Impact Area Review Team
Future Agenda Items:
Handouts Distributed at Meeting:
Agenda Item #1. Welcome, Agenda Review, Approval of June 22, 2004 IART Minutes
Ms. Bonarrigo convened the meeting at 6:05 p.m. and reviewed the Impact Area Review Team (IART) groundrules, after which the IART members introduced themselves. Ms. Bonarrigo also reviewed the agenda and asked if there were any changes or additions to the June 22, 2004 IART meeting minutes. No changes were offered and the minutes were approved as written.
Agenda Item #2. Late-Breaking News and Responses to Action Items from the 6/22/04 IART Meeting
There was no late-breaking news to report at this time. Ms. Bonarrigo read the response to the action item from the June 22, 2004 meeting ("A discussion on DEP perchlorate standards will be included on a future meeting agenda as more information becomes available."), which generated no further comment from the team.
Agenda Item #3. Investigation Update
Mr. Gregson stated that the purpose of the ongoing investigation at the Northwest Corner is to define the extent of contamination to the north, the east, and the southwest. He referred to monitoring well 338 (MW-338), which was installed to help define the extent of perchlorate contamination and provide information on the RDX detection at MW-323. He reported that in profile sampling MW-338 tested nondetect for RDX and had one perchlorate detection at 0.56 parts per billion (ppb) in one interval at about six feet below water table (bwt). He also noted that screens were set in that well at 115 to 125 feet bwt and at 45 to 55 feet bwt to correspond to RDX detections to the north, and at the water table to correspond with the perchlorate detection. Mr. Gregson then mentioned that the decision was made not to set screens at this time at MW-333, which was recently drilled and tested nondetect for explosive and perchlorate. Instead, MW-338 was drilled.
Mr. Gregson also reported that groundwater sampling results from MW-332, which was drilled to help define the northern extent of the plume, showed 1.36-ppb perchlorate detection at the water table and no detections of RDX. Another set of samples was recently collected from MW-270 to the west, which previously had perchlorate detections in profile from the water table down to bedrock and in all three well screens that were set. Recent groundwater results from MW-270 showed no perchlorate in the shallow screen, but did show RDX at 0.28 ppb in that screen. Mr. Gregson said that it seems that this RDX detection might be related to the other RDX detections in the investigation area.
Mr. Gregson informed the group that the Impact Area Groundwater Study Program (IAGWSP) asked the USGS to conduct age dating of groundwater in a number of wells in the Northwest Corner investigation area, including MW-270. He noted that samples were collected last week and the USGS will be using a chlorofluorocarbon (CFC) method to determine the relative ages of the water. He noted that the normal age distribution would be older water at the bottom of a well and younger water at the top.
Mr. Mullennix asked if any conclusions were reached regarding the source of perchlorate at the Northwest Corner. Mr. Gregson replied that data are still being collected, as outlined in a project note recently signed by the IAGWSP and the regulators, and some additional soil sampling also is planned. Mr. Mullennix asked if the regulators had come to any conclusion about what the source of perchlorate might be. Mr. Borci stated that, as Mr. Gregson said, the investigation is ongoing.
Mr. Mullennix noted that the perchlorate testing of public water supplies that the Massachusetts Department of Environmental Protection (DEP) required in the spring of this year yielded at least half a dozen detections of perchlorate around the state. The published information indicated that none of those areas had any kind of military operations nearby, and therefore nonmilitary-related sources of that contamination are being sought. Mr. Pinaud said that DEP and the water suppliers are looking at any and all sources, including nonmilitary sources. He added that it's his understanding that at least some of detections had Formerly Used Defense Sites (FUDS) nearby, which would be investigated as well.
Mr. Schlesinger inquired about plans to install a well at the L-3 Range. Mr. Gregson referred to proposed well NWP-18, downgradient of the L-3 Range. Mr. Schlesinger also requested that the IAGWSP provide the team with a cross-section figure that depicts RDX and perchlorate detections at the Northwest Corner. Mr. Gregson agreed to fulfill this request.
Mr. Schlesinger also referred to MW-332 and asked if there is a plan to install a monitoring well on the road near the power line. Mr. Gregson replied that there is not at this time, and added that "it'd be based on the results from these wells." He also said that it appears the investigation is reaching the edge of the plume in that direction.
Ms. Conron asked for an explanation of the water age-dating process. Mr. Gregson replied that the USGS is looking at known concentrations of CFCs and a sulfur compound in the environment (which differ over time) and comparing those known concentrations to concentrations in the water from the wells in order to obtain some idea of the relative age of the water. He referred to MW-270 and noted that in a normal situation, the youngest water would be in the shallowest well screen and the oldest water would be in the deepest screen. If the situation is found to be reversed, however, it could provide some indication of what might be causing the distribution of perchlorate contamination in that well at all levels, such as whether it's mixing, upwelling, or downwelling. Mr. Gregson said that while the USGS won't be able to identify the exact vintage of the water, it will be able to determine which water is older and which is younger.
Mr. Hayes asked about the availability of an interim report from the U.S. Environmental Protection Agency (EPA). Mr. Borci replied that the only report published thus far was the IAGWSP's interim data summary report. He also noted that the project note, which is essentially a follow-up document that identifies a number of tasks to fill data gaps in the investigation, has been signed and could be provided to the team. Ms. Hayes confirmed that she would like to see the project note.
Dr. Dahmani asked if the RDX detections indicate a source from the base. Mr. Gregson replied that since RDX is a military compound and there's no evidence of civilian use of RDX in that area, it's thought that that contamination is from the base. Dr. Dahmani noted that potentially RDX and perchlorate have emanated from the base, and there might be some additional sources off base. Mr. Gregson agreed. He also said that the RDX found at the water table in MW-270 was an unusual result in that it would indicate a nearby off-base source, and it's hoped that age-dating of that water will help the understanding there. Dr. Dahmani seconded Mr. Schlesinger's request for a cross-section figure.
Mr. Mullennix expressed his frustration with the length of time it's taking to come to a conclusion about the source of the perchlorate at the Northwest Corner. He noted that the IAGWSP's interim data summary report "concluded clearly what the source of the perchlorate contamination was and EPA vehemently rejected it," and stated that the IAGWSP would be in violation of EPA's administrative orders if it didn't retract its conclusion - which Mr. Mullennix thinks "puts the whole situation in limbo."
Mr. Mullennix also said that while Mr. Pinaud may have information that he himself does not, the published information stated that the sources being sought (with respect to perchlorate detections across the state) were construction blasting, fireworks, and the like. That information also specifically stated that there didn't seem to be any military operations in those areas. Mr. Mullennix said that this indicates to him that rocket fuel and military operations are not the only sources of perchlorate in the environment. He again noted his frustration over the lack of a conclusion regarding perchlorate at the Northwest Corner.
Mr. Pinaud said that his intention was to clarify, not to refute what Mr. Mullennix was saying. Mr. Borci said that he wants to clarify for the record that the IAGWSP's document was an interim report, and EPA had stated that it was inappropriate that that report contained conclusions about the perchlorate source, based on the existing data. He also mentioned the recent detections in MW-270 that can't be explained at this time and said that this is why the investigation continues. He further noted that everyone wishes the investigation would go faster.
Mr. Schlesinger stated that he doesn't think there's enough information yet to determine the source of perchlorate at the Northwest Corner. He said that more information is needed from upgradient locations such as NWP-18 and points farther in order to define the northeast boundary of the plume, and the investigation has not yet reached that stage. Mr. Gregson pointed out the locations where new wells NWP-18 and NWP-20 are going to be drilled to help understand the RDX detections.
Mr. Dow asked if the USGS is going to date just the layers that are just contaminated with perchlorate, or also those with RDX detections. Mr. Gregson replied that it will also date the layers with RDX. Mr. Dow then asked if there's a way to look at the relative ages for the RDX and compare that with perchlorate at layers that aren't at the water table, since CFCs are volatile and were developed sometime in the 1970s, probably after the RDX plume was initiated on the base. Mr. Gregson said that he doesn't have a definitive answer; however, the analysis really isn't concerned with the contaminant in a particular screen. Rather, it looks at the CFCs to determine the age relative to other screens being analyzed. He said that if screens that would answer that question happen to be selected, that could be done. Dr. Dahmani added that "enough concentrations of RDX" would be needed, which might not be the case in this situation.
Mr. Dow also asked about radioactive tracers, like cesium, which might confirm the CFC data since it would presumably be a more recent vintage. Mr. Gregson replied that that technique has been used in the past and he would have to ask Denis LeBlanc of USGS why he thought it wasn't preferable in this case.
Mr. Hugus remarked that he thinks it's the IAGWSP, not EPA, that's "made this thing go on so long" by putting forth the idea that fireworks were the cause of perchlorate in this area. He said that RDX being co-located with perchlorate makes it almost impossible for him to believe that that hypothesis could be true. Mr. Hugus said that he thinks the Northwest Corner plume looks like other plumes on the base, coming from a base training range. He added that the real problem seems to be that the investigation into who's responsible for the contamination is getting in the way of discussions about stopping and remediating the plume, and he thinks time is being wasted.
Dr. Dahmani said that the IAGWSP is actually delineating the plume, and ultimately will have to deal with the regulation issues. He said that as far as he's concerned "this is proper procedure." He also said that it appears there may be two sources of perchlorate contamination. Having RDX co-located with perchlorate certainly indicates a base source, and the fireworks are another possible source. However, the plume still has to be delineated in order to come up with a plan for remedial measures, and he doesn't believe that doing so is a waste of time.
J-2 Range Northern Plume Recent Results
Mr. Gregson said that the IAGWSP is getting information to help define the downgradient extent of the J-2 Range Northern plume. He reported nondetect results for perchlorate and RDX in profile samples from two new monitoring wells: MW-337, located west of Barlow Road, between Jefferson Road and Gibbs Road; and MW-340, located south of Gibbs Road. He noted that there were some detections of explosive compounds with interference at MW-340, and a screen was set in that well to determine if the compounds will show up again in a groundwater sample. Mr. Gregson also reported that last week, using a packer in order to sample at 10-foot intervals, samples were collected from sentinel wells C7 and C4, which are associated with Co-op water supply well #2. He further noted that drilling was recently started at a location to the east on Gibbs Road to ensure that the plume is not shifting in an easterly direction. Well screens are being installed in the new wells in order to collect groundwater samples, and recent groundwater sampling results from MW-318M2 showed it to be nondetect for perchlorate and RDX.
Mr. Schlesinger asked why the plume outline isn't drawn to a fuller extent in the handout map that depicts the J-2 Range Northern plume, while the Northwest Corner plume map shows a portion of that plume "with no supportive data." Mr. Gregson showed a map that depicted a fuller extent of the plume and explained that it was not included in the handout because it's based on profile data. He noted that the handout map would be updated as well data become available. Mr. Gregson then referred to the profile data map, pointed out the plume's source area (Disposal Area 2 on the J-2 Range), and noted that the highest levels of perchlorate are located in the center, between the source area and Wood Road. He also pointed out the nondetect wells he'd mentioned earlier, and the new well to be drilled to the east.
Mr. Schlesinger questioned whether the towns were receiving this information. Mr. Gregson replied that the IAGWSP has been attending Upper Cape Water Cooperative (the Co-op) meetings and providing the Co-op with updates. Mr. Borci asked for confirmation that the Co-op has seen the J-2 Range Northern plume profile data map. Ms. Curley of the IAGWSP confirmed that the package that includes the map was sent to the Co-op.
Mr. Borci referred to the cross-section figure that Mr. Gregson had put on the screen and asked him to point out Wood Road, which he did. Mr. Borci noted that groundwater data exist up to that point and said that at Thursday's technical meeting the project managers would discuss the schedule for obtaining groundwater data from the remaining wells, after which just one updated map could be used.
Mr. Gregson stated that the cross-section runs down the center of the plume, south to north. He pointed out the source area to the south and noted that a soil Rapid Response Action (RRA) is going to be conducted there this summer. He also pointed out a well where perchlorate was detected at 1.5 ppb and said that wells farther north have been nondetect. In addition, Mr. Gregson pointed out sentinel wells C7 and C4.
Mr. Mullennix inquired about the number of samples collected from MW-313, where perchlorate was detected at slightly more than 1 ppb, and based upon which a plume outline was drawn. Mr. Gregson said that he doesn't know that a screen has been set in that well, and he believes that the detection Mr. Mullennix mentioned was from profile sampling. He also confirmed for Mr. Mullennix that a groundwater sample from that well would be collected within the next month or two. Mr. Gregson explained that in order to expedite the delineation of the plume, a decision was made to base subsequent well locations on profile data, and then collect groundwater samples at a later date. Mr. Mullennix expressed concern about a fairly wide distribution of a plume map that's based on a single profile sample. Mr. Gregson clarified that the map based on profile data has not been widely distributed, just shown at IART meetings and provided to the Co-op; whereas the map based on groundwater data was included in the handout packet.
Ms. Conron expressed some confusion about the difference between the map based on groundwater data and the one based on profile data. Mr. Gregson noted that the profile data map is an interpretation of what might be happening with the plume, based on profile data. Mr. Minior recommended that Mr. Gregson explain the difference between profile data and fixed-well data. Mr. Gregson explained that a profile sample is a "grab sample" that's collected every 10 feet while the well is being drilled. Profile results provide extremely valuable information in terms of where the contamination is and where to set well screens, which are typically set at depths where contamination was detected in profile samples or at depths related to nearby detections. A well screen is a 10-foot section of slotted PVC pipe that's set into the hole. After screens are set, the well is developed, which means that the silt and sediment are removed in order to be able to obtain a clean water sample, and a small pump is used to collect groundwater samples from the well screens. Mr. Gregson explained that the operating philosophy is that the profile sample is a good screening tool that provides usually very reliable information on the contamination in the aquifer. However, the sample from the screen provides a better quality result, primarily because there's less interference from sediment and the like.
Dr. Dahmani recommended that Ms. Conron ignore the map in the handout and focus on the profile data map "because the plume is showing contamination there." Mr. Gregson commented that while profile data are usually reliable, they can change once groundwater samples are tested. Therefore, the plume depiction that's shown after groundwater samples have been collected and analyzed will be similar, but perhaps a little bit different than the map based on profile data.
Dr. Dahmani then inquired about what appears to be a second, deeper plume shown on the cross-section figure. Mr. Gregson replied that the source of that contamination is a little more difficult to explain. He said that particle backtracks from there lead to somewhere on the J-1 Range, but a source has not yet been identified. Dr. Dahmani asked if it's correct that that is a physically separate plume. Mr. Gregson confirmed that it is.
Mr. Hugus referred to Co-op water supply well #2 on the cross-section and asked when results would be validated. Mr. Gregson replied that he thinks that at least the unvalidated results from the packer sampling done at C4 and C7 would be available by the next IART meeting. Mr. Hugus asked when groundwater sampling results will be obtained from wells where only profile data are available at this time. Mr. Gregson replied that, as Mr. Borci mentioned, that schedule is going to be discussed this week, after which the team could be provided with that information.
Mr. Hugus said that it seems that the zone of contribution (ZOC) for water supply well #2, which was supposed to be a replacement supply for water already lost because of the base, has been compromised and is in danger. He also said that he thinks that at this point the regulators should be making plans to replace that well. He further noted that he thinks most of the residents of the Upper Cape, who get their water from the Co-op, are not even aware of "how bad this situation is." He urged the regulators to look into replacing water supply well #2.
Mr. Pinaud stated that DEP is quite concerned about the location of the plume, although the focus of his program is on full investigation and remediation of the plume. He said that the decision of whether to shut down the well or to treat it rests with the Co-op and the DEP Water Supply program, both of which are fully engaged and informed of all the investigation results. He also noted that the plume is fairly close to that water supply well and the sentry wells.
Ms. Conron asked how close the plume is to the supply well. Mr. Gregson replied that the sentry wells were located to be approximately five years in travel time upgradient of the supply well, and so the toe of the plume is somewhat greater than five years away, based on the interpretation. Ms. Bonarrigo noted that Ms. Conron wants to know the distance in feet. Mr. Gregson replied that it's about 2,200 feet. Mr. Borci said that he wants to clarify that the five-year travel time is a model-derived number; the distance in feet is the more important number, and the model can be revised as more data become available. Ms. Conron asked if the team could be provided with copies of the cross-section figure. Mr. Gregson said that because the figure is not based on validated data, the IAGWSP is hesitant to send it out for general distribution, but that may change.
Ms. Hayes mentioned the 1-ppb perchlorate level that the IAGWSP has been dealing with, and inquired about the status of establishing a perchlorate standard. Mr. Gregson replied that there is still no drinking water standard or groundwater cleanup standard for perchlorate. He also noted, however, that DEP is working to develop a cleanup standard at this time. Ms. Hayes asked if Mr. Pinaud attended the meeting of scientists that took place at Woods Hole, and where 40 ppb was put forth as a safe level of perchlorate. Mr. Pinaud replied that while he did not attend that meeting, others from DEP did, and it's his understanding that some individuals from the Department of Defense and from industry spoke about a 40-ppb level. Ms. Hayes noted her understanding that some rather renowned scientists stated that 40 ppb was a safe level. She also asked, "How did DEP take that?" Mr. Pinaud replied that DEP representatives from its Office of Research & Standards were at the meeting to monitor the discussion, but he's not aware of what the feedback was. Ms. Hayes noted that there's a large variation between 1 ppb and 40 ppb. Mr. Pinaud agreed.
Mr. Schlesinger asked if the perchlorate detections at MW-307M3 (24 ppb) and MW-310M1 (16 ppb), which are located at the J-2 Range Eastern Boundary area, are related to the deeper plume seen in the cross-section figure for the J-2 Range Northern plume. Mr. Gregson replied that they are not related, and occur at different depths. Mr. Schlesinger inquired about the perchlorate concentrations in the J-2 Range Northern plume as compared with the detections at MW-307M3 and MW-310M1. Mr. Gregson pointed out the mapped plume contours at the J-3 Range Northern plume and noted that they represent areas of 1, 4, 18, and greater than 100 ppb. Mr. Schlesinger noted that the detections he mentioned appear to be moving toward the ZOC for water supply well #1 and toward the northwestern fringe of the ZOCs for the Sandwich supply wells; therefore, he's concerned about them and whether they might be all part of one plume.
Mr. Mullennix inquired about the black dot labeled RW-2 in the northern section of the groundwater data map. Mr. Gregson replied that that is an old well. Mr. Mullennix said that he wanted to clarify that the plume is heading toward water supply well #2. He also said that it's his understanding that the Co-op is very informed about what's happening with the J-2 Range Northern plume and he believes that the Co-op takes very seriously its charge to ensure that public water supplies remain clean.
Mr. Dow asked how much perchlorate contaminant mass exists in the source area versus the amount that's already in the plume. Mr. Gregson said that he doesn't have that answer off the top of his head, but the extent of contamination to be removed from the source area has been established based on sampling. Mr. Dow suggested that perhaps this information could be provided at the next meeting. He also asked if the source removal effort would influence the best timing on startup of an RRA groundwater system. Mr. Gregson replied that the source removal will have a greater impact on how long it takes to clean up the plume, as opposed to how quickly a groundwater RRA needs to become operational. He also noted that with that in mind, the IAGWSP has ordered two mobile treatment units that can be put in place once the extent of contamination has been defined. Mr. Dow asked if the plan is to address this issue in fiscal year 2005 (FY'05). Mr. Gregson replied that some of the money is FY'04, and additional money will be dedicated to it in FY'05.
J-2 Range Eastern Boundary
Mr. Gregson said that the J-2 Range Eastern Boundary is a relatively new area that the IAGWSP is investigating. He reported that MW-336, which was drilled on Greenway Road to help define the southern extent of contamination seen at MW-319 and MW-158, tested nondetect for perchlorate and RDX in profile sampling. Another new well, MW-339, which was installed to help define contamination downgradient from MW-307, had perchlorate detections in five profile intervals at concentrations ranging from 0.43 ppb to 11 ppb, and RDX detection in two intervals, both at concentrations less than 1 ppb. Screens have been set in that well to correspond to those detections.
Mr. Gregson also reported the following groundwater sampling results: for MW-307, perchlorate at 24 ppb and RDX at 0.5 ppb; for MW-310, on the base boundary, perchlorate at 16 ppb and RDX at 0.4 ppb; for MW-319, to the south, perchlorate at 2.8 ppb and 2.6 ppb, nondetect for explosives; for MW-321, perchlorate at 3.5 ppb, RDX at 1.2 ppb, and HMX at about 3.8 ppb; and for MW-324, on Wood Road, perchlorate at 1.9 ppb.
Mr. Gregson said that there seem to be three distinct plumes in the Eastern Boundary area. The detections at MW-307, MW-321, MW-339, and MW-335 (western wells) appear to be connected. Also, the detections at MW-310, MW-215, MW-324, and MW-334 (eastern wells) appear to be connected, as do the detections at MW-319 and MW-158 (southern wells). The first is an RDX and perchlorate plume, and the other two are perchlorate plumes.
Mr. Gregson explained that the detections at the western wells appear to line up to a potential source area in the center of the J-2 Range area - Polygons 14, 15, and 16, which are a series of magnetic anomalies. The source area for the detections at the southern wells appears to be the southeastern edge near the firing point at the J-2 Range, where a melt/pour building, a latrine, a bunker, and other structures used for past contractor activities were once located. The detections at the eastern wells appear to track back to the northeastern edge of the J-2 Range, where there were features such as firing points and berms.
Mr. Schlesinger said that he doesn't think there's enough available data to conclude that the Eastern Boundary contamination is separate plumes. He also inquired about sampling existing wells LRWS5-1 and 84MW003. Mr. Gregson replied that he could check on those locations, but he thinks that they must not be at the proper depth to help with the investigation if they are not being sampled. Mr. Schlesinger also said that he thinks the team should be shown profile information to provide evidence that the plumes are separate, given that they are so close together. Mr. Gregson replied that this is "hot-off-the-presses" information. He also noted that based on what is known to date in terms of particle tracking, there appear to be separate source areas within the J-2 Range, which has distinct areas where disposal or burning activities occurred. Based on the conceptual model, it's feasible that there would be relatively small, isolated plumes with relatively small source areas on the J-2 Range.
Mr. Schlesinger questioned why the J-2 Range Northern plume emanates at such a wide angle, while the Eastern Boundary plumes, about which little information is available, are assumed to be separate. Mr. Gregson replied that the fanning effect at the J-2 Range Northern plume might have to do with its position on the groundwater mound. He also said that things might change as more data become available. Mr. Borci noted that the idea of three separate plumes at the Eastern Boundary was presented to the regulators before this meeting, and they thought that it made sense. He explained that it's important to keep in mind that while in plan view it appears that the plumes are close together, in cross-section the contamination depths line up back to the J-2 Range, as Mr. Gregson said. Also, in terms of comparing the J-2 Range plumes, Disposal Area 2, which is the source area for the J-2 Range Northern plume, covers more than an acre, which might explain why that plume is larger and wider.
Mr. Gregson then displayed a map that shows some of the locations being pursued for drilling off base. He pointed out proposed well 1, located on the driveway to the Forestdale School and upgradient of the detection in a private well on Peters Pond; wells 2 and 3, designed to be downgradient of detections in MW-310 and MW-319; and well 4, to determine if any contamination is emanating past the southern boundary. He also noted that the location of wells 6, 5A, and 5B would be contingent on results from wells 1 through 4. Mr. Gregson noted that the IAGWSP is in the process of obtaining agreements with the property owners so that those wells can be drilled as soon as possible.
Mr. Hugus inquired about the blue lines on the map. Mr. Gregson replied that the blue lines represent modeled permitted ZOCs for the Co-op wells and the Sandwich supply wells, while the yellow lines represent modeled ZOCs for the actual pumping rates at those supply wells.
Mr. Schlesinger requested that the IAGWSP make a practice of presenting at least longitudinal cross-sections, when they are available, whenever plan view maps of plumes are shown. Mr. Gregson replied that when that information is available it would be provided to the team.
Dr. Dahmani suggested that it might be better not to present "hot-off-the-presses" data, and instead present just updated figures. Mr. Gregson noted that IART members had requested to be provided with the most recent information on detections, and while he thinks Dr. Dahmani's point is well taken, he also thinks that it's important to take the time to review the latest data with the team. Mr. Borci added that in the past the project managers tried the approach that Dr. Dahmani mentioned, and it didn't work because it led to a situation where the team was being presented with very old data. He also noted, however, that he thinks a better job should be done in terms of updating plume maps so that they make sense and aren't confusing. Mr. Borci cautioned that withholding data to present at a later time could lead to other problems. Dr. Dahmani agreed that the plume maps should be updated more frequently. Mr. Gregson added that he would also continue to explain how detections relate to one another and potential source areas, and the reasons for specific drilling locations.
L Range Recent Results
Mr. Gregson noted that the L Range investigation is continuing. He reported that groundwater sampling results from MW-325 were nondetect for RDX and perchlorate.
Agenda Item #4. Remediation Update
Demolition Area 1
Mr. Nixon stated that the excavation work at the Demolition Area 1 (Demo 1) site is expected to be completed in about one month. The 1-foot and 2-foot lift portions have been completed, except a small area where the stockpiles are currently staged. An 8-foot depth cut through the center of the bowl was just done and the excavation there will continue until the natural grade is reached. Mr. Nixon also reported that about nine different burn pits were found scattered throughout an area of the site. The material from the burn pits is being sampled and analyzed for required hazardous waste parameters, and thus far no hazardous waste has been found. The burn pit material will be transported off site to a licensed landfill. He further noted that there have been no blow-in-place events recently, as only small arms items have been found. Mr. Nixon also mentioned that no additional depleted uranium (DU) rounds have been found; only the one that was found in May 2004.
Mr. Nixon then reported that the Demo 1 RRA groundwater systems at Frank Perkins Road and Pew Road are still under construction. The system containers are expected to arrive at the site next week, and while that represents a slight delay, it shouldn't affect the system startup date of September 2004. The two systems will pump a total of 320 gallons per minute (gpm) and are expected to prevent further downgradient migration of the plume until the comprehensive remedial system is in place. Mr. Nixon also mentioned that the IAGWSP is in the process of addressing EPA's comments on the Draft Demo 1 Groundwater Feasibility Study.
Mr. Nixon noted that part of the work to be done at Demo 1 is removal of the Pew Road innovative technology evaluation (ITE) project to assess three different types of filter media (monomer-amended granular activated carbon, a styrenic resin, and a nitrate-selective resin) and their effectiveness in removing perchlorate. During the ITE, which ran from January to the middle of July, 2.6 million gallons of water contaminated with very low levels of perchlorate (around 2 ppb to 2.5 ppb) were treated, and no breakthrough was seen in any of the three media. Mr. Nixon stated that it's probably because there aren't many competing ions in the groundwater at the base that all three filter media worked better than expected. He also said that results of the ITE could be used to help design future remediation systems.
Mr. Minior asked where the influent samples were taken. Mr. Nixon replied that they were taken after the water left the 10-gpm extraction well but before it reached the treatment equipment. He also said that the system has been demobilized to make room for the pumps needed for the 100-gpm RRA system at Pew Road.
Thermal Treatment Update
Mr. Nixon stated that full-scale operation of the thermal treatment unit began on July 7, 2004. Demo 1 soil is being treated currently, and while the plant was shut down today for some routine maintenance, the plant has been operating about 85% of the time at a throughput of 30 to 40 tons per hour. Including the soil that was treated during the shakedown testing and proof-of-performance (POP) testing that was done in the spring, about 7,000 to 8,000 tons of soil has been treated. Mr. Nixon noted that it will take a couple more weeks to finish treating the Demo 1 soil.
Mr. Nixon reported that one composite sample per 100 cubic yards of treated soil is being analyzed. Since full-scale operation began, about 90 composite samples have been tested, and four of those came back above the treatment standard. He also noted that that soil, along with the rest of the soil in the stockpile, is sent back through the system to be treated again. Mr. Nixon said that it's thought that this problem probably is due to cross-contamination remaining in the baghouse filter as a result of the perchlorate spiking that was done at DEP's request as part of the POP tests. He noted that tomorrow there'll be a Vactor truck on site and individuals with respirators and the appropriate protective suits will go inside the machine to vacuum out any remaining particulate matter. He said that it's hoped that this will take care of the problem and no further exceedances of the 4-ppb criteria for perchlorate will be seen. Mr. Nixon also mentioned that explosives have not been a problem.
Mr. Mullennix inquired about the concentrations of contaminants of concern (COCs) in the soil entering the treatment system. Mr. Nixon replied that the highest in situ perchlorate detection in Demo 1 was 27 ppb, but somewhat higher concentrations have been seen in some of the excavated soil samples. He said that he can't remember the exact number, but it was less than 100 ppb. Mr. Mullennix then asked if it's correct that there's no cleanup standard for perchlorate at either the state or federal level. Mr. Nixon replied that that's correct. Mr. Mullennix questioned whether the Demo 1 soil RRA is then a proactive cleanup, without any legal requirement.
Mr. Borci noted the existence of EPA's administrative orders and the Massachusetts Contingency Plan, and said that the regulators work with the IAGWSP to come with cleanup numbers, as is the case at Demo 1. He said that it would be inappropriate to imply that the cleanup is voluntary. Mr. Mullennix suggested that rather than a legal requirement, it's more an agreement between the regulators and the IAGWSP "that this is the thing to do." Mr. Gonser noted that the Demo 1 RRA was initially recommended by the Army. He also said that even though there isn't a perchlorate cleanup standard at this time, from an economic standpoint it wouldn't make sense to excavate the soil, treat it for one constituent, and then have to excavate it again in the future to treat it for another constituent.
Mr. Mullennix asked if there is a cleanup standard for any of the soil contamination that's currently being treated. Mr. Nixon replied that there isn't, with the exception of 2,4-DNT (700 ppb), of which he thinks a small amount might exist at Demo 1. He said that the primary COCs at Demo 1 are perchlorate, RDX, and HMX, and he doesn't believe that there are state or federal cleanup standards for those.
Mr. Schlesinger asked Mr. Nixon to review the information about sampling the treated soil at the thermal treatment unit. Mr. Nixon said that from every 100 cubic yards of soil that passes through the treatment plant a sample is collected and analyzed for perchlorate. For every 500 cubic yards, a sample is collected and analyzed for compounds. He said that he thinks that 22 ppb was the highest perchlorate detection in treated soil, while explosives have not been a problem. Mr. Nixon noted that an effort is being made to isolate and identify the problem, and it looks like it might be cross-contamination in the air-pollution control system left over from the spiking events conducted last March and April. Mr. Schlesinger said that he wants to be sure that contaminated soil is not returned to Demo 1. Mr. Nixon assured him that if a single result comes back above the 4 ppb treatment standard, it goes back through the treatment plant and is sampled again.
Dr. Dahmani asked if there's a way to separate the residual soil in the baghouse from the rest. Mr. Nixon noted that he asked the same question, and it doesn't seem to be feasible to do that, although it might be possible if a new plant were built from scratch.
Dr. Dahmani asked what criteria are being used when the soil is being tested. Mr. Nixon replied 120 ppb for RDX, HMX, and all the other explosive compounds, with the exception of nitroglycerin, which is 2,500 ppb. He noted that these are all tied to the practical quantitation limit (PQL) for the 8330 analysis, which is the explosives analysis. He also said that the 4 ppb treatment standard for perchlorate was tied to the PQL for the 314 analysis. However, since some interferences with lime were found, there's been a switch to a more sensitive analytic method, the LCMS method, for which the PQL is 3 ppb. Dr. Dahmani said that this information answers the earlier question about soil reuse criteria. Mr. Nixon apologized if he had missed that question. Dr. Dahmani noted that there is a PQL for perchlorate. Mr. Nixon mentioned that it is not a promulgated standard, but a very site-specific standard to ensure that the soil is being treated to the lowest levels possible.
Dr. Dahmani inquired about the percent of soil being retreated. Mr. Nixon replied that right now it's about 20%, but it's hoped that this will improve greatly. He also explained that the entire 500-yard stockpile has to be retreated, given that it's not possible to separate out the 100 yards that failed. Dr. Dahmani noted that he visited the treatment plant site today. He also said that he thinks that it is cause for celebration that active remediation of the Demo 1 source area is occurring. Mr. Nixon said that a ceremony is planned for September.
Dr. Dahmani also asked if the regulators think there are any other concerns the community should know about the thermal treatment unit. Mr. Borci said that the residual perchlorate concentrations post-treatment are troubling and he's just now hearing about the IAGWSP's theory of what might be causing it. He then asked if the material that's removed from the baghouse is going to be sampled. Mr. Nixon replied that it is. He also noted that the material will be removed from the baghouse by a Vactor truck, which is a big vacuum with high-efficiency particulate filters, and while he doesn't know how much there will be, he thinks it would be less than 10 yards. Because the material will be dust, it will be mixed in with some untreated soil in the feed prep area before being retreated. Mr. Nixon also noted that the material will be sampled before being mixed with the soil. Mr. Borci said that EPA would like to be notified by e-mail about this process so it can have some weigh-in and some documentation.
Dr. Dahmani asked about the frequency of site visits from EPA and DEP. Mr. Pinaud said that DEP has not visited the site since full system startup. The idea was to allow some time for the system to operate; however, it sounds like another visit is needed. He also clarified that DEP was at the site prior to full system startup. Mr. Nixon noted that full-scale operations have been going on for only about three weeks so far. Mr. Pinaud agreed and said that the IAGWSP has a fair amount of flexibility to troubleshoot the system as it sees fit, as long as DEP is kept informed. Mr. Nixon noted that someone from EPA visited the site last week or the week before.
Mr. Schlesinger asked if the PQLs that were discussed are soil specific. Mr. Nixon replied that soil and groundwater undergo slightly different analyses and have "drastically different" PQLs. He said that a PQL, which is the same thing as a reporting limit (RL), is considered to be the lowest value that the analytical method can reliably detect, while the method detection limit (MDL) is a much lower number. He also noted that the PQL or RL for groundwater is usually lower than that for soil.
Mr. Dow asked if Resource Conservation and Recovery Act (RCRA) standards can apply to explosives or propellants in soil. Mr. Nixon replied that a couple of explosives have RCRA standards associated with them, and although he can't think of them offhand, he knows that none have been detected in the burn pit soil. He also said that he doesn't think that there's a RCRA standard for propellant compounds like perchlorate, but there are standards for ignitability and reactivity that relate to explosives and perchlorate, and none of those have been exceeded. Mr. Nixon further noted that the burn pit soil is analyzed separately for perchlorate and explosives. He said that HMX has been found, perchlorate has not, and he thinks that RDX might have been found a couple times.
Mr. Dow asked if it's correct that no burn pit soil goes to the thermal treatment unit. Mr. Nixon confirmed that it is. He also noted that it's not difficult to identify the soil because it's stained black and smells like it's been burned. Mr. Dow asked if there are any other products of incomplete combustion or thermalization that would be present in the burn pit soil, such as dioxins. Mr. Nixon replied that the soil has been sampled for dioxins, but none have been found. He also noted that the landfill facility has a long list of required analytes.
Mr. Borci asked Mr. Nixon to specify the type of landfill. Mr. Nixon said that it is a lined landfill that's located in New Hampshire. He explained that the landfill is lined with either a clay or plastic layer on the bottom and would be capped with another impervious layer so that water cannot percolate through it.
Soil Rapid Response Actions Update
Mr. Nixon showed a list of the other major soil RRA sites that will be excavated while the thermal treatment unit is on base. The list included: the J-2 soil RRA - 6,200 tons: the J-3 soil RRA - 3,800 tons; the Central Impact Area soil RRA - 2,000 tons; and the Demolition Area 2 soil RRA - 1,200 tons. He said that these RRAs, which will help eliminate potential sources to groundwater, along with a couple smaller ones, are expected to be completed by the middle of October.
Mr. Mullennix asked Mr. Nixon to describe the process to obtain a composite sample for analysis from 100 cubic yards of soil. Mr. Nixon said that he's not sure of all the details, but he knows that grab samples are taken as the soil comes out of the pugmill, right before it goes on the conveyor belt out to the pile. The grab samples are then mixed together in a stainless steel bowl or a plastic bowl to make the composite sample. Mr. Mullennix inquired about the possibility of resampling the same 100 cubic yards. Mr. Nixon explained that enough soil is taken that the sample can be reanalyzed at least two more times, and that has been done. Dr. Dahmani noted that there's a standard procedure for sampling soil piles. Mr. Nixon agreed but explained that this is a little different in that the grab samples are taken just before the soil hits the conveyor belt. Dr. Dahmani remarked that the soil coming out of the pugmill is nice to sample because it's a homogenous mixture, unlike soil piles used for construction. He also said that he thinks this testing is appropriate.
Dr. Dahmani then asked to be provided with a complete list of analytes associated with the burn pit material, including those required by the landfill. Mr. Nixon agreed to see that that list is provided.
Agenda Item #5. Open Discussion
Mr. Schlesinger said that he wants the ZOC future agenda item to occur sooner rather than later, as he believes it's important for team members to have a good understanding about ZOCs in order to do a better job of providing advice. Mr. Gregson said that the project managers could discuss this at their meeting on Thursday. He also mentioned the possibility of checking to see if Denis LeBlanc of the USGS would be available to make the presentation.
Mr. Hugus seconded Mr. Schlesinger's request about the ZOC agenda item. He also asked whether there's been any follow-up on determining the source of the DU round that was found at Demo 1. Mr. Gonser stated that the experts at the Army Research Lab at Aberdeen Proving Ground, which has a permit to test and store DU rounds, confirmed that it was an unfired 20mm DU round of the type used in the Navy Phalanx Weapons System. Also, the round was x-rayed to confirm that this determination was correct, after which all the information was sent to the Crane Naval Weapons Facility in Indiana. The Navy confirmed that this was one of the types of rounds it uses. Mr. Gonser said that since the Navy would routinely use this type of round on shipboard training exercises, one theory is that it got to the base from a Navy person or a Marine.
Mr. Gonser also reported that the Army Environmental Center (AEC) spoke with a number of Army facilities that handle DU, and some "old-timers" indicated that they thought that the Air Force may have tested a 20mm DU round. This led the AEC to talk to some Air Force contacts at Eglin Air Force Base, who spoke about a contract that was let by the Air Force to develop an improved 20mm round. There's an ongoing effort to find someone with information about that contract, as it's not now known whether "improved" means that DU was involved. Mr. Gonser said that these are the two potential sources.
Mr. Hugus asked if any attempt has been made to question Textron regarding the DU round found at Demo 1, as Textron was known to have experimented with armor-piercing rounds at the J Ranges. Mr. Gonser replied that Textron was contacted and did provide the paperwork that confirmed that the rounds that it tested were received on the base and then shipped out again and received in New Mexico. He noted that this is not significantly different from what Textron stated when the DU issue came up several years ago, but this time Textron provided documentation. Mr. Gonser also said that now an effort is being made to look at whether any other past testing contracts might be related to Textron or any of its predecessors.
Mr. McDonagh explained that Textron did a "mass balance type investigation." That is, it looked at what had been brought in and attempted to determine whether it could trace that it had been taken out. That answer was yes, based on the material provided by Textron. The documentation also showed that Textron was not dealing with the same type of DU munition as the one that was recently found. While there might have been other contracts, this is the latest that's known based on the information provided by Textron, which has thus far been forthcoming with providing answers to the IAGWSP.
Mr. Borci affirmed that the round that Textron used was clearly very different from the one found at Demo 1. He also said that since it was not that long ago that the testing ceased on the base, he would recommend contacting EOD (explosives ordnance disposal) personnel and other former employees who worked at the base to see if they could provide further information.
Mr. Hugus noted that for a long time the Navy fired rounds at Noman's Island, next to Martha's Vineyard, and he believes it's possible that it could have fired DU rounds. He then suggested looking into the possibility that the Navy might have done some dumping at the base that's related to those training exercises. Mr. Hugus also said that he thinks it's important to know the origin of the DU round and whether there are any more on the base.
Mr. Mullennix said that he too would like to learn more about ZOCs, and he assumes that the Co-op also would be interested. He then asked that the IART be informed in advance of a Co-op meeting where the IAGWSP makes a presentation on ZOCs, so that he and other team members could attend.
Mr. Mullennix also inquired about the status of the future agenda item "Massachusetts Department of Public Health (MDPH) Update." He noted that two years ago, Suzanne Condon of MDPH announced that available data on neonatal thyroid problems in Bourne would be assessed and presented to the team in a couple of months, but that has not yet happened. Mr. Mullennix noted that he's asked Mr. Williams of MDPH about this situation, but the information does not seem to be forthcoming, which leads him to assume: that there really hasn't been any perchlorate "to any degree" in the Bourne water supply, and that the data do not show "any kind of problem at all." Mr. Mullennix suggested, therefore, that the topic be removed from the future agenda items list rather than left on for another year, without any update occurring.
Mr. Williams stated that it's his understanding that MDPH is in the process of releasing both reports that look at the perchlorate issue on Cape Cod - one from the University of Massachusetts and another from the Harvard School of Public Health. He said that he doesn't know when the reports will be released, but the item was deliberately left on the future agenda items list because the intention is to present that material to the IART.
Mr. Mullennix then asked why depleted uranium is called depleted. Mr. Gonser replied that while his knowledge about the subject is limited, as far as he knows DU is the byproduct of the process to create enriched uranium. This byproduct has very little radioactivity, and thus is called depleted uranium. Mr. Mullennix questioned whether it would be safe then to "carry around a handful of DU for a while." Mr. Gonser replied that the issue has to do primarily with inhaling or ingesting, as skin is fairly protective. He also noted that DU is used for a number of routine items, such as helicopter blades, and keels on some sailboats.
Mr. Schlesinger referred to the "J-3 and L Range" Figure 5 and questioned why there are so many more proposed wells in the area downgradient of the J-3 Range than in the J-2 Range Northern plume or the Northwest Corner. Mr. Gregson replied that most of those wells are part of an ongoing investigation and an approved workplan developed for the J-3 Range investigation. Their purpose is to confirm the extent of known contamination emanating from the center of the J-3 Range and to look at two other potential source areas west of the J-3 Range.
Mr. Schlesinger asked why there aren't more proposed wells to investigate the plume near Co-op water supply well #2. Mr. Gregson said that the best explanation is that that has been a higher priority area; therefore, many proposed wells already have been drilled and sampled there, and it's thought that the extent of that area of contamination is fairly well known at this point. Mr. Schlesinger asked if it's correct that there are no additional upgradient monitoring wells planned for the J-2 Range Northern plume. Mr. Gregson replied that he thinks there might be one additional upgradient location to be drilled. He also noted, however, that the goal is to achieve an understanding of the extent of perchlorate and RDX contamination to the point that an RRA can be put forth to clean up the plume.
Mr. Schlesinger questioned why an additional monitoring well wouldn't be installed downgradient from MW-302 and MW-305 in the J-2 Range Northern plume, for example. Mr. Gregson explained that the IAGWSP tries to balance the need for wells to define the plume versus affecting natural resources where there aren't existing roads. Mr. Schlesinger pointed out that there is an existing road in that area. Mr. Gregson noted that Mr. Schlesinger was referring to Barlow Road, which runs north/south, and said that based on the model and the depth of contamination it's thought that an additional well "in the middle" isn't really needed to show a connection there. Ms. Dolan said that the IAGWSP already has proposed a new well at that location.
Mr. Schlesinger said that there appears to be another road, to the north of MW-305 and heading toward MW-318, where he would suggest that a monitoring well be drilled, in addition to the one on Barlow Road. Mr. Gregson replied that the question is whether that data point would be needed in order to start cleaning up the plume, or if it would be sufficient "to assume that it's somewhere in between that location and this location."
Mr. Borci said that he thinks the project managers could look at the wells that are truly proposed and ensure that they are depicted accurately. He also agreed that the reason why there are not a lot of proposed wells in the J-2 Range Northern plume area is because they've already been installed. At this time drill rigs are not available for drilling the proposed wells near the J-3 Range. He explained that it takes a while to get to some areas because others are considered a higher priority. He also said that it should be kept in mind that not every drop of contamination is defined before treatment begins, but additional wells could be drilled when data gaps are identified, or in response to results from treatment system performance monitoring. Mr. Borci encouraged Mr. Schlesinger to make comments at any time if he thinks a new well is needed, and said that those comments would always be taken into consideration.
Mr. Schlesinger said that his suggestion would be to drill another well "somewhere in the middle there," in addition to the one Ms. Dolan mentioned. He also referred to the plume map that's based on profile sampling results and asked why the plume becomes narrower downgradient after fanning out in the middle, other than because that's what the data show.
Mr. Gregson noted that the data show that the plume does narrow "and go that way." He also said that much of that probably has to do with shifting in the groundwater mound that's causing the contamination to disperse there. Mr. Minior agreed and further explained that concentrations diminish as the contaminant mass becomes reduced through the natural processes of dilution and dispersion. This is why the higher concentrations are seen down the middle of the plume, which basically collapses on itself as result of the natural attenuation processes.
Dr. Dahmani asked if the profile data plume depiction was drawn by hand or by computer. Mr. Gregson replied that it was drawn by hand. Dr. Dahmani said that he thinks the plume has "that weird shape" because there's only one central data point to the north and so it was necessary to guess how that central point relates to the other data points. He suggested that additional points to the left of right of that central point would change the look of the plume, and so he thinks the answer to the question is that there just aren't yet enough data to delineate the plume properly.
Mr. Gregson noted that the mass in the source area has been estimated, and with that information, groundwater modeling was done to determine how the plume might behave over time, and this was used to help draw that plume depiction. Dr. Dahmani maintained that the depiction was still based on a single data point, and he believes that that area needs to be populated with additional data points in order to come up with a better picture of how the plume looks.
Mr. Goydas pointed out the "handful" of wells on Jefferson Road and Gibbs Road that were drilled downgradient of the mapped plume that's based on actual groundwater samples. He then explained that in reality, it's not that the plume has narrowed down; it's that the concentrations there aren't high enough to contaminate that portion of the aquifer. Therefore, although two of the wells on Jefferson Road tested nondetect, the plume probably exists there, but at concentrations that are below the current method of detection. Mr. Goydas concluded by saying "It's not so much that the plume is wicking through a particular portion of the aquifer, there's just not enough mass to drive the plume at high concentrations to those locations."
Mr. Mullennix inquired about the status of the effort to recruit new IART members from Sandwich. Mr. Borci said that he hadn't gotten an update on this issue from Jim Murphy of EPA, who was not at the meeting tonight. He did report, however, that he knows that a number of individuals expressed some interest and were asked to attend an IART meeting, and then start the process to apply for team membership if still interested. Mr. Borci said that he would see to it that an update is provided at the next IART dry run so the issue can be discussed at the next IART meeting. Mr. Mullennix asked if any audience members at this meeting were Sandwich citizens interested in joining the team. He received no response.
Mr. Schlesinger, who noted that he lives fairly close to the ranges, said that last weekend he heard "heavier-than-normal" and "much louder than usual" and longer-lasting noises coming from the base. He said that he's always curious as to whether there might be on-base activities that aren't supposed to be happening, and he would like some clarification on what occurred. Mr. Borci asked if Mr. Schlesinger thought he heard something other than machineguns or small arms. Mr. Schlesinger replied, "Not small arms."
Mr. Gonser said that this request for information would be passed along to the Environmental & Readiness Center. He also noted that he thinks that the last two weeks were a very busy training period, as was a two-week period earlier in the summer. He said that the IAGWSP had done a lot of coordination to ensure that well drilling could continue while some of this training was happening. Mr. Minior suggested that Mark Begley, the environmental officer on the base, might be able to provide some information. Mr. Pinaud indicated his agreement.
Ms. Bonarrigo noted that the next IART meeting is scheduled for August 24, 2004 at the Holiday Inn in Falmouth. Mr. Borci reminded the team members that they were to revisit the question of whether to have an August meeting. Ms. Conron said that she thinks the team needs to meet every month. Mr. Schlesinger agreed and said that while tonight is an exception, ordinarily the team runs out of time before discussing all the agenda items. He said that he thinks it's imperative that the team meet.
Agenda Item #6. Adjourn
Ms. Bonarrigo confirmed that the IART would meet next on August 24, 2004 at the Falmouth Holiday Inn. She then adjourned the meeting at 8:45 p.m.