about the updated team membership list that was supposed to have been mailed out to team members. Mr. Murphy replied that the updated list was included with the handouts distributed to the team this evening. He also noted that he'd sent out an e-mail regarding procedures for canceling an IART meeting in the event of bad weather. He provided copies of the e-mail message, as well as a contact list for team members to review and update.
Mr. Schlesinger inquired about follow-up associated with the list of website addresses that the Impact Area Groundwater Study Program (IAGWSP) provided for articles pertaining to the potential for perchlorate to bio-accumulate. Mr. Gonser replied that the list was provided in response to an IART request, but he expects that the project team would also review the material. He also noted that the first step is to conduct the investigation and determine whether there's a pathway for perchlorate to get to vegetative areas, such as cranberry bogs, which were mentioned in previous meetings. Mr. Schlesinger said that he thinks it's important to look at all ecological receptors, not just cranberries. Mr. Gonser agreed and noted that the feasibility study process for each investigation will involve looking at ecological risks and impacts.
Agenda Item #3. Open Discussion
Mr. Schlesinger asked to be provided with a "working" site-wide perchlorate map that shows which areas have and have not been tested for perchlorate. He said that he wants the map to include all perchlorate detections (not just those at concentrations that exceed an "arbitrary" risk category number) for both soil and groundwater. Mr. Borci noted that the project managers have been using the map contained in the site-wide perchlorate report to determine whether additional areas on base require perchlorate sampling. He said that the map shows just groundwater detections, but consideration could be given to adding soil detections. Mr. Schlesinger mentioned his concern about ranges and berms that the IART discussed prior to the time that perchlorate testing was being done. Mr. Borci replied that the regulators actively review each IAGWSP document (such as the Phase IIb Report) to determine whether perchlorate testing should be done, and has asked the IAGWSP to go back and do testing in some areas. Mr. Schlesinger repeated his request for a map that includes perchlorate detections in both soil and groundwater. Mr. Borci indicated that he would try to see that this request is accommodated.
Mr. Judge said that he thinks that the map Mr. Schlesinger requested would be helpful in identifying areas where perchlorate might be "wicking" out of the soil, i.e., being absorbed up through the soil to the ground surface and blowing around. Mr. Schlesinger asked if the IAGWSP is doing any testing for wicking. Mr. Gregson said that soils would have to be quite close to the water table for wicking to be a concern. He noted that the only area in the cleanup program that he can think of where the groundwater is very shallow is right near Snake Pond, and he doesn't think there have been any shallow perchlorate detections there. Mr. Gregson also said that the IAGWSP can continue to "look for that type of relationship" and see if there's potential for contaminants to get into shallower soil because of capillary pressure. Mr. Judge suggested that the depth of groundwater doesn't matter as much in the sandy soil of Cape Cod. He added that he thinks a perchlorate map would be useful in terms of determining whether wicking is occurring based on detections in soil in areas over plumes, which are not known source areas.
MCP Compliance Issue
Mr. Hugus stated that last fall the IAGWSP indicated that it didn't think it was necessary to fill out the paperwork required by the Massachusetts Contingency Plan (MCP), and a recent progress report noted that Millie-Garcia Surette of the Massachusetts Department of Environmental Protection (DEP) was not entirely satisfied with the IAGWSP's adherence to the MCP. He asked to be updated on this issue.
Mr. Pinaud said that the Army currently is not in full compliance with the MCP, but has been complying with some portions in many of the submittals it's made to date. The issue has been elevated to the DEP Commissioner's office and he believes a meeting is being arranged with the Army and DEP to try to resolve it. Mr. Pinaud also noted that DEP continues to be a participant in the decision-making process and continues to perform document review and comment. Mr. Gonser agreed that an effort is being made to schedule a meeting in February.
Mr. Hugus asked for clarification regarding the lack of compliance. Mr. Pinaud replied that potentially responsible parties must comply with certain technical portions of the MCP. The Army is partially in compliance with many but not all of those. Also, the Army has chosen not to comply with administrative portions of the MCP, which pertain to paperwork, fees, and the like. Mr. Hugus compared this approach to paying taxes without filling out the associated paperwork. He noted that the Guard had said that it was willing to comply fully with substantive requirements of the MCP, but didn't want to fill out the paperwork, and he believes that this means a lack of any kind of communication, given how bureaucracies work. Mr. Hugus said that he doesn't think the Guard is acting in good faith with DEP.
Mr. Judge said that Cape Cod residents were convinced that the base lease extension would be a good thing because there would be compliance with the MCP, and when the lease extension was signed, the Governor mentioned in his speech that the military would follow MCP requirements. Mr. Judge then inquired about the penalty for failing to comply fully with the MCP - whether a fine would be imposed, or whether the lease would be pulled, and if so, at what point. Mr. Pinaud replied that the only statement he can offer at this time is that the issue has been elevated to the Commissioner's office. Mr. Judge requested that the IART be invited to attend the upcoming meeting on this issue, or at least be given the opportunity to review those meeting minutes.
Mr. Schlesinger commented that not all Cape Cod residents were convinced that the lease extension was a good thing. He also asked if the MCP is part of Massachusetts state law, and if so, whether DEP is allowed to make exceptions to the law when dealing with another state agency, i.e., the Massachusetts National Guard. Mr. Pinaud replied that the MCP is a state regulation under Massachusetts General Law, Chapter 21E, and includes the Code of Massachusetts Regulations, 40.0000. Mr. Schlesinger asked whether DEP or the Attorney General's office enforces this law. Mr. Pinaud replied that both the Attorney General's office and DEP can enforce it. Mr. Schlesinger then asked if DEP has the ability to make changes in the law in terms of enforcement. Mr. Pinaud replied that it does not. Mr. Schlesinger said that it seems to him that DEP is "dancing around this issue" and he thinks the Attorney General should be involved.
Mr. Mullennix stated that, as a Bourne resident, he feels very comfortable that DEP and the Army will work out the MCP issue.
Ms. Pepin asked EPA to comment on the recent Supreme Court case having to do with EPA's ability to override decisions made by state environmental agencies, and whether it might apply to the situation at the Massachusetts Military Reservation (MMR). Ms. Adams first noted that she believes that the National Guard Bureau and Department of Army - the federal respondents to EPA's administrative order - are the ones having a problem complying with the MCP. She said that she thinks it's quite clear under Massachusetts General Law that state agencies are subject to state environmental law; however, the Department of Army has the potential defense of sovereign immunity, an area of the law that is not entirely clear. Ms. Adams then said that she really can't comment on how the Supreme Court's Cominco decision (to which Ms. Pepin referred) might apply to a hazardous waste situation. She noted that the case had to do with an EPA order to the state of Alaska to deny issuance of a permit under the Clean Air Act for a zinc mine, as EPA's view was that the permit failed to require the proper technology. Ms. Adams said that how far that decision extends beyond the Clean Air Act is unclear at this point.
Mr. Gonser explained that the issue at hand pertains to having both state and federal laws, which are not entirely consistent. He also said that he thinks that the Army and DEP are trying to work together to keep the cleanup program moving forward despite uncertainties over the various laws involved.
Mr. Kinney questioned whether DEP couldn't resolve this issue by clamping down and making the Guard comply with the MCP, which he believes would set a positive precedent for future situations when state law is more protective of the citizens than federal law. Mr. Pinaud said that he wasn't going to try to answer that question. Mr. Kinney requested that legal opinions from EPA, DEP, and the military on the MCP compliance issue be included on a future IART meeting agenda. Mr. Murphy replied that an update on this issue might be appropriate if any progress has been made. Mr. Gonser assured Mr. Kinney that if state has a standard that's more protective than the federal standard, and is officially promulgated, the IAGWSP definitely would comply with that standard and work with the state to achieve it.
Mr. Judge commented that the term officially promulgated means to him that the IAGWSP would argue that it doesn't have to adhere to the current state "standard" for perchlorate. He then stressed that he thinks the Attorney General needs to be involved in this situation because he (Mr. Judge) believes that the military is violating state law if it's not fully complying with the MCP. He also said that he thinks this topic should be included on next month's IART meeting agenda.
Mr. Skelly said that he thinks the best way to proceed is to request specific information on which sections of the MCP the military is and is not in full compliance. Mr. Schlesinger agreed. He also said that rather than making a motion as a team, he thinks the citizens could take it upon themselves to approach the Attorney General's office with their concerns about this issue.
Mr. Cambareri said that he thinks that the compliance issue really has to do with the question of a perchlorate standard. He noted that DEP issued a health advisory level of 1 ppb to be used in evaluating the water situation in Bourne. He said that perchlorate is a "giant issue" nationally, and he thinks the military doesn't want to set precedent by adhering to a 1 ppb standard. Mr. Cambareri also said that he's glad that the Department of Defense and DEP will be meeting to discuss this issue.
Mr. Pinaud made a point of assuring the team that while the compliance issue is being worked through, DEP continues to do its job and is at the table making decisions, working with the Army and the Guard and EPA. He noted that when there was "a matter of public health risk and the Army was unable or unwilling to perform response actions, DEP performed those response actions." Mr. Pinaud further noted that DEP is identifying to the Army areas where it is not in compliance.
Mr. Judge said that he appreciates DEP's continued involvement. However, he also noted his belief that the military should be in full compliance with the MCP in order to prevent any problems in the future, and that he thinks the issue should be brought to the Attorney General.
Mr. Hugus stated that at the last IART meeting, Mr. Racheotes, the Bourne resident from Foretop Road whose private well (RSNW03) had perchlorate detections, came before the team to discuss his situation. Mr. Hugus noted that DEP, rather than the Guard, is providing bottled water to Mr. Racheotes, who has been waiting nine months for the Guard to provide a town water hookup to his home. Mr. Hugus said that he believes it's the IART's job to represent people in the community "who aren't being treated fairly," and he asked why the Guard hasn't provided a town water hookup.
Mr. Gonser noted that when he was in Washington, D.C. in December he discussed this issue with the people there and checked in with them again last week. The situation has gotten visibility at the very highest levels and efforts to resolve it are continuing. He also noted, however, that the resolution of the situation in Bourne is somewhat tied to the resolution of the broader national issue, which is that currently there is no standard for perchlorate, and there's considerable disagreement about the health risks.
Mr. Hugus commented that he finds this response to be unacceptable. He said that it seems that the Guard is not willing to open itself up to liability in this case, which DEP clearly thinks is a public health issue, as does he. Mr. Hugus added that he thinks the Guard "is in an indefensible position" and is making an "immoral" decision.
Mr. Kinney expressed his belief that this situation exemplifies how people can "get ground up" in bureaucracies. He said that he thinks that the most common sense approach, given the lack of a perchlorate standard, is to err on the side of caution and provide a town water hookup, which would not cost a lot of money, but would resolve the problem for the family on Foretop Road. He also noted that the same type of battle was fought in the early 1990s when residents of Mashpee and Falmouth were being exposed to water polluted by contaminants from the base, and the bureaucrats didn't take immediate action, despite a history of high cancer rates in this area. Mr. Kinney said that he believes the military should do the right thing and protect an individual family, not resolve the national issue about a perchlorate standard.
Mr. Judge asked whether EPA could issue an order under the Safe Drinking Water Act (SDWA) to provide water to the family on Foretop Road. Ms. Adams replied that the current perchlorate risk range from EPA Headquarters is 4 to 18 ppb, and that is the guiding principle in terms of whether EPA can take emergency actions under the SDWA. She also said that while she shares Mr. Judge's frustration, the point is that there's a big debate about the safe level of perchlorate in drinking water. She said that it's good that DEP is providing bottled water, but she too wishes that this issue could be resolved much faster. Mr. Judge remarked that he will be very disappointed if EPA doesn't protect the family on Foretop Road, and he believes that being precautionary probably would prove to be prudent.
Dr. Dahmani questioned whether DEP could provide a town water hookup for the family on Foretop Road now, without waiting for resolution of the perchlorate standard question. Mr. Kinney mentioned the idea of taking up a collection in the community to reimburse DEP for funding a town water hookup. He said that it's not right that the Foretop Road family has contaminated drinking water while bureaucrats are arguing about what the standard should be.
Mr. Mullennix said that he's very sympathetic toward the family on Foretop Road. He also noted, however, that perchlorate is a national issue and millions of people in the country have been drinking perchlorate-laden water at levels as high as 8 to 12 ppb for many years. Mr. Judge stated that the responsible parties should remedy those circumstances. He also said that he thinks it's more sensible to spend taxpayers' money now to fix the problem, rather than waiting and having to spend more taxpayers' money on health care later. Mr. Mullennix noted that the National Academy of Sciences (NAS) is in the process of studying the perchlorate issue. He asked for patience while waiting for the NAS report, which is expected sometime in late spring. Mr. Judge replied that the NAS is known to take extended periods of time to come to decisions, which is of little comfort to him and probably of little comfort to the family on Foretop Road.
Dr. Dahmani said that the current "health advisory" level for perchlorate in drinking water in Massachusetts is 1 ppb, and therefore he thinks it would be right for DEP to step up and provide a town water hookup for the Foretop Road family. He added that if money is an issue, perhaps, as Mr. Kinney suggested, there is some way to help DEP in that regard.
Mr. Cambareri said that just as the military hooked up the Bourne Water District to an alternative water supply because of uncertainties in the Monument Beach wellfield, he thinks that providing a town water hookup would be the right thing to do for the family on Foretop Road, given the uncertainty of that situation.
Agenda Item #4. Remediation and Investigation Update
Demolition Area 1 Soil Update
Mr. Nixon stated that the treatability study report, which is to be mailed to IART members tomorrow, indicates that perchlorate is effectively treated by thermal desorption technology at a temperature between 725 and 775 degrees Fahrenheit (°F). Based on that, proof-of-performance testing will be done on the system at a temperature of 775°F. Mr. Nixon noted that samples used in the study had to be spiked in order to achieve desired concentrations for testing at two different levels: 100 ppb and 100 parts per million (ppm). The highest perchlorate level detected in Demolition Area 1 (Demo 1) soils was 27 ppb.
Mr. Nixon noted that assembly of the thermal desorption treatment unit at Demo 1 is close to completion. The IAGWSP has received draft approval from DEP on its air permit application, and full approval is expected once some additional information is provided. Proof-of-performance testing, which should begin sometime in early March, will include stack emissions testing and pre- and post-treatment sampling.
Mr. Nixon also reported that anomaly removal at the two outer areas of Demo 1 has been completed. Soil excavation there will begin prior to completion of anomaly removal at the depression in the center of Demo 1 so that treatment can begin. Anomaly removal and excavation at the center will be done to about eight feet, or until natural soil is reached. Mr. Nixon noted that around Thanksgiving time, a test patch area of soil was excavated to test quality control and sampling procedures, and all went well.
Mr. Hugus asked if there's a contour map that indicates the original depth of the Demo 1 depression. Mr. Nixon replied that he doesn't know of one, but there are old aerial photos of the area. He noted that the horizon between disturbed and undisturbed soil would be identified through visual determination. He also said that there's clear evidence that that area was reworked and test pitting activities there indicated a depth of about eight feet. Mr. Borci said that he thinks that original test pitting showed the deepest disturbance to be at 13 feet. He explained that the eight-foot excavation depth is an average - some areas will be shallower and others could be as deep at 13 feet.
Mr. Schlesinger asked if the cleanup timeframe would have to be extended now that the treatment unit must operate at 775°F, rather than the originally proposed 550°F. Mr. Nixon replied that achieving the higher temperature is just a matter of consuming more propane. Mr. Gangopadhyay of Environmental Chemical Corporation (ECC), the company contracted to operate the thermal desorption treatment unit, confirmed that the retention time would not be affected. Mr. Nixon noted that the retention time is about 10 minutes.
Demolition Area 1 Groundwater Update
Mr. Nixon said that the Demo 1 portable groundwater treatment system is being evaluated to determine exactly what the shape and form of the treatment trains inside the portable treatment units should be. The system is going to be located at the same site proposed for the full-size treatment plant. The treatment train has not yet been finalized, but will be a combination of ion exchange resin and granular activated carbon (GAC) to remove both perchlorate and explosive compounds. Mr. Nixon also noted that installation of extraction and reinjection wells is under way.
Mr. Nixon reported that the Pew Road system is operating at a flow rate of 10 gallons per minute (gpm) as part of the innovative technology evaluation (ITE) study, which is expected to run for about six months. Three filter media (two types of ion exchange resin and an amended carbon specifically tailored for perchlorate removal) are being evaluated in the ITE. The system has been up and running for a little over a week, following a slight glitch when fuel in the generator gelled up due to the extremely cold weather. That problem was fixed by adding some kerosene to the fuel. Mr. Nixon said that results of the ITE study will help guide future work and remediation designs. Around September 2004, the Pew Road system will be ramped up to 100 gpm, using the system described in the Rapid Response Action (RRA) plan.
Mr. Mullennix inquired about use of a fluidized bed reactor (FBR) at the Frank Perkins Road system. Mr. Nixon replied that an FBR was proposed in the original RRA plan; but there's since been a change to the temporary treatment system, which will be used until a comprehensive remediation system is designed through the feasibility study process. Mr. Mullennix asked if an FBR system might be used in the future. Mr. Nixon replied that the FBR is still being evaluated, but it looks as though ion exchange resin is the more efficient and effective technology. He noted that the cost of ion exchange resin has dropped quite a bit over the past couple years, which makes it a more attractive option. Mr. Mullennix questioned whether another reason is the relatively low concentrations of perchlorate expected at Frank Perkins Road. Mr. Nixon replied that influent perchlorate concentrations at the Frank Perkins Road system are expected to be fairly low, in the 10 to 20 ppb range. Therefore, it probably would be necessary to add some food to an FBR system in order for biological activity to occur and degrade the perchlorate.
Ms. Pepin asked Mr. Nixon to identify the document that details the decision-making process regarding which technologies to study. Mr. Nixon replied that the RRA document, dated July 2003, evaluates FBR, ion exchange resin, and GAC. He noted that the IAGWSP is currently working with EPA and DEP to revise the text of that document.
Ms. Pepin asked how ion exchange resin technology works. Mr. Nixon explained that the process is similar to carbon adsorption, but the filter is made up of an ion exchange resin, a positively-charged polar resin to which negatively-charged perchlorate ions are attracted, thereby causing a molecular bonding attachment. Mr. Gonser compared the technology to a home water softening system. Ms. Pepin said that it was her understanding a year ago that the use of GAC at Demo 1 was completely out of the question. Mr. Nixon clarified that GAC had always been part of the RRA system as a polishing step.
Mr. Schlesinger inquired about continued sampling of monitoring wells to update knowledge of the Demo 1 plume. Mr. Nixon replied that there are wells within the Demo 1 plume that are part of the long-term groundwater monitoring program, which he believes are sampled on a yearly basis. He also said that there's agreement among the IAGWSP, EPA, and DEP that the plume has been adequately delineated. Mr. Schlesinger said that he thought there had been disagreement about the toe of the plume. Mr. Borci clarified that the plume has been adequately delineated for the purposes of moving forward with a feasibility study, but for cleanup purposes it's assumed that the plume extends beyond monitoring well 252 (MW-252) and MW-258. He also said that he thinks the current sampling frequency of wells with perchlorate detections is three times a year.
Mr. Gregson told Ms. Pepin that GAC is also necessary to treat Research Department Explosive (RDX), which ion exchange resin is not able to treat. Mr. Nixon added that the FBR doesn't treat RDX completely either.
Mr. Dow asked what measures would be taken to prevent the ion exchange resin from becoming clogged with other salts in the groundwater, such as bicarbonates and chlorides, which are negatively charged. Mr. Nixon replied that while nothing can be done to prevent the resin from gathering those compounds, the concentrations at MMR are not very high. He said that it's been found that the groundwater chemistry shouldn't be a problem for ion exchange resin. He also said that he would take it as an action item to look into providing more detailed information on this topic. Dr. Stahl stated that Mr. Dow's concern is justified because it's correct that a more negatively-charged salt would displace perchlorate from the resin. He said that levels of chloride or bicarbonate would have to be examined in some kind of feasibility testing that looks at the type of resin and how strongly it binds and interacts. Mr. Nixon noted that the GAC polishing step would gather any low concentrations of perchlorate, should they break through the treatment system.
Mr. Dow then asked if it's correct that the temporary treatment system at Demo 1 will not exceed the one-million-dollar Military Construction (MILCON) threshold, but the permanent system that comes after the feasibility study will exceed that amount. Mr. Nixon confirmed that both are correct. He also said that it's expected to take two to three years for the comprehensive system to be built and operational; in the meantime outstanding issues will be worked and resolved.
Mr. Hugus commented that he doesn't want the RRA to be the only treatment for the Demo 1 plume, and he hopes that the next presentation includes information on work to delineate the toe. Mr. Nixon noted that at the February IART meeting the IAGWSP would like to make a presentation on groundwater modeling done to date, including fate and transport of the toe of the plume and the different well scenarios to be evaluated as part of the feasibility study. He said that last week the regulators and their consultants saw this presentation, which would have to be cut down from 2.5 hours in order to fit within the timeframe of an IART meeting.
Mr. Hugus inquired about the Pew Road ITE pilot program schedule. Mr. Nixon replied that the program started "a week ago Friday" and is scheduled to run until about July, after which the data will be evaluated, and a report will be issued perhaps in early September. Mr. Hugus asked if the study could be expedited in order to prevent delay of final treatment. Mr. Nixon said that results of the pilot study could influence the selection of the comprehensive system. He also explained that speeding up the program would mean having to reduce retention time in the vessels, which is an important characteristic of the study. Mr. Hugus pointed out that it was said that pumping at the system would later be increased to 100 gpm. Mr. Nixon clarified that that will be a separate unit, with an expected startup date of September 2004. Mr. Gonser added that the timeframe for the study shouldn't delay the final remedy selection; however, ways to shorten the overall schedule for the final solution are being sought.
Dr. Dahmani asked whether there is a preliminary study or report upon which it was decided that ion exchange resin would be appropriate and effective at Demo 1. Mr. Nixon replied that there are studies that indicate that GAC can be effective, and there are studies that indicate that ion exchange resin can be effective in dealing with the perchlorate concentrations seen at MMR. Dr. Dahmani said that he's interested in studies that looked at the specific water chemistry at MMR.
Dr. Osgerby of the U.S. Army Corps of Engineers (USACE) said that he monitored the Penn State carbon studies, which used various forms of carbon, including some specially tailored forms, all of which showed that carbon can handle low concentrations of perchlorate. Ion exchange resin studies that have been conducted, however, have not looked at these concentrations. This is why the Pew Road pilot test is being done - to look at site water, and carbon versus ion exchange resin. Dr. Osgerby also noted that regular GAC will serve as "the catchall downstream" so that no contamination will get by the system. He further noted that water tested in the Penn State carbon studies was actually sampled from the site.
Dr. Dahmani asked if data from the ongoing ITE study would be made available. Mr. Nixon said that the full report is expected to come out in September, but sometime in the July/August timeframe there will be table that shows laboratory results, the number of bed volumes treated before breakthrough occurred, and the like. He noted that results of the study would help in formulating the design of the RRA system.
Mr. Schlesinger said that he remembers being told that GAC cannot remove perchlorate from water. Mr. Nixon clarified that GAC can remove perchlorate, but not as efficiently as it removes other contaminants, such as benzene or perchloroethylene (PCE). He said that the Penn State studies demonstrated that, and he thinks that that final report may have been distributed.
Mr. Borci asked if the Penn State studies looked at amended carbon. Mr. Nixon clarified that they looked at different types of regular, un-amended carbon. Mr. Borci then said that Mr. Schlesinger is correct that GAC was not the treatment of choice when a remedy for Demo 1 was first being considered, and regular GAC wasn't even chosen for testing at the Pew Road system. He noted that it's the polishing unit, after the testing, that uses regular GAC. He also suggested that the IAGWSP seems to be promoting the idea of using regular GAC. Mr. Nixon clarified that that idea has been put aside, although the IAGWSP believes that technically it would work. However, the Frank Perkins Road system will use both GAC and ion exchange resin. Mr. Borci said that he stills hears GAC being put forth as a potential solution, whether now or in the future. He also noted that it's important to clarify whether regular GAC or amended carbon is being discussed.
Dr. Osgerby noted that regular carbon, which will be used in the polishing unit, can exchange only 1,000 bed volumes before it becomes depleted and has to be replaced. The special or amended carbons that were mentioned, however, are capable of exchanging somewhere between 30,000 to 200,000 bed volumes, which would make them very economic in terms of contaminant concentrations like those seen at Frank Perkins Road and Pew Road. He explained that carbon is not used regularly at other sites in the country because contaminant concentrations are much higher. Dr. Osgerby also said that the ITE study will result in a case history on regular carbon, amended carbon, and ion exchange resin, and he's certain that that record will be released to the public.
Mr. Borci requested that the IAGWSP provide a comprehensive table and write-up that clarifies exactly the types of testing that's been done. He said that the table should indicate which tests were conducted using MMR water, as well as the perchlorate concentrations used in the testing. He also mentioned that he had heard that there are ion exchange resin systems in California that are treating levels as low as those detected at MMR. Mr. Borci noted that the table could educate and prepare everyone for the feasibility study process. Mr. Nixon agreed to fulfill this request.
Ms. Cassidy stated that the IAGWSP had proposed to use regular GAC for the temporary Frank Perkins Road system, which raised some concerns for EPA. She noted that GAC hasn't been used elsewhere in the country for this application, although there have been some column tests that have provided preliminary information. She said that because of the unknowns and the RRA timeframe, EPA told the IAGWSP that it would be inappropriate to use GAC for the temporary system. Mr. Nixon noted that the IAGWSP did take that proposal off the table. Ms. Cassidy agreed and said that she expects the issue to be revisited in the feasibility study, when it will be more formally vetted and reviewed. She also mentioned that EPA had sent the issue to some national laboratories for review.
Ms. Pepin stated that two years ago, when she first read about the Penn State studies in the monthly progress reports, she asked for more information and requested a presentation about them. She said that having received nothing, she is re-asking for a copy of whatever formal report is issued, as well as some of the interim reports that were mentioned. Mr. Nixon noted that the study results hadn't come out until last fall.
Ms. Adams asked that the table/write-up summary that Mr. Borci requested include specific information about interim and long-term systems proposed for Frank Perkins Road and Pew Road at Demo 1. She said that she expects that such a summary would help everyone understand the issue, as she herself was very confused by tonight's discussion. Mr. Nixon replied that he hopes his presentation was coherent, and that it was the follow-on discussion that became confusing.
Mr. Cambareri asked if the use of kerosene that Mr. Nixon mentioned was related to the generators. Mr. Nixon replied that it was. Mr. Cambareri inquired about the energy source for the long-term system. Mr. Nixon explained that the temporary containerized system at Frank Perkins Road will have overhead power. The generators are for the Pew Road ITE system, running at 10 gpm. Mr. Gonser noted that the generators there will be replaced with a regular overhead power line. Mr. Cambareri inquired about the amount of fuel stored at the site to run the generators. Mr. Nixon replied that the tank holds a couple hundred gallons of fuel at the most, and is situated inside a lined berm.
Central Impact Area/J-2 and J-3 Ranges RRA Update
Mr. Gregson stated that RRA soil removal efforts at the Central Impact Area and the J-2 and J-3 Ranges are ongoing. He noted that the idea is to remove the soil from those sites in a timely fashion in order to fully utilize the thermal treatment unit while it's at MMR. He said that these removal actions are smaller in scope than the 15,000-cubic-yard excavation effort at Demo 1; rather, they are isolated "hotspot" type removals.
J-1 Range Recent Unvalidated Detections
Mr. Gregson showed a perchlorate detection map for the J-1/J-2 Range area and pointed out the base boundary, the Impact Area boundary, and the zones of contribution (ZOCs) for the Upper Cape Water Cooperative supply wells. He reported that in MW-286 perchlorate was detected at 2.1 ppb and RDX was detected at 0.54 ppb. In MW-303, which is closer to the suspected source known as the Interberm Area, perchlorate was detected in 12 profile sampling intervals, from about 0.4 ppb to 26 ppb. High Melting Explosive (HMX) and RDX also were detected in profile sampling there, with a maximum RDX concentration of 36 ppb. Mr. Gregson noted that the plume of perchlorate and RDX extends from the source area off to the northwest. He also said that the next well planned for this investigation is J1P-22, which should help define the western edge of contamination.
Mr. Schlesinger asked how long it would take for the contamination to reach the water co-op's supply wells, assuming that there's no additional contamination between the detections and the those wells. Mr. Gregson replied that the monitoring wells are located near the tail end of the ZOCs, which are based on a one-million-gallon-per-day pumping rate, although the wells actually are pumped at consistently lesser rates. He said that the travel time between the recent detections and the supply wells is about 40 to 60 years.
Mr. Schlesinger expressed concern about the speed at which perchlorate travels. Mr. Gregson explained that perchlorate doesn't move any faster than groundwater; however, RDX moves away more slowly from its source area because it tends to get retarded in the subsurface. Therefore, it there's a simultaneous release of perchlorate and RDX, perchlorate would advance through the groundwater more quickly than the RDX would. Mr. Schlesinger suggested that the perchlorate detected at MW-300 might not indicate the extent of contamination moving downgradient through the ZOC. Mr. Gregson said that he would talk about this when he discusses the J-2 Range. Mr. Borci noted that the water's travel speed and the age of the source are the key points to consider.
Mr. Judge reminded the team that when perchlorate was first detected in the Monument Beach wellfield sentinel wells, it was said that it would take two to three years before the contamination there would reach the supply wells, yet perchlorate was detected in a supply well only two to three weeks later. He noted that because of a lack of monitoring wells in the ZOCs, it's unknown at this time whether perchlorate exists closer to the water co-op wells. Therefore, it might be a matter of only 10 years or even several months, rather than 50 years, before perchlorate reaches those wells. Mr. Judge urged the IAGWSP to protect the water co-op supply wells right away, now that it's no longer a question of whether contamination exists in the ZOCs, but a question of how quickly that contamination will reach the supply wells.
J-2 Range Recent Detections
Mr. Judge also inquired about detections at MW-296. Mr. Gregson replied that in profile sampling that well tested nondetect for perchlorate, and showed a low-level RDX detection with some interference associated with it. He also noted that the IAWSP is trying to proceed rapidly with definition of this plume. He pointed out the wells that were drilled in order to determine whether the nondetect at MW-296 was indicative of the plume extent. He noted that perchlorate was detected at 89 ppb in MW-300, at 9.5 ppb in MW-302, and at about 32 ppb in a well farther east, MW-395. Based on those detections, it appears that the core of the plume is somewhere right along the edge of the Impact Area. Mr. Gregson also said that on Thursday the IAGWSP is going to discuss additional drilling locations with the regulators. He noted that it appears that another well is need to the east on Wood Road, and another downgradient to define the downgradient extent of the plume.
Mr. Judge questioned what perchlorate concentration would have to be detected in a ZOC in order for a water co-op well to be shut off. He also expressed great concern that a federal standard for perchlorate has not yet been determined, and indicated that he worries that ultimately the residents of Cape Cod would be asked to accept wellhead treatment on the water co-op wells. Mr. Judge said that he thinks that many monitoring wells should be drilled in the ZOCs right now, without having to wait several years to find out that there's perchlorate "right in the middle of this zone of contribution."
Mr. Borci indicated that the effort is being made to install monitoring wells in this area as quickly as possible. He said that the regulators will listen to the IAGWSP's proposals on Thursday, and he thinks that the investigation will be focused downgradient so the size of the plume can be determined, after which options can be evaluated.
Mr. Kinney inquired about RDX detections in this area. Mr. Gregson replied that RDX levels in that row of wells are relatively low, ranging from 0.31 ppb to 0.65 ppb. Mr. Kinney noted that the health advisory for RDX is 2 ppb. He also asked how installation of more wells in the ZOC could be expedited. Mr. Gregson replied that the wells are being installed as quickly as possible, and four are planned for the next drilling round. He said that this investigation is a priority and everyone wants to get the plume defined as soon as possible.
Mr. Gonser confirmed that the IAGWSP is moving this investigation along as quickly as it can, immediately moving the drilling equipment from one well site to the next. Mr. Kinney said that while he's glad to hear that the IAGWSP is committed to moving as quickly as possible, he's concerned that the program's capacity for drilling wells might be inadequate. He also said that he would suggest increasing that capacity and focusing not just on one ZOC, but on all of the ZOCs that might be endangered. Mr. Kinney then asked the IAGWSP to provide specifics on what "as fast as you can" really means, perhaps in terms of number of wells per month that it expects to install.
Mr. Gregson replied that he can't provide that answer off the top of his head, but Mr. Kinney's concerns have been heard and when the IAGWSP meets with the regulators on Thursday, they will continue to look for ways to get this investigation done as quickly as possible. Mr. Kinney inquired about the number of drill rigs available to the IAGWSP. Mr. Gregson said that he thinks there are four or five rigs working at MMR. He also noted that the installation of some wells is contingent upon wells that are drilled beforehand. Mr. Kinney replied that while he understands the incremental nature of these investigations, he thinks it's important to increase the pace of installation and the number of wells in this case, given the contamination in a ZOC for a well that's providing replacement supplies for water previously contaminated by the military. He said that he thinks the $150,000 cost to install a monitoring well is "nothing in this budget" and so it wouldn't be a big deal if an extra well were drilled. He urged the IAGWSP to obtain more drill rigs so that the investigation can move faster.
Mr. Judge said that he thinks that the focus of the investigation should start near the supply well itself and work backwards from there. He also asked if any volatile organic compounds (VOCs) have been detected in the water co-op wells, and if EPA standards exist for VOCs. Mr. Borci replied that there are both EPA and DEP standards for VOCs. He also said that he knows of no VOC detections in either the J Range plumes or the supply wells.
Mr. Cambareri asked whether the water co-op has been notified of the detections. Mr. Gregson replied that it has, and added that the IAGWSP keeps the co-op updated on the progress of the investigation. Mr. Cambareri recommended that the IAGWSP consider issuing a news release about this matter. Mr. Judge requested that this recommendation be noted as an action item.
Northwest Corner Recent Unvalidated Detections
Mr. Gregson stated that the first round of groundwater sampling at MW-287 yielded a 1.9-ppb perchlorate detection in the shallow screen at the water table and a 0.8-ppb perchlorate detection in the screen 25 feet below water table (bwt). MW-297, which is located at the canal overlook, showed a 2.5-ppb perchlorate detection at the water table and a 1.9-ppb perchlorate detection at 20 to 30 feet bwt. Profile sampling results from a new well location, NWP-8ba, showed a perchlorate detection at about 0.5 ppb at the water table and deeper detections at about 121 and 131 feet bwt at low levels of 0.42 ppb and 0.5 ppb.
Mr. Gregson noted that NWP-12 is being drilled currently. Also, there are plans to drill NWP-9 on a service road near the tech school, and a proposal to drill NWP-14 and NWP-15 to define the northern extent of perchlorate there. In addition, the IAGWSP is working on an easement to obtain access to the Schooner Pass property to drill NWP-13 and determine what the perchlorate concentrations are in that middle section.
Mr. Gregson also discussed detections in residential wells in the area. He noted that well RSNW03 has had consistent detections of perchlorate at concentrations ranging from about 1 to 2 ppb. An irrigation well, RSNW06, which is not used for drinking water, has had detections of perchlorate at about 0.6 ppb or less, as well as a detection of RDX at 0.26 ppb, which is just above the detection limit. RSNW01 had a one-time detection of perchlorate at 0.4 ppb, just above the detection limit of 0.35 ppb. That well is being tested on a monthly basis and has been nondetect since the initial detection. RSNW02 tested nondetect for perchlorate.
Mr. Hugus asked if it's correct that two residential wells in this area have had perchlorate detections. Mr. Gregson replied that it is, and noted that the well to the north had just a single detection. He also noted that all the other residences in that area are on town water. Mr. Hugus then said that he thought he read something in the progress report about a water co-op at Schooner Pass. Mr. Murphy said that he thinks mention of the water co-op referred to the three supply wells on base. Mr. Hugus inquired about the status of the Schooner Pass community well, which supplies about 90 individuals. Mr. Gregson replied that RDX was detected in that well at 0.26 ppb in one sampling event. The community continues to use the well, which the IAGWSP monitors on a monthly basis, but has entered into an agreement for a town water hookup.
Mr. Minior offered a point of clarification that any perchlorate detection less than the reporting level of 1 ppb is an estimated value. Mr. Gregson agreed that values below 1 ppb are flagged with a "J" to indicate that the value is between the method detection limit and the laboratory reporting limit. Mr. Minior suggested that the IAGWSP note estimated values during presentations. Mr. Borci added that a "J" value also means that the contaminant is positively present; it's the quantity of the contaminant that's estimated.
Mr. Schlesinger inquired about the possibility of installing wells upgradient of MW-278 and MW-279, but downgradient of MW-298. Mr. Gregson explained that MW-298 is located on the next available road north of MW-278 and MW-279. He also noted that MW-298 was sited based on particle backtracks from MW-278 and MW-279, but the exact location perhaps had to be shifted somewhat because of topography considerations. Mr. Schlesinger asked if it's correct that there are no data east of MW-278 and MW-279. Mr. Gregson replied that it would be very difficult to get a drill rig in that area because of boulders, cliffs, and forests there. Therefore, at this point it makes sense to go back to Cat Road and get the same information. Mr. Schlesinger said that he's suggesting going farther to the southwest than where NWP-12 is now located, as the groundwater contours indicate to him that the center of the plume wouldn't be found near the NWP-12 location. Mr. Gregson replied that there's a very wide area of contamination there, so if the plume "extends back in this direction, we're going to catch it."
Mr. Mullennix inquired about the report on the Northwest Corner investigation. Mr. Gregson said that the report has been mailed out and team members should be receiving it tomorrow. He encouraged team members to review it and contact the IAGWSP with any questions or comments. Mr. Mullennix asked if the report includes any conclusions about the source of perchlorate contamination. Mr. Gregson replied that it contains nothing new in this regard - just that there appears to be a nearby source of perchlorate based on surface detections, and there also appears to be a source farther back on the base, based on deeper detections of both perchlorate and RDX.
Agenda Item #5. Discussion on Future Meeting Planning
Mr. Murphy informed the team that Dr. Dahmani, who was scheduled to make a presentation on thermal desorption this evening, has agreed to postpone it until the February IART meeting. Mr. Murphy explained that the presentation is rather lengthy and the time remaining on tonight's agenda would be insufficient to cover the subject matter adequately. He also noted that Dr. Dahmani's presentation would be rescheduled for the beginning of February's meeting.
Ms. Adams asked that Dr. Dahmani be provided with an opportunity to review the draft air emissions permit associated with the thermal desorption treatment unit at Demo 1. Mr. Pinaud agreed to provide a copy of the draft permit to Dr. Dahmani.
Mr. Schlesinger commented that the "Massachusetts Department of Public Health Update," which is noted as a future agenda item at the bottom of tonight's agenda, seems far less important than other topics, such as the water supply well ZOCs and the carbon issue. Mr. Murphy explained that the update is noted as a future agenda item as a placeholder, but won't necessarily be covered at the next IART meeting.
Mr. Hugus asked about the length of the thermal desorption presentation. Dr. Dahmani replied that it will depend on the number of questions asked, but the presentation itself should last about 25 minutes. Mr. Hugus said that as a courtesy to Dr. Dahmani, he wants to be certain that the thermal desorption presentation is scheduled for the beginning of February's meeting agenda.
Mr. Kinney noted that a "Natural Heritage and Endangered Species Program" update was listed as a future item on the agenda that was mailed to the team, but not included on the agenda provided at tonight's meeting. He said that he's not sure what the presentation entails, but he thinks that the subject of effects of contamination and cleanup activities on habitat at the base would attract members of the public who otherwise wouldn't be interested in attending an IART meeting. He said that he doesn't want this item to be dropped completely from the future agenda list because if it were well publicized and well presented, it might be a way to draw new people to the IART. Mr. Borci said that he thinks this topic was addressed as an action item from last month's meeting. He also said that the update probably would be a more appropriate agenda item to cover around the time of the Central Impact Area feasibility study - sometime in late spring or early summer - as many related issues will have to be incorporated into the Central Impact Area remedy decision.
Mr. Judge suggested that the Technical Outreach Services for Communities (TOSC) present on the carbon issue at a future meeting. He also asked that all future TOSC presentations be scheduled for the early part of agendas, as he believes it is very important for IART members to become better educated about issues relating to the cleanup. Mr. Judge also asked EPA to convey to Mr. Varney his appreciation for EPA's recognition of the citizen IART members.
Mr. Schlesinger referred to the "Mass Flux Approach to Assessing the Potential Threat to Snake Pond" item, another future item that was dropped from the list, and asked if it pertains to a proposal or to an approach that's currently being implemented. Mr. Gonser replied that in past meetings Dr. Dahmani had recommended that the IAGWSP consider this approach. He said that the IAGWSP is considering it, but it isn't being implemented at this time.
Agenda Item #6. Adjourn
Mr. Murphy announced that the IART would meet next on February 24, 2004 at the Bourne Best Western. He then adjourned the meeting at 9:00 p.m.