Impact Area Review Team
Future Agenda Items:
Handouts Distributed at Meeting:
Agenda Item #1. Welcome, Agenda Review, Approval of SAugust 24, 2004 IART Minutes
Mr. Murphy convened the meeting at 6:05 p.m. and the Impact Area Review Team (IART) members introduced themselves. Mr. Murphy reviewed the agenda and asked if there were any changes or additions to the August 24, 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 8/24/04 IART Meeting
Mr. Pinaud announced that the Massachusetts Department of Environmental Protection (DEP) has amended its Massachusetts Contingency Plan (MCP), waste site cleanup regulations. He said that there are many changes, but the one of most interest to the IART is that DEP is promulgating new cleanup standards for explosives and propellants, specifically RDX, HMX, and perchlorate. He also noted that the web site, www.mass.gov, includes information on public hearings, numerical standards and calculations, and differences in how Massachusetts, California, and some other states look at perchlorate. Mr. Pinaud further noted that four public meetings are scheduled and team members might be interested in attending the one held on November 16, 2004 at 7:00 p.m. at the Upper Cape Regional Technical School in Bourne. He said that public comments can be submitted to DEP in writing or at the November 16, 2004 meeting.
Mr. Mullennix asked if the regulations are still in draft form. Mr. Pinaud confirmed that they are and clarified that DEP is in the process of promulgating the regulations.
Mr. Schlesinger asked how the Impact Area Groundwater Study Program's (IAGWSP's) decision-making would be affected until the regulations become finalized. Mr. Pinaud replied that the IAGWSP has agreed to comply with whatever cleanup standards are promulgated. Mr. Schlesinger explained that he's interested in the timing, in terms of whether the IAGWSP will wait until there's a final decision before moving forward. Mr. Gonser replied that the IAGWSP will respond to the regulations once they've been promulgated, as there may be significant comments and changes. In the meantime, in order to operate as efficiently as possible, the IAGWSP will be "starting to think along those lines" so that when the regulations are promulgated the program will be prepared to move along in the most effective way.
Mr. Cambareri thanked DEP for bringing this issue to the IART's attention as a late-breaking news item. He also said that a recent newspaper article mentioned a proposed perchlorate cleanup standard of 1 ppb, and asked if that is the GW-1 standard. Mr. Pinaud replied that it is, and explained that that is the most conservative groundwater category, pertaining to groundwater that can be used for drinking water.
Mr. Walsh-Rogalski noted that in general the U.S. Environmental Protection Policy (EPA) policy regarding changing standards is to look at remedies retrospectively in order to ensure that they are protective. If a standard is changed for health reasons, EPA would require that the remedy be altered to conform to the new standard. If a standard is changed for reasons other than health, EPA might not require that the remedy conform to it.
Mr. Borci added that with regard to the site-specific cleanup being undertaken, EPA's numbers will meet or beat the state standards. EPA looks at the numbers from a site-specific perspective and bases "everything on leaching." He also said that with respect to the proposed numbers, "We're there; we're already lower."
Mr. Schlesinger inquired about the responsibility of the towns that surround the base, in light of the new standards. Mr. Pinaud replied that the standards being discussed are waste site cleanup standards, which would affect any soil or groundwater contamination coming from known source areas being tracked as a cleanup project. The water suppliers have their own sets of regulations, but the subject at hand pertains specifically to cleaning up groundwater.
Dr. Dahmani asked about the timeframe for promulgating the new standards. Mr. Pinaud replied that while it depends on the number of public comments submitted, he thinks the new standards should probably be promulgated by late winter/early spring.
Responses to Action Items from the August 24, 2004 IART Meeting
Mr. Schlesinger referred to Action Item #1, his request for information on the origin of specific zones of contribution (ZOC) depictions shown on IAGWSP maps, and the IAGWSP's proposal to use forward particle tracks and time markers on maps rather than ZOC depictions. He mentioned an early diagram that indicated that the Demolition Area 1 (Demo 1) plume would take 20 years to reach the edge of the base, and that turned out to be wrong. He then asked what is meant by "time markers" and whether there are error bars associated with them.
Mr. Gregson replied that time markers on a particle track are just a tool to help understand what's happening with a particular detection. He also said that the position of a particular detection in the plume is significant because it might not end up being at the toe; further investigation could reveal other detections downgradient, as was the case at Demo 1 and at the western boundary in Bourne. Mr. Gregson said that time markers show model-based information, but it's still necessary to look at the overall picture.
Mr. Schlesinger said that although he understands this, he's concerned about the general public's perception. He also mentioned that perchlorate moves faster than originally thought and he believes that it's important to err on "the liberal side with respect to human health, rather than strictly based on the model." Mr. Gregson said that as new information becomes available, models change, interpretations change, and particle tracks and time markers will change. He reiterated that particle tracks and time markers are just part of the tools used to assess the plumes. Mr. Schlesinger remarked that if time markers are going to be depicted on maps, he would hope that they move monthly with the new data coming in, unlike the static ZOCs that have been shown.
Ms. Conron asked if the time markers on the particle tracks indicate the number of years it would take for pollution to reach a particular area. Mr. Gregson referred to the sample figure depicting Central Impact Area contamination, which was included with the Responses to Action Items document, and he pointed out a monitoring well where perchlorate was detected. He explained that the particle track from the well shows the direction the contamination is expected to travel and the time markers indicate 10-year intervals of travel. Ms. Conron noted that particle tracks shown on the figure head toward an area in Bourne that's been identified by the U.S. Geological Survey (USGS) as a potential future water resource area. Mr. Gregson stated that those particle tracks show that if the concentrations of upgradient detections of perchlorate and RDX were high enough, they would travel beneath that area before discharging to the canal.
Mr. Borci stated that he strongly disagrees with the response to this action item, which proposes to replace one piece of information, the ZOCs, with another piece of information, particle tracks and time markers. He said that ZOCs are one tool in the toolbox to help prioritize areas of contamination, and he doesn't think it matters if one model was used to create the ZOC for the Town of Sandwich wells and another was used to create the ZOCs for the Upper Cape Water Cooperative (the Co-op) wells, for example, because "it's just a piece of information..." Another piece of information is the particle tracks, which help inform the placement of downgradient monitoring wells. He said that the time makers are usually inaccurate, and the particle tracks themselves are "hit or miss" depending on the distance from the top of the mound and other factors. Mr. Borci stated that he thinks that both ZOCs and particle tracks, and perhaps time markers, should be provided because it's important to know where the contamination is headed and where the water supply is drawing its water.
Mr. Cambareri agreed that these are two separate pieces of information and that ZOC depictions are important in terms of the relationship between contamination and a water supply source. He also noted that according to the map that was shown, the particle tracks and time markers indicate that it would take 20 years for the Central Impact Area contamination to reach the base boundary and the area identified by the USGS as a potential water supply area, and he is sure that within that timeframe the IAGWSP will have installed a containment system to address that contamination.
Dr. Dahmani asked if it's correct that the cleanup program's general approach is to intercept all plumes heading toward the general direction of water supply wells. Mr. Gregson replied that action is warranted if a plume is a threat to a particular water supply well. Dr. Dahmani said that because the USGS has done a good job of mapping groundwater flow on Cape Cod, one has a fairly good idea of where the plumes are headed. And if the intent is to catch the plumes and treat the water, the ZOCs don't "bring anything new to the ultimate remedy" that's going to be applied. He also said that he believes that it's understood that the ZOCs and particle tracks are two separate things, and it would be okay to show both of them, as long as that is understood. Dr. Dahmani added that if the plumes that are headed in the general direction of water supply wells are going to be captured, the ZOCs don't contribute a lot to the understanding "of what's going to be occurring in terms of remediating the site."
Mr. Schlesinger noted that when he first read the response to the action item, he expressed a desire to have both ZOCs and particle tracks and time markers shown on maps. He acknowledged that this could be confusing on a map, but he thinks it's important to have both, especially for members of the public who might be affected. He said that if the ZOCs were eliminated from the maps, the public would not be provided with this information, which it would not know otherwise.
Mr. Dow said that scientists don't make point estimates from projection models, but instead develop confidence intervals so that managers or policy makers have an idea of the uncertainty of the future predictions. He suggested that the IAGWSP explore some of these methods, such as bootstrapping, to make confidence interval estimations for model-predicted point estimates.
Mr. Borci said that some thought has gone into "how best to show these things," but one can see how confusing a map with particle tracks and time markers can be. He then spoke of the projected paths of hurricanes, shown so often on television lately, which appear relatively certain "close in," with the uncertainty increasing "farther out." He recommended viewing the particle tracks similarly, keeping in mind "a sort of visual representation of the data and error bars and uncertainty" that Mr. Dow mentioned.
Mr. Pinaud referred to Action Item #2, Mr. Mullennix's request for information on perchlorate concentrations detected in public water supplies across Massachusetts. He noted that he'd be discussing data from testing conducted in April 2004, and reported that of the 693 public water supplies required to sample for perchlorate, 594 (or about 86%) have submitted results to DEP. He also said that DEP approved seven laboratories that passed proficiency testing to use a modified Method 314 for perchlorate analysis, which he described as "a bootstrapped QA/QC methodology." The water suppliers were required to use only these laboratories, which document the ability to achieve a reporting limit of 1 microgram per liter (µg/L).
Mr. Pinaud then reviewed results from water supplies where perchlorate was detected: Hadley's Highway & Water Department reported detections from 1.5 to 3.2 µg/L or parts per billion (ppb); a condominium complex in Boxboro reported detections from 4.8 ppb to 15 ppb, as well as a recent detection of 791 ppb, believed to be from the complex's swimming pool, which was filled using that water supply; Milbury's private water company, Aquarian Water Supply, reported detections from 16.1 ppb to 45.3 ppb; Westford reported detections up to 3.7 ppb; and Tewksbury reported detections up to 3.2 ppb. In addition, perchlorate was detected at two non-transient, non-community water supply wells: Mount Greylock Regional High School in Williamstown reported detections from 1.03 ppb to 9.6 ppb, and Westport High School reported detections from 1.1 ppb to 3 ppb.
Mr. Pinaud said that although more systems had perchlorate detections than expected, based on the number of water supplies that were tested statewide, only a limited amount have a perchlorate issue. He said that DEP's next steps are to search for sources of the perchlorate, which might include chlorination from wastewater treatment plants, blasting operations, fireworks launch sites, and current and former military sites.
Mr. Mullennix thanked Mr. Pinaud for providing this information. He also said that he thinks it's terrific that the list of public water supplies where perchlorate was detected did not include any on Cape Cod.
Mr. Gregson asked when the next sampling round is scheduled to occur. Mr. Pinaud replied that the next round is to occur this month, September. Mr. Gregson asked if results from the September sampling round would be provided over the next few months. Mr. Pinaud confirmed that they would.
Dr. Dahmani asked if the sampling was conducted by DEP or by the towns. Mr. Pinaud replied that he believes that each town took its own samples and sent them to one of the DEP-approved laboratories.
Mr. Borci remarked that while it's great that no Cape Cod public water supplies had perchlorate detections, it's important to remember that there is perchlorate contamination in groundwater off base, and a number of private wells have been or may have been affected. He said that the entire aquifer in this area is a water supply, it's known to have been affected, and the issue needs to be addressed.
Mr. Mullennix explained that he just wanted to point out for the sake of perspective that while it's true that there were one or two perchlorate detections slightly above 1 ppb in private wells on Cape Cod, a significantly larger number of people within the state were found to be drinking perchlorate-laden water, given the public water supplies that tested positive.
Mr. Cambareri inquired about perchlorate concentrations detected in the Bourne Water District wells. Mr. Borci replied that while he's not certain, he believes that any detections in the wells themselves were less than 0.5 ppb. He also said that he thinks that the Bourne Water District imposed upon itself a cutoff value of 0.5 ppb; that is, it would shut down a well that had a perchlorate detection that exceeded that number.
Mr. Schlesinger inquired about the towns' responses to the perchlorate data. Mr. Pinaud replied that it's his understanding that the towns are using the 1-ppb action level developed by DEP. He said that as soon as the detections were identified, the towns shut down the wells and called on DEP to help fix the problem. In some cases, they were able to get water from other towns temporarily, and some towns are operating without their backup wells for a time.
Agenda Item #3. Remediationi Update
Demolition Area 1 Groundwater Rapid Response Action
Mr. Nixon reported that the new treatment plant at Pew Road began operating on September 8, 2004, pumping 100 gallons per minute (gpm), and capturing influent perchlorate concentrations of about 3 ppb. He also noted that RDX was detected in the influent at about 0.25 ppb, which is the detection limit. He further noted that the treatment plant at Frank Perkins Road began operating this morning, which means that the entire Demo 1 Rapid Response Action (RRA) system is pumping a total of 320 gpm, or 0.5 million gallons per day (mgd). Mr. Nixon stated that the IAGWSP will build upon the RRA system through the feasibility study (FS), which will lead to the comprehensive remedy.
Mr. Nixon showed a photograph of the three containerized units at the Frank Perkins Road system. He also announced that there will be a ceremony and tour on October 5, 2004 to celebrate the cleanup program's transition from investigation to remediation, including both soil and groundwater cleanup. He said that IART members should have received their invitations to this event. Mr. Schlesinger noted that he hadn't received an invitation, and Mr. Cambareri inquired about obtaining access to the base.
Ms. Curley of the IAGWSP replied that she'll need to gather driver's license numbers, information on the make and model of vehicles, and license plate numbers, which she'll provide to the guards at the gate so that attendees of the event can gain access. She said that the event will begin at the Welcome Center at 10:30 a.m., and be followed by a bus tour to the Demo 1 site. Ms. Curley also said that she'd e-mail an invitation to Mr. Schlesinger. She noted that she can be reached at 508-969-5626 to answer questions and provide further information.
Soil Rapid Response Actions
Mr. Nixon reported that at the Demo 1 soil RRA site the lift has been completed to about 8.5 to 9 feet below grade and sample results are pending. Excavation work there is nearly completed, with the exception of the soil underneath the stockpiles. Mr. Nixon noted that soil is being removed to the point that concentrations of RDX are below the reporting limit of 120 ppb, which is approximately one-ninth the new standard proposed by DEP. The IAGWSP is excavating to a much lower standard, and actually excavating to background.
Mr. Nixon stated that to date about 23,500 tons of soil has been excavated from the Demo 1 site, about 1,100 tons from the Demo 2 site, about 3,500 tons from the J-3 Range, about 8,000 tons from the J-2 Range, and about 2,000 tons total from Targets 42 and 23 at the Central Impact Area. He noted that excavated soil from all these sites is being treated at the thermal desorption unit at the H Range, which will be part of the tour in October.
Mr. Dow inquired about any plans for additional soil RRAs. Mr. Nixon replied that there are no other soil RRAs currently planned; however, there are some smaller sites under the Soil Management Plan, from which excavated soil will be treated at the thermal desorption unit. Those include the High Use Target Area (HUTA) stockpile, about 800 cubic yards of soil that was excavated several years ago; soil excavated from blow-in-place (BIP) event locations; and about 200 cubic yards of soil from two former gun positions. Mr. Borci clarified that these are proposals; the regulators have not yet given their approval to go forward with that treatment. Mr. Nixon agreed.
Mr. Dow noted that it's his understanding that the thermal desorption unit will be on base for just a fixed period of time. Mr. Nixon said that the IAGWSP is treating as much soil in the unit as it can at this time. The unit will be demobilized beginning October 22, 2004, and if needed, will be brought back sometime in the future. He noted that infrastructure that supports the unit, such as the concrete pad and electricity, will be kept in place.
Dr. Dahmani asked when the report on the pilot scale data from the Demo 1 groundwater treatment system would be provided. Mr. Nixon replied that the report is currently in internal draft form, and should be available in another month or so. Dr. Dahmani then asked how those data might affect the final remedy at the site. Mr. Borci stated that any future remedy would build on the existing RRA system, while the biggest question to be answered is whether straight carbon is sufficient. Dr. Dahmani asked if the plan is to wait a year or so before reaching a final decision on the filter medium. Mr. Borci said that he thinks things will work out such that that decision has been made once the final remedy is selected. Mr. Nixon added that the results from the Innovative Technology Evaluation (ITE) study and what's learned from the RRA system will lead to a decision on the most efficient filter medium for the comprehensive system.
Mr. Nixon stated that about 27,000 tons of soil has been treated at the thermal desorption unit, which includes soil from Demo 1, Demo 2, the J-3 Range, and the J-2 Range. Cleanup guidelines, which are the same as the excavation guidelines at Demo 1, are being met, and are below the proposed MCP standard for RDX. The soil is being retreated if perchlorate exceeds 4 ppb (the reporting limit), and there hasn't been a breakthrough in several loads.
Agenda Item #4. Investigation Update
Demolition Area 1 Recent Results
Mr. Nixon showed a map of Demo 1 and noted that the plume shell shown does not include all the newest data, but is in the process of being updated, after which it will undergo interval review by EPA and DEP to get their buy-in. He also noted that more modeling will be done of the toe of the plume, which, according to modeling that included data through last May, shows that, with the RRA system operating, contamination at the toe would dissipate to below detectable levels before reaching the base boundary, in the vicinity of North Pond. The model will be updated with newer well data, which show higher contaminant concentrations in that area, to see if that would still be the case. Mr. Nixon pointed out a monitoring well where perchlorate was recently detected at 14 ppb, but previously detected at about 4 ppb; a well where it was recently detected at 4.6 ppb; and another well where it was recently detected at 1.4 ppb, but previously detected at 0.9 ppb. He said that all this information will be used to develop new plume contours and update the model, which will be used in the FS and the remedy selection process.
Mr. Schlesinger questioned the meaning of Mr. Nixon's remark about getting buy-in from the regulators. Mr. Nixon explained that the IAGWSP is seeking the regulators' concurrence on an updated plume shell before investing in the modeling. He also said, however, that he doesn't see why it couldn't be shown to a wider audience.
Mr. Borci stated that the Demo 1 Draft FS for Groundwater had already been presented to the IART and comments were solicited from the team, the public, and the regulators. He also reminded the group that at that time EPA expressed a preference for Alternative 6, which included an extraction well at the toe of the plume, while the IAGWSP preferred Alternative 5, which did not. Since the time that the FS, which included data up to a specific cutoff point, was written, higher concentrations have been detected at the toe of the plume, including an 11-ppb perchlorate concentration in MW-211 on Pew Road. These newer data further support EPA's position that the comprehensive remedy should include an extraction well at the toe of the plume, but the IAGWSP did not agree. The resolution to that disagreement was to update the model and conduct some sensitivity analysis. Mr. Borci said that it's understood that this effort will delay the remedy selection, but he thinks that the delay is worthwhile in order to ensure that the correct remedy is implemented. Mr. Nixon agreed that the remedy selection plan will be delayed, but also noted that the IAGWSP and the regulators have agreed on five-sixths of the remedy, and design efforts would be starting fairly soon.
Dr. Dahmani asked if an extraction well at the toe of the plume would be considered necessary in the event that a 1-ppb standard for perchlorate is promulgated. Mr. Borci replied that that possibility needs to be considered. He also said that the point is aquifer restoration, not whether perchlorate concentrations dilute before they reach the base boundary. He further stated that the 1-ppb concentration already has been exceeded at the most downgradient monitoring well. Mr. Nixon noted that drilling of two new sentinel wells (between the plume and North Pond) began yesterday.
Mr. Borci returned to the topic of the thermal desorption unit. He acknowledged that it's good news that 27,000 tons of soil has been treated, but expressed frustration about the plan to demobilize the system after it's finally been fine tuned, and while there are more sites "that could be addressed in a relatively short timeframe." Mr. Nixon stated that there are only about three-more-weeks' worth of soil currently in the queue and approved for treatment. However, the unit can be brought back on site, if needed. He also noted that small amounts of excavated soil could be transported off site.
Mr. Borci countered that the amount of contaminated soil at the base is nowhere "near the end of the line." For example, 37 targets at the Central Impact Area are believed to have contamination around them, and 25 of those have data to prove it, and there are number of gun positions with soils that exceed cleanup numbers for propellants. Mr. Borci said that it's just a matter of submitting reports so that EPA can approve the soil for treatment in the thermal desorption unit. He explained that there has to be accurate documentation of what goes into the unit - for example, there can be no Resource Conservation and Recovery Act (RCRA) waste. It has taken some time to fine tune what needs to be included in the reports that are submitted to EPA so that it can give approval for treatment, but "there's plenty of stuff out there to treat."
Mr. Schlesinger asked why the treatment unit has to go off site, and how the IAGWSP could be convinced to keep it on site. Mr. Nixon replied that the unit is rented and is expensive to have on site. Given that at this time there's no soil in the queue, ready to go, the choices were to keep the unit here until there's some soil ready for treatment, or let it go and bring it back at a future date, which is what the IAGWSP decided to do. Mr. Schlesinger asked how long it would take to bring the unit back to the site. Mr. Nixon replied that it wouldn't take long since the air permitting has been taken care of and the infrastructure will remain in place at the H Range. Mr. Gregson agreed that with the air permitting and infrastructure in place, and the unit being on wheels, it would not take anywhere near as long to return the unit to the site as it took to get it there initially.
Mr. Gregson also said that a great deal of contamination likely exists within the 300-acre Central Impact Area, and one of the goals of the RRA at two of the targets there is to assess whether excavating and thermally treating the soil from around the remaining targets is an effective technique for treating Central Impact Area contamination, before excavating what could be as much as hundreds of thousands of cubic yards of soil. Mr. Gregson also acknowledged there are a handful of gun positions that have contamination above state levels. He noted that consideration is being given to employing an in situ technique at the gun positions, which would be less intrusive than excavation and treatment, and which might provide a remedy for all the gun positions at the Massachusetts Military Reservation (MMR) and for Army gun positions throughout the country.
Mr. Schlesinger asked again what could be done to keep the thermal desorption unit at the base. Mr. Gregson replied that, as Mr. Nixon explained, based on the economics of keeping the unit on site while not operational, the IAGWSP has decided to end the lease and send the unit back to the contractor. Mr. Nixon questioned the wisdom of keeping the unit on base when doing so would be more costly than ending the lease and bringing it back in the future, if needed.
Dr. Dahmani asked why thermal treatment might not be the technique to use for Central Impact Area contamination, when it's the same type of contamination at Demo 1. Mr. Gregson clarified that he's not saying that the technique could not treat Central Impact Area soil; rather, he's questioning, given the widespread contamination there, whether there might be a better remedy. Dr. Dahmani said that he doesn't know of any other technique that's more effective than excavation. He also noted that his understanding was that the general approach to the cleanup is to excavate and treat source area soils and then extract and treat groundwater to control the plume. He added that he thinks this is a very reasonable approach that would bring comfort to the population of Cape Cod because it's an effective method. He further noted that he thinks that in situ techniques would be more expensive, and he sees none on the horizon that would be more effective than the current method.
Mr. Nixon mentioned successful lab-scale studies that looked at the use of lime, peat moss, and other organic materials, for in situ soil treatment. He said that the IAGWSP is interested in investigating how well this might work on a larger scale. He also said that the thermal desorption unit is not at all cheap. Dr. Dahmani said that unlike using this technique on a bench scale test, there's a lack of control in the field with respect to injecting organic materials and whether or not they would treat the whole area. With all in situ techniques, delivery of the treatment is a problem because of the heterogeneous nature of soil. Excavating and treating, however, is a very effective technique. Mr. Nixon noted that he thinks it would more likely be a surface addition, rather than injection of materials.
Mr. Gregson remarked that these are the kind of issues that need to be hashed out through the Central Impact Area FS process: whether excavating 300 acres needs to be done; if so, how it should be done; whether there's enough money in the program to do it; and whether there's a better, more appropriate remedy for this area of high ecological sensitivity. He said that the plan is to make an informed decision, through the FS process, on the best remedy for the Central Impact Area as a whole.
Ms. Conron inquired about the cost of using the thermal desorption unit. Mr. Nixon replied that he doesn't know exactly, but the contractor has been tasked to assess that figure. Mr. Gregson said that millions of dollars have been spent on this activity. He also explained that Mr. Nixon was referring to a request of the contractor to provide a breakdown cost per ton that would include the air permitting and construction of infrastructure, as well as a cost per ton pertaining to future use, now that everything is in place.
Ms. Conron inquired about the meaning of "documented" soil. Mr. Nixon replied that if the regulators approve of all the soil that's currently available for treatment, the unit will run out of soil to treat on October 23, 2004. Ms. Conron noted that there's more contaminated soil at the base, and asked if documenting that soil means that it has to be tested. Mr. Nixon explained that to get approval to treat the soil, the IAGWSP has to prepare documents for the regulators to review and approve. He also noted that so far approval has always been given, with the one exception of the MT-9 stockpile.
Ms. Conron asked if it's correct that more soil isn't being prepared for treatment in the unit because it might not be effective, or it might be too expensive. Mr. Nixon explained that for the first batch of soil to be treated, the IAGWSP prioritized sites that have the biggest potential impact to groundwater (Demo 1, Demo 2, the J-2 Range, and the J-3 Range), as well as readily available soil, such as from the HUTA stockpile and some gun positions. He added that the IAGWSP is not trying to say that this is the last batch of soil to be treated.
Ms. Conron also inquired about the less expensive method of adding lime to the soil. Mr. Nixon explained that it turns out that raising the pH of the soil changes the contaminant to a different form and degrades it. He also said that in the future there'll be more discussion about alternative methods.
Mr. Mullennix remarked that it's important to keep in mind that the "hotspots" identified during the investigation phase (at Demo 1, Demo 2, the J-3 Range, and the J-2 Range) have been cleaned up using the thermal desorption unit. What predominantly remains is the Central Impact Area, which is a very large area that has discrete sources of contamination, rather than a single hotspot. He said that he's unfamiliar with any previous attempts to clean up such a large area of disperse contamination, and, as Mr. Gregson mentioned, the FS process will help in gaining understanding about the cost-effective and correct way to clean up this area. Mr. Nixon added that six months ago the only source area cleanup being discussed was Demo 1, and now excavated soil from about seven other sites also is being treated at the thermal desorption unit.
Mr. Borci said that the IAGWSP brought the unit on site to treat a finite amount of soil over a finite period of time and the regulators asked that it look into treating other soils while the unit was on base. He said that the problem is that there wasn't a clear process from the beginning whereby the IAGWSP was finding a site, producing a report, finding the next site, producing the next report, and so on, so that the regulators were able to review and approve sites constantly and keep the treatment unit operating. He said that there's enough contaminated soil that this process could have worked, even excluding contaminated soil from the Central Impact Area. Mr. Borci added that some additional foresight might have helped to keep the unit on site, using not only fiscal year 2004 (FY'04) money, but also FY'05 money.
Mr. Schlesinger remarked that he thinks this is "hogwash," and that the IAGWSP really doesn't want to clean up the Central Impact Area, but would rather wait for some other remedy "like letting it go on its own" because it doesn't want to spend the money. He also said that he, and perhaps the majority of the public, would disagree with that approach, and he strongly encouraged the military to "get on with" the cleanup.
Mr. Walsh-Rogalski disagreed that the only source area site being discussed for cleanup six months ago was Demo 1, as he was at meeting more than six months ago when the regulators and the IAGWSP talked about continuing to move soil through the treatment system as long as there was contaminated soil at the site. Therefore, he was somewhat surprised to hear that the unit was leaving. He also suggested that a clear statement from Mr. Gonser providing assurance that the unit could be returned to the site when needed would help to close this conversation.
Mr. Gonser explained that the unit is rented; the contractor's goal is to have it fully operational at all times, and the IAGWSP would have to request it. However, there was no problem renting the unit the first time, and he wouldn't anticipate any problem in the future. Mr. Gonser also mentioned that for smaller sites, it might be more effective to ship out the excavated soil. He further noted that a great deal of soil needs to be stockpiled in order to keep the thermal desorption unit operating 24 hours a day, and if it's not running full time, money that could be spent on cleanup elsewhere would be wasted on a unit on standby. Mr. Gonser said that while he believes there would be no problem getting the unit back to the site, he can't make that promise, as it would depend on the unit's availability.
Mr. Nixon noted that the thermal desorption unit at MMR is not the only unit of its kind; there are others just like it. Mr. Walsh-Rogalski asked who owns the unit on the base. Mr. Nixon replied that the name of the company is ESMI, which is a subcontractor to the IAGWSP's contractor, Environmental Chemical Corporation (ECC). Mr. Walsh-Rogalski asked if ECC has an ownership interest in ESMI. Mr. Nixon replied that he doesn't think so, but doesn't know.
Dr. Dahmani inquired about the process for determining which sites will be RRA sites. Mr. Gonser replied that RRAs are proposed to move a project along faster. If the contamination is clearly actionable and tied to groundwater contamination, an RRA to remove the source area is proposed. A normal FS process is undertaken if the contamination may or may not be actionable, may or may not be linked to groundwater contamination, if the investigation hasn't been completed to the point where the contamination is fully understood, or if there are massive ecological impacts associated with the site, such as the Central Impact Area.
Dr. Dahmani asked if it's correct that there are no additional RRA soils that can be treated at the thermal desorption unit. Mr. Gonser replied no other soil RRAs are planned or in the works at this time, but there are planned groundwater RRAs at the J-3 Range and the J-2 Range. Other possible soil RRA sites are smaller areas, the soil from which would likely be shipped off site, or material from burn pits, which would not go into a thermal desorption unit.
Dr. Dahmani asked if the bench-scale testing of alternative soil treatment technologies is an active process. Mr. Gonser replied that it is, and noted that the tests include those that Mr. Nixon mentioned, as well as a composting method for the gun positions, which the U.S. Army Environmental Center (USAEC) is looking at.
Ms. Conron asked if any of the Central Impact Area contamination, which is emanating toward Bourne, has been cleaned up. Mr. Nixon replied that Targets 42 and 23 have been cleaned up. Ms. Conron expressed concern, as a resident of Bourne, about Central Impact Area contamination in groundwater, and added, "If it's as simple as lime added to the soil... I don't understand why this soil would be different."
Mr. Gonser stated that the concern is groundwater, and the link between the soil and groundwater. He said that at many sites it's important to know what that link is, and how source removal might affect the groundwater remedy, or vice versa. At the Central Impact Area, for example, the solution might be to cut off the plume rather than remove the source. He also mentioned the massive ecological problem associated with the Central Impact Area, where state-listed species reside. Mr. Gonser further stated that at this point there's no convincing evidence that cleaning up the targets would positively impact the groundwater. He said that the IAGWSP does not want to spend money on an effort that's not certain to be productive when that money could be spent on efforts that are known to be useful, and this still has to be sorted out.
Ms. Conron asked if methods to clean up the Central Impact Area are being actively pursued. Mr. Gonser replied that the IAGWSP is conducting the FS, which will list options for remedies, and is looking at the possibilities that were discussed tonight, including excavation. He also said that the IART would have an opportunity to weigh in on the options.
Mr. Borci noted his belief that the FY'04 budget is the deciding factor with respect to how much soil is treated in the thermal desorption unit. He said that he thinks it comes down to money, and also believes that the longer the unit is kept on the base, the more effective and cost-effective it would be. Mr. Borci also stated that there's no need to wait until groundwater is contaminated in order to take action on soil that's already known to be in need of remediation, and he thinks that is "an awful position to take." He added that a perfect example is the gun positions that have contamination above state or EPA cleanup numbers, which the regulators have asked the IAGWSP to remediate, but which it has not because it's waiting to see if that contamination affects the water table.
Mr. Gonser stated that Mr. Borci is clearly incorrect that money is the deciding factor. He said that the question is not how much money is available, but how the money is spent - either on an idle treatment unit, or on feasibility studies, investigations and cleanup, and shipping off soil that's known to be contaminated. He explained that it does not make sense to keep the unit on site because it processes soil so quickly that there would have to be 50 tons of soil ready to go, and that is not the case. He also made the comparison to the contained detonation chamber (CDC), which the regulators required be kept at the base on standby. He said that hundreds of thousand of dollars were wasted until the IAGWSP said that the CDC should be sent back and then returned to the base when needed. Mr. Gonser stated that the real reason the thermal desorption unit is being demobilized is not because the money isn't available; it's just a basic decision on the smartest way to move the cleanup forward.
Mr. Dow asked what kind of timeframe is needed to request money for FY'06, since he assumes the Central Impact Area won't be addressed in 2005. Mr. Gonser replied that to a large extent the money for 2006 is already programmed because the federal government programs its budget five years in advance. However, the IAGWSP does have some flexibility to move money around within the budget, and therefore is not restricted from responding to particular needs that become important, such as the J-2 Range Northern plume this year. Mr. Dow asked if this means that a major new initiative really couldn't be addressed until 2007 if the IAGWSP didn't have the money that it could reprogram in 2006. Mr. Gonser replied that it's correct that the IAGWSP has a fixed amount; therefore it might be difficult to address a really large new initiative in 2006 without having to postpone other projects planned for that year.
Mr. Cambareri inquired about the timetable for the Central Impact Area FS and separating out the groundwater unit and soil unit. Mr. Gonser replied that the groundwater FS is currently in progress and the soil FS would fall in behind it. He also noted, however, that he's concerned that the two are separated and thinks they need to be linked because of the difficulty of making a decision on groundwater until there's a decision on source removal. Therefore, the IAGWSP is trying to "pull up the soil to link in with the groundwater," and expects to have the FS completed by next year. Mr. Cambareri asked if the effort would include more fine-tuning of the delineation of the toe of the plume. Mr. Gonser noted that there's more investigation happening at the Northwest Corner, if that's considered to be the toe. He also said that he believes that at least two additional wells have been budgeted for the area between the Central Impact Area and the Northwest Corner.
Mr. Pinaud noted that no one wants to see money wasted on an idle treatment unit; however, he believes that the issue is that there is soil on the base that should be treated and could keep the unit busy. He said that if tomorrow the IAGWSP proposed to DEP and EPA to remove the top foot of soil from all the gun and mortar positions, the regulators would likely find a way to provide quick approval so that that soil could be treated at the thermal desorption unit. He said that he thinks there are ways to keep the unit operating if everyone works together, and added that he certainly doesn't want the process to slow down the cleanup.
Mr. Borci referred to Mr. Gonser's earlier reference to the CDC and said that in fact money was not wasted because of EPA requirements. Rather, the IAGWSP made a management decision to build up a stockpile of items and bring the CDC back to the base twice a year, which it proposed to the regulators, who agreed to the decision.
Mr. Borci also stated that when the regulators first heard that the thermal desorption unit was coming to the base, they said, "Let's start lining up the dirt." At that time the regulators were told that a certain amount of money was available to treat soil and so many RRAs would be done, but it was unclear how many, and the regulators raised the issue of the gun and mortar positions where cleanup standards were exceeded. Mr. Borci said that his point is that if the IAGWSP had thought ahead and submitted plans for all sites that are clearly "remediation worthy," there would be more soil available now to go through the treatment system. He also referred to Mr. Gonser's mention of the need for a nexus between soil and groundwater and said that "that's where the issues come into play." He also said that he wants the citizens to be aware of what went on "behind the scenes."
Mr. Mullennix said that he thinks he's hearing that at some gun positions there are contaminated soils that might not clearly be contaminating groundwater at this point. He then asked Mr. Gonser or Mr. Gregson if the barrier to cleaning up those soils at this time is the process, but it's expected that at some point in the future they will be cleaned up by a thermal desorption system. Mr. Gregson replied that for treatment in the thermal desorption unit, the IAGWSP gave priority to sites that had a clear impact and were contributing to groundwater contamination. He noted that 2,4-DNT has not been detected in groundwater near gun positions with soil contamination above cleanup levels. The IAGWSP's position was to take a closer look at the gun positions, determine whether there might be less expensive alternatives to address those sites, and use the money that's saved on thermal treatment for other sites. Mr. Gregson also said that he doesn't recall which other site soils (outside of the Central Impact Area and the gun positions), as was suggested, that could have been lined up for treatment in the thermal desorption unit if plans had been ready and investigations complete.
Dr. Dahmani remarked that the philosophy of the entire investigation doesn't seem to be clear, and he thinks it's important for the citizens to understand the ultimate purpose. He questioned whether the program is trying to clean up soils to certain cleanup levels, or if it's conducting risk-based corrective actions that involve looking at whether or not groundwater would be affected. Dr. Dahmani said that he thinks that members of the community need to know what the approach is, and what the IAGWSP and the regulators have agreed on.
Mr. Gregson asked the team to keep in mind that the actions being discussed are RRAs, also known as Interim Actions under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), and as Release Abatement Measures under the MCP, all of which are designed to clean up sites that can be cleaned up quickly, while providing the best bang for the buck with respect to protecting groundwater.
Mr. Schlesinger asked that a request for an answer to Dr. Dahmani's question be noted as an action item. He said that he thinks this issue must be resolved, whether that requires a one-paragraph answer from the IAGWSP or a full discussion at a future IART meeting. He also asked if it's correct that the monthly cost of the thermal desorption unit to the cleanup project is $25,000. Mr. Murphy recommended that this request for information be noted as an action item so that the meeting could move forward.
Northwest Corner Recent Results
Mr. Gregson showed a map of the Northwest Corner investigation area and pointed out MW-344, which was installed to help define the eastern plume boundary and monitor a possible link to the L-3 Range. He reported that profile sampling at MW-344 showed perchlorate in five intervals, at concentrations ranging from 0.4 ppb to 0.72 ppb. The detections occurred both at the water table and deeper, and screens have been set in the well.
Mr. Gregson then pointed out MW-350, which was installed to further define the southeastern extent of perchlorate contamination and to help determine the source of the 5-ppb RDX detection in MW-323. He noted that the RDX at MW-323 appears to tie in to downgradient RDX detections at wells 4036011, RSNW06, MW-284, and MW-270. Mr. Gregson reported that profile sampling at MW-350 showed no RDX and no shallow perchlorate. However, there were deeper detections of perchlorate, and screens were set in the well. Mr. Dow inquired about the concentrations of the perchlorate detections. Mr. Gregson replied that they ranged from 0.64 to 0.84 ppb.
Mr. Gregson reported that 37 soil samples collected in the area yielded two perchlorate detections: 2.95 ppb at a location on Canal View Road, and 3.08 ppb at a location at gun position 14 (GP-14). He also noted that town water hookups for the three homes on Foretop Road have been completed.
Mr. Walsh-Rogalski inquired about the depth of detections in MW-350. Mr. Gregson replied that perchlorate was detected in three intervals, 135 to 155 feet below the water table. Mr. Walsh-Rogalski asked if Mr. Gregson could offer any conclusion on the source of that perchlorate. Mr. Gregson replied that perchlorate at that depth probably tracks back to the Central Impact Area.
Mr. Borci said that this is the first he'd heard about the soil results and assumes that all the information will provided at Thursday's technical meeting. Mr. Gregson confirmed that an update would be provided.
Mr. Dow asked about the depth of the soil samples. Mr. Gregson replied that they were surface soil samples, with nothing below two feet down. Mr. Dow asked if samples were collected in increments in that two-foot interval. Mr. Gregson replied that he'd have to look at the workplan to be certain, but typical depth intervals are 0 to 6 inches and 18 to 24 inches. Mr. Dow asked if the detections Mr. Gregson mentioned occurred off base. Mr. Gregson clarified that they occurred on base, on Canal View Road and south of GP-14.
Dr. Dahmani asked if the Northwest Corner qualifies as an RRA site. Mr. Gregson replied that it will as soon as an actionable source area is found. Dr. Dahmani noted that Mr. Gregson had said that the perchlorate detected at MW-350 tracks back to the Central Impact Area; therefore at least some of the source is known. Mr. Gregson replied that that's correct, but within about 300 acres.
Dr. Dahmani inquired about the process to add the site to the RRA list. Mr. Gregson replied that because of uncertainties with the model, following particle backtracks and collecting soil samples has not been very successful. He also noted that there have been a multitude of detections that track back to the Central Impact Area, so this latest detection is just one piece of the puzzle in understanding the Central Impact Area source. Dr. Dahmani asked if the site could be identified for an RRA in terms of the groundwater contamination. Mr. Gregson said that once the IAGWSP is confident that the extent of contamination is defined well enough, it can work with the regulators to decide whether an RRA is warranted, or whether the site would be better served by an FS or some other way forward. Dr. Dahmani commented that the groundwater contamination seems to be defined. He also said that he wants to understand how sites are identified for RRAs since RRAs seem to drive the process for cleaning up contamination at MMR.
Mr. Borci recommended that this be noted as an action item: a request for the IAGWSP to provide information on next steps, and their related timeframes, for the Northwest Corner. He also said that actions have been taken in situations where the full extent of contamination has not been defined; as long as there are actionable levels, an action can be taken. He further noted that the focus at the Northwest Corner has been to provide town water hookups to the three residences in that area with private wells, and thereby eliminate that pathway, which in itself might be called an RRA. Mr. Pinaud agreed that the immediate response was to ensure that there were no human health risks. However, there's no doubt that the area needs to be cleaned up.
Mr. Walsh-Rogalski told Dr. Dahmani that RRAs can be initiated either by EPA or by the IAGWSP. He also noted that the initial EPA Administrative Order set out five or six areas with contamination that was tripping certain actionable levels; all of those were soil actions. As the process has evolved, however, groundwater actions have been incorporated into that process. Mr. Walsh-Rogalski explained that for an RRA, someone identifies a site that needs a fairly rapid "process-light" approach, as opposed to an FS, which raises more issues and is more technically complicated.
J-1 Range Recent Results
Mr. Gregson reminded the group that the likely source of the J-1 Range plume is the J-1 Range interberm area, a location between a 1000-meter berm and a 150-meter berm where disposal and testing activities are believed to have occurred in the past under the direction of defense contractors. He then reported that profile results from MW-346, which was drilled near the center of the plume, showed perchlorate in seven intervals at concentrations from 0.36 ppb to 66 ppb, RDX in two intervals from 0.26 ppb to 0.31 ppb, and HMX in two intervals at less than 1 ppb. Screens will be set to correspond with the perchlorate detections. Also, profile results at MW-349, drilled on the eastern edge of the plume, showed no RDX detections and one perchlorate detection at 1.6 ppb. Three screens will be set in that well to correspond to the perchlorate detection there and other nearby detections.
Mr. Gregson stated that next steps include drilling a downgradient well at location J1P-20, on the J-1 Range, but on the other side of the mound. Results from that well, which will be drilled in mid October, will be significant in that if contamination is detected there it could indicate off-base migration potential.
Mr. Dow referred to MW-346 and asked if the detections at multiple intervals indicate multiple layers in the plume. Mr. Gregson said that he doesn't recall, but he does know that other wells in the J-1 plume have shown distinct levels of contamination, which might indicate multiple source areas. He also mentioned that this location is complicated because it is right near the top of the mound where there's a strong vertical component, which changes over time as the mound shifts. Mr. Dow explained that he's concerned about the very deep component of the plume that can be seen in the cross-section, which doesn't appear to him to be related to the J-1 source area soil that was removed, but to something farther upgradient. He suggested running some back-track models from that deep component to determine if there's another source area that could require an RRA.
Mr. Schlesinger requested that the IAGWSP run a forward particle track from MW-315 to help determine the direction the plume is traveling. Mr. Borci suggested that forward particle tracks also be run from MW-349 and MW-346 in order to take the edges of the plume and bring them forward as well. He also acknowledged that this couldn't be done until screens are set and the necessary data are plugged into the model. Mr. Borci explained that there's inherent error in just one particle track, so it helps to look at multiple tracks. He also said that he thinks that forward particle tracks, in addition to the ZOC, would be useful to include on the J-1 Range figure.
Dr. Dahmani suggested that the purpose behind running forward particle tracks is really to help select future monitoring well locations. He said that the general direction of the plume is known, as is the general flow direction toward the water supply well. The way that the plume appears to "cut on the edge" of the ZOC basically shows the difference between the two models that were used. Dr. Dahmani said that he thinks the model should be used to determine the particle track "and then try to position a monitoring well between the two and the water supply well accordingly." He also said that he believes that the limitations of the model are understood, but in terms of positioning monitoring wells, some confidence can be gained that the plume is being monitored properly.
J-2 Range Northern Plume Results
Mr. Gregson stated that additional data on the J-2 Range Northern plume indicate that the plume is close to being well defined. Recent results from MW-331 (nondetect) and MW-348 helped define the western edge of the plume and provide some understanding of levels within the plume itself. Also, nondetect results from MW-327 and MW-337 helped define the toe of the plume as being somewhere between MW-313, where perchlorate was detected at about 8 ppb, and nondetects farther down Barlow Road. The screens of the Co-op's sentry wells also tested nondetect.
Mr. Gregson then reported that profile sampling results from MW-348, in the center of the plume, showed a maximum perchlorate detection of about 49 ppb, which is consistent with other detections in the core of the plume. He said that the next step is to obtain groundwater data from a handful of remaining wells and then begin working on the RRA plan to address the J-2 Range Northern plume contamination.
Mr. Borci inquired about the process for including the J-2 Range Eastern Boundary plume depictions on the same figure with the J-2 Range Northern plume depiction. Mr. Gregson replied that the process involves obtaining validated data and working with the regulators to reach agreement on the plume shells. He also noted that one of the Eastern Boundary plumes is drawn on only one data point, which makes it difficult to develop a three-dimensional figure. Mr. Borci noted that Mr. Gregson will be presenting groundwater data, which, in theory, is the information needed to produce a figure that includes plume depictions, and he thinks the IAGWSP should be working toward providing that figure by the next IART meeting. He also said that the one data point that Mr. Gregson mentioned is MW-319, which particle tracking indicates could be connected to the perchlorate detection in a neighborhood east of the base, which would mean there are two data points. Mr. Borci said that he thinks that the technical team should discuss what needs to be included on the J-2 Range figure in order to provide the single-most comprehensive piece of information.
Mr. Schlesinger asked if the J-2 Range Northern plume is an RRA site. Mr. Gregson replied that the IAGWSP intends to propose an RRA for that site and, with this year's money, has ordered two containerized treatment units to address the plume. He said that the IAGWSP is working on an RRA plan that it hopes will be ready to present to the IART by the end of this year or early next year. Mr. Schlesinger inquired about any associated soil cleanup. Mr. Gregson replied that the source area for the J-2 Range Northern plume, Disposal Area 2, was cleaned up as part of the J-2 Range RRAs for soil.
Mr. Schlesinger also remarked that Mr. Borci seemed to intimate that there was "some little agreement... about certain wells..." Mr. Borci clarified that he had been referring to the J-2 Range Eastern Boundary figure, which is separate from the J-2 Range Northern plume figure. He explained that he was saying that he thinks that all of the J-2 Range plumes should be depicted on a single figure, now that there are validated groundwater data for the eastern plumes. Mr. Borci assured Mr. Schlesinger that there is "no side deal" about what is and isn't shown to the team. Mr. Schlesinger said that he had misunderstood the comment.
Mr. Borci inquired about the objective of the RRA system for the J-2 Northern plume. Mr. Gregson replied that although the plan is yet to be written, the objective is to address the perchlorate and RDX contamination in the J-2 Range Northern plume by removing mass and helping prevent further downgradient migration. Mr. Borci asked if the purpose is "to knock down the mass" or to prevent the plume from affecting the water supply well. Mr. Gregson said that he'd prefer to wait until he sees the draft RRA plan before answering that question.
J-2 Range Eastern Boundary Results
Mr. Gregson referred to MW-324 and MW-341, which were drilled as part of the investigation of the Eastern Boundary plume that originates somewhere near the firing point of the J-2 Range and extends off to the northeast. He reported that MW-324 had a 1-ppb perchlorate detection, a 2.7-ppb RDX detection, and a 5-ppb HMX detection. He also reported that recent groundwater results for MW-334, 0.43 ppb perchlorate, confirmed profile results for that well.
Mr. Gregson then displayed the figure, based on modeling and available results, that shows the three Eastern Boundary plumes. He pointed out the plume based on the data point at MW-319 and also pointed out the location of the off-base perchlorate detection, in the Peters Pond neighborhood.
Mr. Gregson stated that the IAGWSP is continuing to pursue off-site drilling locations. The final agreement with the Town of Sandwich is being completed, and the IAGWSP is awaiting final approval from the school committee to install the first well on school property, along the backwards particle track from the detection at Peters Pond. Two other well locations can be drilled as soon as approval is given: one is on Department of Environmental Management property and the other is on Town of Sandwich cemetery property. In addition, approval is anticipated for a couple more locations on school property, contingent on results from the first well drilled there. Further drilling locations are to the south and to the east. Mr. Gregson said that it's hoped that by the next IART meeting some preliminary profile data will be available from the first well.
Mr. Schlesinger asked why the team wasn't provided with a copy of the Eastern Boundary map, and noted that he has friends who live in that area. Mr. Gregson replied that once the data are validated and there's agreement on what the plume shells look like, a map will be provided to the team. He explained that the figure shown tonight is just a preliminary snapshot based on modeling and available data. Mr. Schlesinger asked when the team could expect to be provided with that map. Mr. Gregson replied that this will be discussed at Thursday's technical meeting.
J-3 Range Recent Results
Mr. Gregson reported that profile results from MW-347, which was drilled to the north to assess potential contamination from the former barrage rocket target area, were nondetect for perchlorate, but showed RDX at 0.33 ppb in one interval and 4,A-DNT (a TNT breakdown product) at 0.43 ppb in one interval.
Mr. Gregson also reported that to the south, at MW-329, which is closer to Snake Pond on the base boundary, perchlorate was detected at 0.4 ppb and 1.6 ppb. Two additional monitoring well locations are planned: J3P-42, downgradient from a former target area to determine if additional explosives contamination is emanating from that range; and J3P-34, on the shore of Snake Pond, to provide information on the southern extent of both the RDX and perchlorate plumes and how they're reacting in close proximity to the pond - either discharging into the pond, under-flowing it, or both. Another proposed location is J3P-39, off to the west. In addition, a series of wells are planned to help assess the hillside target area at the J-3 Range; J3P-44 will be the first of those locations to be drilled.
Agenda Item #5. Open Discussion
Mr. Murphy noted that the next IART meeting is scheduled for October 26, 2004 at the Bourne Best Western. He also put forth the recommendation to schedule the following meeting on December 7, 2004 in lieu of the meetings initially scheduled for the end of November and December, which would occur close to the holidays. The IART members agreed to the recommended meeting schedule, and Mr. Schlesinger expressed his agreement "provided it doesn't stop the process..."
Agenda Item #6. Adjourn
Mr. Murphy adjourned the meeting at 8:55 p.m.