Impact Area Review Team
Future Agenda Items:
Handouts Distributed at Meeting:
Agenda Item #1. Welcome, Agenda Review, Approval of March22, 2005 IART Minutes
Mr. Murphy convened the meeting at 6:05 p.m. and reviewed the agenda. The Impact Area Review Team (IART) members introduced themselves. Mr. Schlesinger requested that the topic of IART membership recruitment be added to the Open Discussion portion of the agenda. Mr. Murphy agreed to this request and noted that IART member Michael Butler was unable to be at this meeting, but expects to attend the May meeting. Mr. Murphy then asked if there were any additions or corrections to the March 22, 2005 IART meeting minutes. None were offered and the minutes were approved as written.
Agenda Item #2. Late-Breaking News and Responses to Action Items
Ms. Conron questioned whether a recent article in the local newspaper accurately reported Mr. Gonser's statement to the Town of Sandwich selectmen that the military was not at fault regarding perchlorate detections on Peters Pond Drive. Mr. Gonser clarified that he had told the selectmen that from what is currently known, it does not appear that that contamination would be coming from the base because of its depth in the water table. Ms. Conron asked if that area continues to be investigated. Mr. Gonser replied that the investigation is continuing and will include the installation of a well on the property at Peters Pond Drive where the Impact Area Groundwater Study Program (IAGWSP) detected perchlorate. Mr. Murphy recommended postponing further discussion of this issue until Mr. Gregson's presentation on off-post investigations.
Ms. Grillo referred to action item #4 and asked whether the U.S. Geological Survey (USGS) had agreed to look at the interaction of groundwater and Peters Pond. Mr. Gregson confirmed that the USGS has agreed to look at influences on groundwater flow in that area.
Mr. Schlesinger referred to action item #2 and asked if the U.S. Environmental Protection Agency (EPA) had followed up with the Sandwich Water District or the Town of Sandwich about providing town water hookups for the residences on Peters Pond Drive. Ms. Jennings replied that EPA obtained a cost estimate for the water hookups, but did not ask the town to do them.
Agenda Item #3. TOSC Presentation on Granular Activated Carbon and Ion Exchange
Dr. Dahmani introduced Brindiana Thompson, a graduating senior with the civil environmental engineering department at the University of Connecticut, who would be presenting information on ion exchange, granulated activated carbon (GAC), and membrane bio-film reactors (MBfR) technologies for removing perchlorate from groundwater.
Ms. Thompson described ion exchange as a reversible chemical reaction where an ion in solution is exchanged for a similarly charged ion attached to an immobile solid particle. She noted that eventually the ion exchange resin is exhausted and is typically regenerated by a sodium chloride brine system, which creates a waste stream. A biological brine treatment (microbes that eat it) is used to treat the brine waste stream, which reduces perchlorate levels to about 1 part per billion (ppb), or a chemical brine treatment is used, which reduces perchlorate levels to about 2 or 3 ppb.
Ms. Thompson described GAC treatment technology as a process by which ions present in one phase condense and concentrate on the surface of GAC, which is porous. Virgin GAC is exhausted more rapidly than tailored GAC, which is preloaded with cationic polymer or monomer. She showed a graph depicting results of a California study that looked at four different types of monomers to preload the GAC, treating water containing perchlorate at 55 ppb, and noted that the GAC with tailored monomer D was able to treat about 40,000 bed volumes before it was exhausted.
Ms. Thompson described MBfR technology as the diffusion of contaminated water across a micro-porous membrane containing a bio-film of contaminant-degrading microorganisms. She noted that MBfR uses microbes found in the environment, which diffuse across the membrane and eat the perchlorate to degrade it. She also said that there are two types of MBfR: the immobilized MBfR and the hydrogen-fed hollow-fiber MBfR. The immobilized MBfR involves two different reactors: a diffusion reactor and a biological reactor, and results in perchlorate levels of less than 1 ppb. The hydrogen-fed hollow-fiber MBfR is similar to the immobilized MBfR, but also involves a column in which there are fibers that use hydrogen as an electron donor. She noted that the hydrogen-fed hollow-fiber MBfR, treating 55-ppb perchlorate influent, resulted in reduction of perchlorate levels to about 2 ppb, or a 96% removal efficiency.
Mr. Schlesinger inquired about a waste stream associated with MBfR technology. Ms. Thompson replied that the microbes degrade the perchlorate to chloride ions, and the microbes end up being filtered back through different types of filtration systems so that there are no microbes in the effluent. Mr. Schlesinger questioned whether chloride in the waste stream was a concern. Mr. Thompson replied that chloride is routinely used in treatment systems and she believes that the concentrations would be relatively low. Dr. Dahmani added that it really depends on the amount of perchlorate being degraded. He noted that the cleanup program at the Massachusetts Military Reservation (MMR) is dealing with very low concentrations of perchlorate; therefore, the amount of chloride that would be generated is negligible.
Mr. Mullennix asked if it's correct that all of the technologies work. Ms. Thompson replied that a full-scale MBfR pilot study has not yet been done, but the other technologies have been proven. Mr. Mullennix noted that Ms. Thompson mentioned effluent levels of 1 to 2 ppb and he questioned whether there had been nondetects in the effluent. Ms. Thompson said that she doesn't think perchlorate could be measured lower than 1 ppb, and was not involved in the studies; however, she would think that if 1 ppb was measured, there were also nondetects.
Mr. Dow inquired about any difference in efficiency and cost effectiveness among the systems, especially when treating low concentrations in a large volume of water. Dr. Dahmani replied that a cost analysis was not done. He also noted, however, that the MBfR, although not yet tested on a large-scale level, does not have to be regenerated, which is positive. He also noted that when dealing with low concentrations and a large amount of water, "the economics are not going to be good anyway, whether using carbon or a bio-filtration system."
Mr. Dow then questioned whether iron and manganese levels in the water would affect the efficiency of ion exchange or MBfR operations, and possibly cause problems. Dr. Dahmani replied that he wouldn't expect that to be a problem, given that he hasn't seen high iron content in the groundwater that's being addressed under the IAGWSP. Mr. Dow noted that the infiltration trench for the Installation Restoration Program's (IRP's) Ashumet Valley plume treatment system had become clogged, which he presumes was from organisms that utilize iron. Ms. Thompson noted that the MBfR involves a very specific type of bio-film to degrade perchlorate, and she thinks that iron would just pass right though the system, without creating a problem.
Mr. Panni asked if the studies that Ms. Thompson discussed in her presentation are available for review. Ms. Thompson replied that the studies, which were conducted by the American Waterworks Association, are available on-line, and that she could provide the specific links.
Mr. Schlesinger asked Mr. Gregson if the IAGWSP is familiar with a tailored GAC technology being developed by Pennsylvania State University (Penn State) and being used in Redlands, California. He noted that he saw an article about this in today's newspaper. Mr. Gregson replied that in 2002 the IAGWSP began working with Dr. Cannon at Penn State on the tailored GAC technology, and field tests of carbon and tailored carbons were conducted last year when the Demolition Area 1 (Demo 1) Pew Road system was being set up. Mr. Gregson stated that the tailored GAC technology does hold promise for treating perchlorate, but because it is not approved by the National Science Foundation (NSF), effluent couldn't be discharged directly back to the aquifer without first undergoing some type of intermediate step, such as regular GAC. Mr. Schlesinger asked if the NSF concern is a regulatory issue. Mr. Gregson replied that he believes it is a regulatory issue.
Dr. Dahmani noted that Ms. Thompson has produced a report about the treatment technologies, which she could e-mail to IART members.
Mr. Mullennix noted that he concludes from Ms. Thompson's presentation that ion exchange and GAC are well known and well developed technologies that treat perchlorate down to very low levels. Ms. Thompson confirmed that this is true, and noted that the systems that the IAGWSP has in place use a combination of ion exchange and GAC.
Agenda Item #4. Off-Post Investigations - Forestdale
Mr. Gregson said that he would be discussing the eastern part of the J-2 Range investigation, and noted that the range was formerly used for training and then defense contractor testing. He reminded the group that a number of wells were drilled off-base to determine whether any of the known on-base contamination is heading towards the Peters Pond Drive neighborhood. He said that perchlorate was detected at about 2 ppb in one private well on Peters Pond Drive. Also, EPA, using a new method, detected perchlorate in other private wells on Peters Pond Drive at levels from about 0.1 to 0.12 ppb.
Mr. Gregson stated that the IAGWSP has been working with the regulators and USGS to do some additional investigation in an effort to determine whether the perchlorate at Peters Pond Drive is connected to the base. The IAGWSP has proposed a drive-point investigation, which involves using a tractor-mounted drill rig to drive a 1-3/8 inch pipe into the ground to collect water samples. The advantage to this method is that a great deal of data can be collected quickly for a relatively low cost, while the disadvantage is that there can be difficulty working in rocky terrain and at extreme depths. Mr. Gregson noted that the maximum depth that a drive-point can achieve is about 200 to 250 feet.
Mr. Gregson stated that the IAGWSP plans to install a drive-point just upgradient of a private well on Peters Pond Drive in order to get some information on the distribution of perchlorate throughout the water column. In addition, there are plans to install a series of drive-points along the base boundary, starting between monitoring well 310 (MW-310) and MW-319, down to just downgradient of the J-1 Range, where soil sampling indicates there might be some contamination. Mr. Gregson said that the IAGWSP has spoken with the owners of the property about this work, is preparing the paperwork, has contracted with a geo-probe company to do the investigation, and expects the work to begin in the middle of May. He noted that the IART would be updated as results become available.
Ms. Conron asked if the private property would be damaged by the drive-point installation. Mr. Gregson replied that after the rig is gone, there should be no evidence that it had been there, as the process does not generate any waste soils. He also said that later the steel pipe would be cut off below grade and filled with cement. He further noted that if data from the drive-point shows detections, permanent sampling points could be installed.
Mr. Schlesinger asked if samples from the four existing monitoring wells upgradient of Peters Pond Drive had been analyzed using EPA's low-detection methodology. Mr. Gregson replied that samples from those wells, which tested nondetect at a 0.35-ppb detection limit, have not been analyzed with the EPA method. He explained that the IAGWSP is waiting to have a better idea of what contamination might be coming off the base. If it's determined that there's a plume in that area and that EPA's method would provide information to help define the plume, that method would be used. Ms. Jennings further noted that EPA's method is going to be used to analyze samples from the drive-points along the base boundary. She said that it might not be necessary to use that method for the wells Mr. Schlesinger mentioned, depending on results from those drive-points.
Dr. Dahmani questioned why a truck-mounted rig, which could drive the pipes deeper, wasn't going to be used. Mr. Gregson replied that the contracted company has used its equipment at MMR in the past and has achieved depth of greater than 200 feet. Dr. Dahmani asked if it's right that no problems are expected. Mr. Gregson replied that that is right, unless there turns out to be many rocks, which require the use of an auger rig or a sonic rig. Dr. Dahmani said that he believes that geo-probes are unable to go through some other types of formations, beside rocks. Mr. Gregson noted that the area in question is not in the moraine and no clay lenses have been encountered there so far. Although problems are not expected, it will depend on how rocky the soils are. Dr. Dahmani then recommended the installation of piezometers in the area near Peters Pond in order to determine the vertical flow gradient there. Mr. Gregson said that he thinks that is a good idea.
Mr. Walsh-Rogalski inquired about the pumping rate of the P.A. Landers irrigation well. Mr. Gregson noted that the well is used for dust control during activities at the gravel pit. Ms. Richardson added that the person from P.A. Landers with whom she spoke about one year ago confirmed that the irrigation well was used for dust control purposes, but had been unable to provide a pumping rate at that time. Mr. Walsh-Rogalski suggested that a high pumping rate would be relevant to the hydrology in the area. Mr. Gregson noted that "it would have to have a pretty high pumping rate" to influence groundwater flow in the area, and added that he would have to look into this question in more detail to determine whether or not that would account for what's being seen in the private well on Peters Pond Drive.
Mr. Walsh-Rogalski remarked that it is early to conclude that the perchlorate contamination at Peters Pond Drive isn't coming from the base, given that the pumping rate at the P.A. Landers irrigation well is unknown. Mr. Gregson mentioned having to prove a negative, and noted that so far there have been no detections of perchlorate in any of the monitoring wells drilled between the Peters Pond area and the base. Also, the private well has shallow screens, which would indicate a nearby source of contaminant. He stated that the IAGWSP has found no positive evidence to connect the perchlorate detections at Peters Pond Drive with J-2 Range contamination, and is now focused on installing wells along the base boundary and a well upgradient of the private well to get a better understanding of the distribution of contaminant with depth. Mr. Walsh-Rogalski noted that the IAGWSP doesn't have evidence either to prove or disprove a connection between the base and the contamination at Peters Pond Drive.
Ms. Conron inquired about the significance of the P.A. Landers irrigation well. Mr. Gregson explained that on the P.A. Landers property, which is located at the intersection of Route 130 and Quaker Meeting House Road, there is an irrigation well from which water is extracted for dust control measures, and depending on the rate at which that well is pumped, it's possible that it might pull groundwater flow toward it. Ms. Conron asked if the well had been tested. Mr. Gregson confirmed that it had and tested nondetect. Ms. Conron also asked if the IAGWSP has some sense of whether the private property is rocky. Mr. Gregson replied that it is difficult to predict what's underneath the ground, but that area is part of the Mashpee pitted plain, which is outwash material that contains fewer rocks than the moraine.
Mr. Panni mentioned that according to the Massachusetts Department of Environmental Protection (DEP) Water Shed department, there is no permit for withdrawal from the P.A. Landers well, which indicates that it probably pumps fewer than 100,000 gallons per day - assuming that P.A. Landers went through the process to determine if a permit was required.
Mr. Schlesinger inquired about the number of private wells on Peters Pond Drive and the pumping rate of a private well. Mr. Gregson replied that there are seven private wells and he thinks the pumping rate is 500 gallons per day. Mr. Schlesinger questioned whether the combined rate of those wells might affect groundwater flow in that area. Mr. Gregson said that he thinks the pumping rate is low enough that it would not affect groundwater flow, but added that the IAGWSP will be looking at that with the USGS as part of its upcoming work.
Mr. Schlesinger questioned why the IAGWSP would spend the money for a drive-point well near the private well, while saying that there's no connection between base contamination and the contamination on Peters Pond Drive. Mr. Gregson clarified that the IAGWSP is conducting the investigation in order to determine whether the perchlorate contamination in the well is connected to the base. He noted that the program is authorized to conduct the investigation, but in order to take an action to provide water hookups, the military must be at fault for contamination in a private well, and the contaminant has to have a regulatory standard that's been exceeded.
Mr. Schlesinger suggested that it seems "a little weird" to be spending large amounts of money on the investigation when it would cost a fraction of that amount to provide town water hookups to the residences on Peters Pond Drive. He also noted that citizens need to make decisions based on economic reasons, not "because of fault." Mr. Schlesinger then stated that rather than spend $45,000 to investigate the detection in the private well, the military ought to be spending the first $45,000 to provide town water hookups.
Mr. Gonser replied that he is in agreement in that the IAGWSP doesn't want to spend a lot of money looking everywhere for these very low levels of perchlorate, and he thinks it is at the point where it's gone as far it needs to. He also explained that he doesn't have the discretion to spend money the way he thinks it would be good to spend it. It is not a matter of whether it's less expensive to provide hookups than conduct the investigation; it's a matter of not having the authority to pay for town water hookups in the present situation.
Ms. Conron remarked that she doesn't think Mr. Gonser is that powerless. She also said that no one with whom she has discussed the Peters Pond Drive situation has recommended continuing the research; rather, they say that the Peters Pond Drive residences should just be hooked up to town water. Ms. Conron also commented that with the "unbelievable" amount of money being spent on MMR, it needs to be spent wisely and in the best interest of the citizens who live here. She further noted that she thinks that the military eventually will determine that it is responsible for the Peters Pond Drive contamination, and questioned whether there's been any similar situation that ended up not being the military's fault.
Mr. Gonser explained that in our system of government, "you don't have to prove you didn't do it; somebody should be proving that you did do it." He suggested that it's the job of the regulators to prove who caused the problem, and to date there is no evidence that the military caused it. Until that evidence exists, he is powerless to move forward, other than taking the extra effort of the additional investigation to ensure that nothing was missed.
Mr. Minior of the Air Force's cleanup program, the IRP, noted that the P.A. Landers well, being used for dust control, is probably used intermittently, unlike an irrigation well that might be used for a corn field. He also said that he thinks that Mr. Goydas of Jacobs Engineering, who has done a lot of hydrology work for the IRP and is also doing work for the IAGWSP, would say that an intermittent-use well would not have much effect on groundwater flow.
Mr. Minior also noted that a citizen member of the Plume Cleanup Team (PCT), which is the IRP's equivalent to the IART, recently sent out an e-mail regarding a town in New Jersey that he formerly managed, where perchlorate was recently detected in two of the 19 supply wells, at 5 and 23 ppb. The PCT member had noted that the perchlorate was traced to specialty fertilizers used in commercial greenhouses in the area, and wondered whether any such operation might have existed in the past in the vicinity of Peters Pond. Mr. Minior also mentioned that the IRP was in part established in response to base contamination detected in private wells in 1978, and since that time the IRP has provided town water hookups to more than one thousand households.
Mr. Minior further noted that he finds it interesting to look at the quality of water from private wells versus the quality of water provided by various suppliers in the area. He noted, for example, that the Sandwich Water District's 2004 annual report notes the existence of chlorinated solvents that leached into its water supply from distribution pipes (8,000 feet of which have been lined in order to remediate this problem). It's stated in the report that the highest detection of PCE (which has a maximum contaminant level [MCL] of 5 ppb) was 4 ppb, and that the distribution system has PCE detections at an annual average of 1.5 ppb. He noted that that level is about 75% below the MCL, but also noted that some of the perchlorate detections in the private wells on Peters Pond Drive were 90% below the guidance level for sensitive populations. Mr. Minior said that he thinks it is important for individuals to consider all the factors that relate to water supply in order to make informed decisions for themselves and their families.
Ms. Dolan asked whether the results at MW-367, as reported on the "J-2 Range RDX in Groundwater" figure from the Remediation & Investigation Update handout, were validated well screen sample results or validated profile results. Mr. Gregson said that he would have to check on the status of those results. Ms. Dolan requested that Mr. Gregson e-mail that information to the team.
Mr. Dow asked if Denis LeBlanc of the USGS had examined the groundwater in the Peters Pond neighborhood in terms of age dating. Mr. Gregson replied that Mr. LeBlanc has done a lot of work with age dating water, but doesn't think he's done that type of work in the Peters Pond area. He also said that he would ask this question of Mr. LeBlanc.
Mr. Pinaud questioned whether there is a commitment on the part of the IAGWSP to do the drive-point work discussed this evening. Mr. Gregson replied "absolutely," and noted that the contract is in place.
Mr. Schlesinger commented that the information about the Sandwich Water District's supply is "totally irrelevant" because the team is talking about perchlorate coming from the base, not about PCE or lead, which are "found in every town water supply on Cape Cod." He also noted that Mr. Gonser had mentioned being able to provide town water hookups in response to RDX contamination, or in response to perchlorate if a standard existed. He then asked Mr. Gonser to clarify the conditions under which the IAGWSP would be able to provide town water hookups for the residences on Peters Pond Drive.
Mr. Gonser stated that the Department of Defense (DoD) policy at this time does not allow him to take action to treat perchlorate, which is why the RDX issue was raised. Currently the DoD policy allows sampling for perchlorate, but not treatment, although that doesn't mean that the IAGWSP couldn't ask for an exception to the policy. Mr. Schlesinger asked if it's correct that in fact the IAGWSP could spend the money to connect the Peters Pond Drive residences to town water in the event that the perchlorate contamination there is found to be connected to the base. Mr. Gonser replied that while he believes that DoD is formulating a new policy, the current policy only authorizes installations to sample for perchlorate, and does not allow a response action for perchlorate.
Mr. Schlesinger remarked that it was once said that if the state had a cleanup level for perchlorate, the IAGWSP would clean up to that level. He then questioned whether that means the same thing as providing town water hookups. He also noted that what he is trying to determine is whether or not the military, or DEP or EPA, is going to be able to do anything to help the Peters Pond Drive residents - because if not, their time is being wasted. He said that he thinks it's important to be able to reassure the residents that going along with the investigation process will in fact be useful; otherwise, he thinks they should look at other avenues, such as pursuing lawsuits.
Mr. Gonser said that the ongoing investigation is valuable in that it will be helpful in understanding the source of the perchlorate contamination - whether or not that source is DoD related. He also noted that the existing DoD policy is in the process of being changed, that with the right information from the investigation the IAGWSP could ask for an exception to the existing policy, and that procedures are under way to establish regulatory standards for perchlorate. Mr. Gonser stated that the ongoing investigation is not a waste of time because of its value in identifying the source and gathering needed information to make the case to take an action.
Mr. Schlesinger noted that economic issues are also a concern, in that the existence of perchlorate in private wells on Peters Pond Drive affects the property value of those homes. He said that in this sense, the investigation process is holding up the residents' ability to sell their homes. Mr. Schlesinger said that he thinks the residents need a straight yes or no answer as to whether their properties can be hooked up to town water. He also questioned why the IRP was able to provide numerous town water hookups while the IAGWSP is not able to do so.
Mr. Gonser explained that the IRP has a defined procedure for providing town water hookups, which involves a requirement based on exceedances of an MCL. In the case at hand, there are no exceedances of an MCL; therefore the IRP would have to handle the situation similarly. He also said that he doesn't think that that the Peters Pond Drive homes where perchlorate was detected at levels around 0.1 ppb should be affected in terms of selling, given that everyone would agree that that kind of level does not pose any kind of health risk.
Mr. Schlesinger questioned how many people at the table would be willing to drink the water from Peters Pond Drive. He also noted that there is a youngster living on that street, and for that reason alone he believes that someone in the federal or state government ought to find a way to get past the bureaucracy and provide town water hookups for the residences on Peters Pond Drive. Mr. Gonser said that he believes that the state offered to provide a filtration system to at least one of the individuals on the street. He noted that like the state, which has offered positive action within its authority, the IAGWSP is doing everything it can within the investigation and within its authority, as it is understood that this is a significant problem for the people involved.
Mr. Cowick, a homeowner on Peters Pond Drive, asked Mr. Gonser if the federal government would pay for town water hookups in the event that it were discovered tomorrow that the perchlorate problem is coming from the base, a state standard had been established, and the levels at Peters Pond Drive were above that standard. Mr. Gonser replied that in that situation he would approach the leadership in Washington and request authority to take action. He said that while there isn't currently a policy that would allow him to do that, the e-mails that he's read indicate that the leadership would likely be favorable toward granting him that authority. He added that he cannot commit to what the Army would do at this time, because the question hasn't yet been addressed.
Mr. Cowick asked if it's correct that with no federal standard for perchlorate at this time, such a request would lead to the convening of a committee to determine what to do and what precedent would be set. Mr. Gonser agreed that there is no clear policy at this point for responding to perchlorate. However, other installations have similar issues, and the policy is evolving, with the Departments of Army, Air Force, and Navy getting together to review results of the National Academy of Sciences (NAS) study and look at revising the DoD policy. Mr. Gonser added that he believes that ultimately DoD will respond to perchlorate, even without an EPA standard, but at what level, he doesn't know.
Mr. Cowick asked if it's correct that other communities in the country are dealing with perchlorate contamination caused by the military, at levels exceeding state standards, with no help from the federal government. Mr. Gonser replied that one of the problems is that there are no promulgated state standards, although there are goals, proposals, and the like. He noted that perchlorate issues exist in California and at Aberdeen Proving Ground in Maryland, where perchlorate was detected in a public water supply well. He said that as far as he knows, there has been no DoD response to hook up those affected homes to town water.
Mr. Cowick said that when he lived in New Mexico, his wife was a reporter for a local paper and covered a story about a major uranium tailings (residue) spill in the Puerco River. He noted that although it was well known that the tailings were in the lake where the uranium mines were, that the dam had broken, and that the tailings had gone into the Puerco River and contaminated the land along the river - it was 10 years before any cleanup was started. Mr. Cowick said that the residents of Peters Pond Drive are concerned about similar delays in addressing the perchlorate contamination. He then asked if it's correct that Mr. Gonser, although hopeful, is saying that there are really no guarantees - even if the contamination is proven to be coming from the base, and even if a state standard were set and the levels exceeded that standard.
Mr. Gonser reiterated that he cannot commit to the DoD policy at this time because the question has not been asked. He also noted that several years ago the IAGWSP was switched over from the National Guard to the Army Environmental Center (AEC). He works for the AEC, which works for the top person in the Army at the Pentagon, and on May 5, 2005, he'll be briefing the top decision-makers at the Pentagon. Mr. Gonser explained that the IAGWSP has direct access to the leadership of the Pentagon, whom he knows personally, having worked with them for the past 15 years. He said that he thinks that there's a good chance that decisions will be made quickly once the case has been presented to the right people. He also noted that the investigation must first be done in order to determine the source of the perchlorate contamination. Mr. Gonser said that he is keeping this issue on the front burner, talking to the leadership about the struggles associated with it at least once a week, and doesn't expect it to "drag on forever" but anticipates "reasonably quick decisions."
Mr. Cowick asked if it would be safe to say that Mr. Gonser is an advocate for the Peters Pond Drive residents. Mr. Gonser replied that he works for and is loyal to the Department of Army, but is also the person who for five years headed up the Upper Cape Water Cooperative (the Co-op) regional water supply system project, through which he established relationships with all the local water superintendents. He also noted that he is a resident of Sandwich and gets water from the spring in the center of town because salt from the roads drains into his well. Mr. Gonser added, "I would say yes, I am an advocate for your position."
Mr. McDonagh, legal counsel with AEC, said that a problem with discussing policies is identifying which policy - whether draft, final, and so forth. He confirmed that, as Mr. Gonser mentioned, DoD policies on perchlorate are in flux. He also said that he and Mr. Gonser would be willing to consider whatever language could be extracted from those policies that might provide the IAGWSP with more flexibility. Mr. McDonagh further noted that policies are not law, which is why he thinks the question about being an advocate was a very good one. Policies can be changed; and while DoD doesn't like to do it, occasionally it will make an exception to policy. He stated that while Mr. Gonser cannot say what the Army will decide, he can commit to asking for that exception - under appropriate circumstances on appropriate issues.
Mr. McDonagh also said that the IAGWSP can't speak for the Army in terms of what it will do if the proposed perchlorate standard is passed. He noted that California has a 6-ppb standard, that Canada has a 4- or 6-ppb standard, and that many organizations, including EPA and the Army, have a variety of different guidances or thought pieces regarding perchlorate. He also said that it is no secret that the Army, and DoD in general, are somewhat concerned about DEP's proposed 1-ppb limit, and questions have been raised about it. He added that he thinks it is unfair to expect the IAGWSP to be able to speak to what the Army's eventual position will be if DEP does adopt a 1-ppb limit.
Ms. Conron remarked that she is glad to hear Mr. Gonser speak because he is the head of the IAGWSP, and she wouldn't hold him "to any legal thing." She also said, however, that she heard some mixed messages in that Mr. Gonser said that he wasn't too powerful, but then said that he personally knows the leadership and is a sort of advocate for the residents. She further noted that the newspaper article about the Sandwich selectmen left her with the impression that "no way, no how" would the Army accept fault for the perchlorate contamination at Peters Pond Drive. Ms. Conron commented that she thinks it is important for citizens to get satisfaction from their government, from which they ask little. She also asked if the current DoD policy on perchlorate applies only to contamination outside of the base.
Mr. Gonser clarified that the policy applies to all perchlorate contamination. He also explained that the policy allows for testing for perchlorate as a way to prepare for responding to standards that are expected to be established in the future, but does not go beyond testing at this point as there is not yet a driver for cleanup. Mr. Conron suggested that perhaps this is why the process seems to be dragging on. Mr. Gonser replied that the perchlorate investigation is just different, especially when dealing with such low levels, which make it difficult to identify a source. He also mentioned that perchlorate contamination at the Demo 1 and J-2 Range North plumes is being addressed, but this is not seen as a violation of the policy because RDX contamination also exists there and is being addressed at the same time.
Dr. Dahmani remarked that he thinks that DoD is good at responding to imminent danger. He also said that EPA and DEP are responsible for protecting human health and the environment and should provide perchlorate standards in the very near future so that the Army can respond. He said that this would make it easier for the decision makers to say yes or no to providing town water hookups for Peters Pond Drive. Dr. Dahmani suggested that perhaps the team could be provided with an idea of the process that the regulators have to go through in order to establish a standard.
Mr. Schlesinger questioned whether the Massachusetts Department of Public Health (MDPH) could take an action to provide town water hookups if the state establishes a perchlorate standard. He asked if an MDPH representative was at the meeting, and Mr. Murphy confirmed that there was not. Mr. Schlesinger requested that his question be noted as an action item.
Mr. Schlesinger also asked if the IAGWSP would have the authority to provide hookups to clean water in the event that wells supplying drinking water to military personnel were affected by perchlorate. Mr. Gonser replied that the current policy would not give him that authority, and he doesn't think that there is any regulatory driver at this time that would require the base water supplier to take an action. He said that the situation would follow whatever the DEP procedures are for water suppliers.
Mr. Schlesinger then said that he'd like an answer to the question of why the IRP can use federal dollars to provide town water hookups but the IAGWSP cannot. He also asked Mr. Gonser to invite to a future IART meeting the person in Washington who has the authority to change the policy on perchlorate. Mr. Gonser replied that what he can do is provide the team with an update on the status of DoD policy-making at the next IART meeting. He also noted that his understanding is that DoD is coordinating with EPA Headquarters on the policy. He said that he thinks he could probably provide more information and an expected date on the revised policy at the May IART meeting.
Mr. Schlesinger asked if there's any way under the Safe Drinking Water Act (SDWA) that the IAGWSP or some agency could have the same ability that the IRP has to provide town water hookups. Mr. Minior explained that the IRP deals with regulated compounds that have established drinking water standards. He said that the IRP's hands would be tied if it came up against a situation where perchlorate, an unregulated compound, was detected in a private well.
Mr. Cowick noted that his state representative attended a meeting with the residents of Peters Pond Drive and left him with the impression that DEP is expected to make its decision on a perchlorate standard in about one month. Mr. Pinaud stated that DEP has sent the regulatory package to the Executive Office of Environmental Affairs (EOEA), after which it will go the Office of Administration & Finance, and then go out for public comment. He noted that he doesn't know the timeline, but it is moving through the process. Mr. Gonser mentioned that his boss, Mr. Fatz, and Mr. Pinaud's boss, Commissioner Golledge, had a meeting at the Pentagon last week.
Mr. Mullennix remarked that although Cape Cod has some of the best water in the country, and perhaps in the world, he thinks it is important to put the idea of connecting to "clean water" in perspective. He referred to Mr. Minior's comments about the Sandwich Water District's water, and said that the Bourne Water District's water contains naturally occurring radium that's considered to be at fairly high levels, as well as naturally occurring chloroform, which is a known cancer-causing chemical - nevertheless, it is very high quality water. He also noted that the Town of Falmouth chlorinates its water and therefore it contains 60 to 80 ppb of trihalomethanes (chlorinated organics), which are problem materials for drinking water supplies. However, the chlorine is a tradeoff so that bacteria that can cause illness don't grow in the water. Mr. Mullennix stated that "clean water" is a relative term, the levels of perchlorate at Peters Pond Drive are very low, and he thinks that the residents should know that getting hooked up to town water would be a tradeoff.
Mr. Mullennix also commented that rather than innocent until proven guilty, in this case he thinks it is clear that the Army is being perceived as guilty until proven innocent, but is stepping up to try to determine what's happening in areas where contamination is found. He also mentioned the investigation at the Northwest Corner, where the Army's consultants determined that the preponderance of perchlorate contamination there had been caused by nearby fireworks displays over the years. He noted that the report containing that information was deemed unacceptable and the Army was asked to reassess the situation, but he hasn't heard much about this for more than a year. Mr. Mullennix then mentioned the MDPH study regarding incidence of hypothyroidism in newborns in the town of Bourne, the results of which have not yet been brought forward, two years after the fact. He said that he hopes that the results of the DEP study on fireworks and perchlorate contamination, which was conducted at UMass Dartmouth last fall, will be made available more quickly. Mr. Mullennix added that he'd thought that the results of the fireworks study were going to be issued in December.
Mr. Pinaud noted that the report is still in production, and as he told the team previously, he will be happy to distribute it when it's complete. Mr. Mullennix questioned why it is taking so long. Mr. Pinaud said that he would check on the status of the report for the team.
Mr. Schlesinger said that he still wants reassurance that an effort will be made to determine how the IAGWSP can obtain the same authority that the IRP has in terms of providing town water hookups. Mr. Murphy noted that the IRP has a written policy, which he is certain could be provided. Mr. Schlesinger explained that his question is whether the IRP, operating under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), has some "special ability" that the IAGWSP lacks, operating under the SDWA. He also noted that he heard tonight that the IAGWSP needs a perchlorate standard in order to respond, and that even if a standard is established, the IAGWSP wouldn't have the ability to provide town water hookups. Mr. Schlesinger asked which is correct. He also asked, if the IAGWSP has the same authority as the IRP, why the IRP can provide hookups but the IAGWSP cannot.
Mr. Walsh-Rogalski explained that the IRP is dealing with contaminants for which MCLs have been promulgated. However, there is an ongoing national debate about a safe level for perchlorate. He noted that the NAS came out with a study, EPA adopted the number from that study "for limited purposes," and the state is undergoing its own promulgation process. Mr. Walsh-Rogalski stated that no one has a final number for perchlorate, unlike benzene, TCE, and PCE, for example, which have long-promulgated and accepted MCLs.
Mr. Schlesinger asserted that the real issue is that the IAGWSP couldn't provide hookups even with a state standard for perchlorate. Mr. Walsh-Rogalski explained that there's enough of a debate about a perchlorate level going on nationally that DoD, which represents everyone nationally, isn't going to say that the Massachusetts standard is necessarily right. He noted that he thinks Mr. Gonser is saying that that will be a big decision to make - whether DoD accepts the Massachusetts standard for the purposes of working in Massachusetts.
Ms. Porfidio, a homeowner on Peters Pond Drive, who identified herself as the mother of an 18-month-old boy, said that everything that she has read indicates that perchlorate is a harmful substance to young children. She said that her well was tested, perchlorate was detected, and "nobody wants to do anything about it." She expressed concern that her son has to bathe in that water, and said that she doubts that she could sell her house now if she wanted to. She said that she feels stuck and without a solution, is concerned for her son's health, and tries to give him only bottled water, which is expensive.
Mr. Olsen identified himself as the EPA person in charge of all the DoD sites in New England. He said that he has been listening to the residents of Peters Pond Drive and thinks that EPA needs to take some responsibility for what is happening. He noted that if EPA, or DEP, had a perchlorate standard at this time, an action would be taken to ensure that whoever is responsible for the perchlorate at Peters Pond Drive addresses the situation. He said that while EPA and the Army have a difference of opinion about who is responsible, they are working together to determine who in fact is responsible, what the source is, and how the contamination can be stopped.
Mr. Olsen said that from EPA's perspective, he can pledge that it is pushing those who are working to translate the 24.5-ppb number from the NAS study into an actual cleanup standard. He added that he wishes he could assure the residents that 2 ppb is okay, or that the levels in the wells will be lower a month from now, but he can only assure them that EPA is going to push as hard as it can to get out the guidance that's needed and tell the public, from EPA's perspective, or DEP's perspective, whether or not the levels seen at Peters Pond Drive are a problem. Mr. Olsen stated that this is what the residents deserve, but are not getting, and that is not the Army's responsibility. Rather, the Army's responsibility is to do the cleanup, if it has caused the problem, and EPA will make sure that it does, but first must get a standard in place. Also, if DoD, or the town, or whoever turns out to be responsible, isn't getting the job done, it would be EPA's responsibility to step in and take an action in the interim.
Mr. Olsen remarked that he doesn't want the Peters Pond residents to think that EPA is going to "leave them hanging." He said that EPA owes them a standard, and although neither he nor Mr. Pinaud is in a position to commit to exactly when those regulatory standards will be put in place, people are undoubtedly trying to clarify the perchlorate issue, and it's happening all around the country. He further stated that because of the differences of opinion, he probably wouldn't have an 18-month-old child drinking water with 2 ppb of perchlorate, but doesn't think it would be a problem at 0.1 ppb, because there is not a difference of opinion about that level. Nevertheless, it isn't known whether that level will be the same next month, which is why the investigation is important. Mr. Olsen made a point of noting that the investigation will need to continue, regardless of whether town water hookups are provided, so it's not as though the money for the investigation can simply be traded for hookups. He stated again that EPA pledges to do everything it can.
Mr. Olsen also mentioned that he was raised in Woburn, Massachusetts, where children got leukemia from their drinking water, so he certainly understands that there are real environmental and health issue related to the water that people drink. He noted that the perchlorate levels at Peters Pond Drive are very low compared to levels seen at other sites, which make those situations more clear cut. Mr. Olsen reiterated that he understands the residents' position and that EPA will do everything it can to clarify a perchlorate standard.
Mr. Michienzie, another homeowner on Peters Pond Drive, stated that when he had his water checked 11 years ago it was clean, and despite the low levels, there is now something in his water that wasn't there before, and he is concerned for his children who have been drinking it. He also noted that he spent many years in the military, as has every male member of his family, including his son who recently came back from Iraq. He said that his family is pro-military, but he strongly believes that the military is at fault with respect to the perchlorate contamination on his street, and that something must be done about it.
Mr. Michienzie also noted that one of the Peters Pond Drive residents put his house up for sale on April 1 and everyone who has called the real estate agency about it has asked if the house is on the street where perchlorate was detected, and no one has come to look at that house. Mr. Michienzie said that he has put every dime he has into his house, and was hoping to have something to leave his children, but at this point he doesn't think he could give his house away. He said that he hopes something will be done about it.
Mr. Gregson concluded his presentation by reporting that RDX was detected at 18 ppb and perchlorate was detected at 69 ppb in MW-368. He said that this indicates either that there are multiple sources at the J-2 Range, as suspected, or that because of shifts in groundwater flow, there is "more of a splaying of the plumes that are kind of coming together in that area." He noted that these are relatively high levels of explosives and perchlorate and he pointed out the area in the J-2 Range to which they track back.
Mr. Schlesinger inquired about looking into the possibility of using LRWS5-1 as an additional downgradient monitoring well for the J-2 Range perchlorate plume. Mr. Gregson agreed to do so.
Mrs. Moretti, a homeowner on Peters Pond Drive, remarked that she and her husband were deeply saddened to hear that Richard Hugus had resigned from the IART. She said that they and all the residents on Peters Pond Drive cannot thank the IART members enough for all their hard work and dedication. She also said that it has been frustrating to deal with this problem over the past year, and she can see why the citizen IART members might question whether their presence makes a difference. She also said, however, that their presence really does make a difference, knowing that someone is on their side and is willing to fight for them.
Agenda Item #5. Draft J-2 Range North Groundwater RRA Plan
Mr. Gregson showed a map of the J-2 Range North plume, which he said has been a major concern because it is heading toward the Co-op's water supply well #2. He noted that the J-2 Range North Groundwater Rapid Response Action (RRA) plan will be sent out to the team later this week, and that a 15-day informal public comment period on the plan will run from May 11 to May 25, 2005. He mentioned that copies of the plan will also be available in the local libraries on May 6 and that team members can provide comments by mail, phone, or e-mail, or at the May 24, 2005 IART meeting.
Mr. Gregson reminded the group that the J-2 Range was used historically for training as a musketry and rifle range, and then for defense contractor testing of propellants, fuses, smokes, and the like. He said that investigations conducted to date have identified many magnetic anomalies and burial pits at the J-2 Range, with the source of the J-2 Range North plume identified as Disposal Area 2, which was the subject of an RRA soil removal. He also mentioned that based on some air magnetometry data and ground-based geophysical data, the IAGWSP is conducting additional excavations of anomalies and finding additional burial pits.
Mr. Gregson stated that the J-2 Range North plume is located within the zone of contribution (ZOC) for water supply well #2. He showed the map depicting RDX contamination and pointed out the plume contours and the Disposal Area 2 source area. He showed the map depicting perchlorate contamination and noted that it extends farther than the RDX, to a location between Gibbs Road and Jefferson Road. He also pointed out the perchlorate plume contours: nondetect, 0.35 ppb, 1 ppb, 4 ppb, 18 ppb, and greater than or equal to 100 ppb. Mr. Gregson said that the perchlorate levels are relatively high.
Mr. Gregson stated that the goals of the J-2 Range North Groundwater RRA are to control plume migration, expedite aquifer restoration, and begin contaminant mass removal. He noted that the proposed RRA system for groundwater is expected to remove more than 90% of the contaminants and remediate RDX in about seven years. He also said that the system is believed to be protective of water supply well #2, and mentioned that there's an extensive monitoring well network upgradient of that well, which has been testing clean. Mr. Gregson further noted that the RRA is an interim action and that the entire area is going to go through a complete feasibility study, remedial design, and decision document for a comprehensive remedy for all the J-2 plumes and the J-1 plume. He said that it's believed that the J-2 Range North RRA system will be part of that overall remedy and will jumpstart that process.
Mr. Gregson reported that the proposed RRA plan involves three extraction wells, operating at 75 gallons per minute (gpm), 175 gpm, and 125 gpm, from which the extracted groundwater will be piped to modular treatment units located at the intersection of Wood Road and Barlow Road. One extraction well will be located south of the intersection of Wood Road and Barlow Road, another will be about half way between Wood Road and Jefferson Road, and the other will be north of Jefferson Road. The treated water will be returned to the aquifer via infiltration trenches located along the sides of the plume. The treatment system will be identical to the Demo 1 Frank Perkins Road system, which uses GAC, ion exchange media, and then GAC again.
Mr. Schlesinger questioned whether the extraction wells or infiltration trenches would affect water supply well #2. At this time Mr. Gregson turned the presentation over Mr. Goydas, who, he noted, would be able to answer this type of question more clearly.
Mr. Goydas said that his component of the presentation would focus on the proposed wellfield and some of the modeling that was done to arrive at it. He noted that the three extraction wells are oriented along the axis of the plume, with the upgradient well focusing on the some of the higher concentrations of RDX and perchlorate, the center focusing on the meat of the perchlorate plume and some of the downgradient RDX contamination, and the leading edge well focusing on everything else that's downgradient - primarily the distribution of perchlorate. He also said that the side-gradient infiltration trenches are designed to help the system's performance and return the treated water to the aquifer. He noted that, as can be seen in the RRA plan, a whole host of different evaluations were conducted. He then displayed a figure that showed all the extraction well locations that were tested, and a figure that showed all the reinjection well and infiltration trench locations that were tested, and noted that a variety of combinations were considered.
Mr. Goydas then showed a computer animation of what the model predicts would happen to the plume if it were allowed to continue to migrate with no treatment system put in place. He pointed out that in both plan view and cross-section, it shows that the plume would continue to migrate to the north - partially into water supply well #2, and partially underneath it - and would ultimately discharge into Upper Shawme Pond. He also pointed out a portion of deep contamination believed to be located in an area of slow water velocities that retard its migration. He noted that the plan is to address the large volume of contamination with the RRA and reevaluate that deeper portion during the feasibility study to determine if an action is required there.
Mr. Schlesinger inquired about the perchlorate plume concentration contours in the animation. Mr. Goydas replied that the contours represent 1 ppb, 5 ppb, and 25 ppb intervals. Mr. Schlesinger then referred to the speed at which perchlorate travels, and questioned why it seems to move very slowly in this area. Mr. Goydas replied that perchlorate is very mobile; it moves with groundwater. He also said that dispersion tends to "drag out" a plume and also retard it, so it has a potential to actually move faster than the average groundwater velocity. The difference among some of the locations is where they are relative to the top of the groundwater mound and how much the groundwater wants to make it to its discharge point. For example, the groundwater in the Ashumet Valley will migrate at a different rate than at the Chemical Spill 10 (CS-10) plume, or the J-2 Range North plume. Mr. Goydas stated that in this case, the transport model indicates that perchlorate actually migrates faster at the leading edge of the plume than the groundwater velocity would suggest; this is because of the dispersion effect, which "takes the contaminant and tends to stretch it." He concluded by saying that perchlorate moves differently here than it does at other locations, primarily driven on the groundwater velocity.
Dr. Dahmani asked if the modeling assumed removal of the source area. Mr. Goydas replied that the scenarios he's showing tonight have no continuing sources; however, some of the sensitivity and uncertainty analysis had included a continuing source in order to ensure that the extraction wells were located appropriately in the event that the soil remediation that was conducted was incomplete. Dr. Dahmani said that he thinks it would be more appropriate to show scenarios with a continuing source since the source area hasn't been removed. Mr. Gregson clarified that the J-2 Range North plume source area was removed last year as part of the soil RRAs.
Dr. Dahmani also inquired about the dispersion coefficients that were used in calculations. Mr. Goydas replied that through the IRP and USGS work, calibrations of dispersivity have been done to the boron plume in Ashumet Valley - evaluations of first-time-of-arrival relative to the groundwater flow velocity, calculated based on head data. Also, with the "tremendous work" that the IRP has done evaluating various plumes, what he thinks is a very reasonable dispersivity valued was determined. He also noted that sensitivity analysis is done on dispersivity to evaluate what effect different dispersivities would have on the wellfield. Dr. Dahmani asked if it's correct that the impact was not significant in terms of time of arrival of the plume at the pond, for example. Mr. Goydas replied that within the range of what are believed to be realistic dispersivities, the plume would remediate in about the same amount of time; it might lengthen or shorten the restoration timeframe slightly - but not enough to call into question the appropriateness of the design.
Mr. Goydas continued by noting that the RDX plume looks very different than the perchlorate plume. The RDX plume contains less than about 8/10 of 1 kilogram of RDX, whereas the perchlorate plume contains about 30 kilograms of perchlorate. He also noted that while it seems that the contamination is disappearing in the animation he showed, that is not the case - rather, the concentrations are becoming increasingly lower to the point where they can no longer be seen in the aquifer. In other words, the mass is always retained in the aquifer, but the aquifer volume around the plume affects it from above, below, and beside it such that downgradient concentrations are in a larger volume of water.
Mr. Goydas then showed the animation that represents what would happen to the perchlorate plume with the proposed wellfield operating, and pointed out the three extraction wells and the infiltration trenches. Mr. Schlesinger noted that the toe of the plume seems to disappear, and suggested that this is probably an effect of the model. Mr. Goydas replied that, as he'd just explained, the low concentrations at the leading edge of the plume can't be retained as they migrate downgradient. He also noted that the appropriateness of a more downgradient extraction well was evaluated, but it was determined that the remediation would take longer (because of drawing the plume toward the well) and it would be much more difficult to evaluate the effectiveness of that well.
Mr. Schlesinger asked if it's correct that the RRA would be followed by another effort farther downgradient to capture the rest of the plume. Mr. Gonser noted that with the proposed RRA the plume pretty much collapses on itself. However, a feasibility study to come up with a final system, which might involve additional extraction wells, will be done after the RRA system is installed. He also said that it's thought that the proposed RRA system would be part of the final remedy. Mr. Schlesinger remarked that he hopes the model is right, given that the plume is within the ZOC for water supply well #2. Mr. Gonser said that implementation of the performance monitoring plan, which is part of the RRA, will provide frequent data to ensure that the model is right.
Mr. Goydas continued by showing the animation that represents what would happen to the RDX plume with the proposed wellfield operating. He noted that the RDX plume is much smaller than the perchlorate plume and the system would capture about 95% of the mass, with 85% of that mass being captured by the upgradient extraction well, and the central well capturing a small fraction of it.
Dr. Dahmani mentioned that the nondetect level for perchlorate is set at 1 ppb. Mr. Goydas replied that for the animations being shown tonight RDX is at 2 ppb and perchlorate is at 1 ppb. However, the RRA plan includes nondetect plume shells, which are at the analytical method detection limit, as well as some sensitivity plume shells to address areas of uncertainty in the mapping, which really foster and support the assertion that the design is good. Dr. Dahmani asked if there is a reason for not showing the lower levels in this forum. Mr. Goydas explained that the 2 ppb for RDX and 1 ppb for perchlorate has been used as a guide and presented to the agencies over time, but the nondetect evaluation also has been included.
Ms. Conron thanked Mr. Gonser for the work being done to clean up the J-2 Range North plume, and said that she is glad to go be able to go home with some positive news.
Mr. Schlesinger expressed concern about whether the IART is being shown the same information as the regulatory agencies were shown. Mr. Goydas noted that the sensitivity evaluations are included in the RRA plan and what was shown tonight are animations for perchlorate to 1 ppb and RDX to 2 ppb. Ms. Jennings added that the agencies will be receiving the RRA plan at the same time that IART members receive it. She also explained that the IAGWSP is moving very quickly on this project in order to get the system installed within a year. She said that it is a very aggressive schedule and the regulators gave the IAGWSP permission to make this presentation tonight to get the comment process moving, even thought they themselves have not yet seen the work plan. She further noted that IART members will have the chance to provide comments on the work plan at the May meeting.
Mr. Dow asked if the feasibility study will look at whether the soil RRA addressed the entire source area. Mr. Gonser replied that there will be an investigation and feasibility study that will cover the entire J-2 Range and determine whether any source areas were missed in the first effort. Mr. Dow inquired about the timeframe of the feasibility study. Mr. Gonser replied that is about one year behind. He said that the RRA groundwater system will probably operate for two to three years before a final solution would be in, which is why the RRA is fairly robust. He noted that it is expected to take care of all the problems being seen at this point, and unless more problems are found, there might not be much more to do.
Mr. Gregson concluded the presentation by noting that IART members will receive the plan next week and that comments can be submitted to Ms. Richardson. He encouraged the team to take a careful look at the plan and noted that the IAGWSP is looking forward to receiving comments.
Agenda Item #6. Demolition Area 1 Supplemental Evaluation and Schedule
Mr. Nixon stated that following the revised draft feasibility study for the Demo 1 groundwater plume, the regulators asked the IAGWSP to do some supplemental evaluations to determine if higher contaminants levels detected in monitoring wells near Pew Road would affect the outcome of the proposed alternatives. Alternatives 5 and 6 (the five-well system and the six-well system) were the focus of the supplemental evaluations, with the major difference between the two being that sixth extraction well, downgradient of Pew Road.
Mr. Nixon noted that the model was revised to incorporate the most recent actual data - for example, the flow rate at the Frank Perkins Road system is actually 220 gpm, but it had been 200 gpm in the model, because that's what it was supposed to have been originally, when the modeling for the feasibility study was initially done. Another revision in the model was the exact well screen elevation at the Pew Road system, which had to be changed during the drilling process because of the discovery of a clay layer. Porosity was changed from 0.39 to 0.35 to be in line with other modeling done at MMR and to correlate better with groundwater velocities being seen in the field. In addition, the startup date of the comprehensive remedy was moved up to 2007 from 2009, and the actual depths of the two nearby ponds (which are about 3 to 5 feet deep) were also added to the model.
Mr. Nixon showed a side-by-side comparison of the plume depiction used in the feasibility study and the revised plume depiction used in the supplemental evaluations, and noted that, based on drilling data, the plume now extends out a little farther. He also said that the highest detection of perchlorate seen downgradient of Pew Road was 3.2 ppb. He then showed a more close-up figure of the new plume outline, mentioned the RDX at Pew Road, and noted that that system is capturing the contamination in that area. Mr. Schlesinger asked if it is correct that "nothing more of RDX is getting past Pew Road." Mr. Nixon replied that that is a fair statement.
Mr. Nixon then displayed a line graph that showed predicted influent concentrations at a sixth extraction well, east of the ponds. He noted that detectable concentrations would be seen only in the first several years of operation, after which concentrations would have decreased to below the method detection limit of 0.35 ppb, by year six.
Mr. Nixon showed a table that detailed the comparison of the five- and six-well systems. He noted that cleanup time for RDX is the same, due to there being almost no RDX contamination past Pew Road and because of dispersion those low concentrations would decrease to the point that they are no longer detectable. Mr. Nixon noted that the five-well system includes four reinjection wells and the six-well system includes five. He also reported that the timeframe for cleaning up perchlorate to 1 ppb downgradient of Pew Road is nine years for both systems, but cleanup timeframes do vary by two years for cleaning up the perchlorate to 0.35 ppb, the current detection limit. Mr. Nixon then stated that with the five-well system, the plume would travel a distance of about 250 feet farther than it would with the six-well system.
Mr. Nixon reported that the difference in construction costs between the five- and six-well systems is $1.6 million and the difference in operation & maintenance costs is $2 million, bring the total difference to $3.6 million. He noted that spending that additional $3.6 million for a sixth well would mean achieving cleanup to background, or 0.35 ppb, two years faster, and would prevent 250 feet of downgradient migration of perchlorate contamination that's slightly above the detection limit.
Mr. Nixon noted that for sensitivity analysis, perchlorate concentrations throughout the plume were multiplied by five, such that the highest detection (3.2 ppb) was about 16 ppb. He said that the result was not very different; the plume traveled a little bit farther, but the concentrations were fairly similar. He remarked that as long at there are no unknown concentrations greater than five times those that are expected, "we should be on pretty safe ground."
Mr. Nixon stated that the feasibility study and remedy selection plan are scheduled to go out on May 13, 2005 and be followed by a 30-day public comment period. He noted that information on the supplemental evaluations will be presented as an appendix to the final feasibility study report. He also mentioned that the IART would meet next on May 24, 2005, in the middle of the public comment period, at which time he would try to address any questions team members have. In addition, comments and questions could be answered in the responsiveness summary document. Mr. Nixon stated that the last step in the process is to get EPA's approval and finalize a decision document.
Mr. Schlesinger said that he doesn't understand the idea that dispersion "makes plumes go away," and questioned what would happen if a "blob" of contamination moved from one point to another over time. Mr. Nixon replied that the "blob" would actually become larger as it moves and the concentrations in any one spot within it would be lower than they were before. He also noted that the Pew Road extraction well is containing the high concentrations of perchlorate, preventing it from feeding the downgradient portion of the plume. Mr. Schlesinger asserted his belief that it's possible that the plume could move with groundwater and the concentrations could remain the same. Mr. Nixon explained that the low concentrations would mix with the groundwater above, below, and on the sides, and eventually reach levels below the detection limit. Although the perchlorate molecule would still exist, dispersion would cause the concentrations to decrease to the point where one would see a stagnant plume front. He added that any plume will eventually reach a point where the forward migration of the water is continuing but the concentration has degraded - in this case, by dispersion and dilution - to below detectable levels. Mr. Schlesinger remarked that he hopes that is true, but is not convinced.
Mr. Jennings confirmed that what Mr. Nixon is saying is true, and she suggested thinking of it as a long tube with an extraction well cutting off one end of it. Water continues to flow through what is left on the other side "and dilutes it down, and dispersion also causes it to degrade, basically, over time." Based on the hydrology in this particular situation, the model predicts that the plume would only travel another 250 feet before reaching what's called a steady state. Mr. Nixon compared the process to a drop of salt in a swimming pool. As more and more water is added, it gets to a point that the salt cannot be tasted, even though the molecule of salt continues to exist.
Mr. Pinaud noted that DEP has reviewed the supplemental evaluation document and recently issued a comment letter, which IART members will receive by e-mail. He said that DEP fundamentally disagrees with the modeling at the leading edge of the plume. Rather, DEP believes that although the plume will disperse, it will be possible to detect it past the base boundary. He asked the IART members to keep DEP's comments in mind when reviewing the feasibility study alternatives.
Dr. Dahmani said that he thinks it might be appropriate for a Technical Outreach Services for Communities (TOSC) representative to make a short presentation to the IART on dilution and dispersion. He then asked why the decision was made to change the porosity values in the model. Mr. Nixon replied that the most current USGS information, as well as the information developed by Jacobs Engineering for the J Ranges, is a 0.35 value. He also noted that the value was truth-checked to ensure that it matches what was being seen in the field as far as groundwater velocities, and it did match. Mr. Nixon stated that it is about a 10% change in porosity, and leads to about a 10% increase in groundwater velocity, and also leads to a 10% decrease in plume mass.
Dr. Dahmani remarked that he's sure that DEP disagrees about how the plume will move because of the change made to porosity, a key parameter. He said that it's important to keep in mind that models are just models, but the important thing will be the monitoring that occurs in addition to the modeling. He also said that the 0.35 porosity value that was used is not based on reality, in that it wasn't based on analysis of actual soil cores. Mr. Nixon clarified that the 0.35 value is in fact a real number, based on data from the field, and now the model matches it better. Dr. Dahmani said that any parameter could be changed in order to change the modeling results. He also stated that it cannot be said that porosity is a true value at 0.35 just because it fits in the model results. Mr. Nixon said that 0.35 is the more accurate number, and even more importantly, the same porosities were used for both the five- and six-well systems in the comparison.
Agenda Item #7. Open Discussion - IART Membership
Mr. Schlesinger said that there is some agreement among the citizen IART members that more citizen members are needed on the team. He noted that only a few of the remaining members attend IART meetings regularly and he thinks it is important to bring more citizens to the table so that there will be more minds reviewing documents, finding mistakes, or coming up with bright ideas on how the IART's work can be improved. He added that he thinks the team originally started out with about 10 citizen members. Mr. Murphy noted that EPA has been looking at 12 as an operating number, but hasn't seen that in quite a while.
Mr. Schlesinger said that he's been trying to find potential IART members in Sandwich, but doesn't think this should be his responsibility alone. He also noted that more members from Mashpee and Falmouth are needed, and that residents from all four Upper Cape towns could end up drinking water from water supply well #2 if there's a drought this summer. Mr. Schlesinger then recommended that the EPA Region 1 Administrator, who appoints members to the IART, consider allowing individuals from the town boards' of selectmen as team members.
Ms. Conron said that while she doesn't think it is the place of the existing IART members to recruit new members, she would like to help with the effort. She recommended a separate meeting where the citizen members could discuss different ways to recruit. She then mentioned that the recruitment effort in the Bourne, which followed a well-attended public meeting about contamination in some town wells, was successful. She also noted, however, that since she's been part of the IART, the team has lost five productive members, and she questions whether IART meetings would even continue with no citizens at the table. Ms. Conron acknowledged that technical meetings can sometimes be boring, but noted that the applicants who came forward in Bourne were generally individuals who were interested in technical issues. She added that it is upsetting to her that the team doesn't have the resources it once had in terms of "people to give ideas." Mr. Murphy said that he thinks it is a good idea to have a separate meeting about recruitment and look at some of the IRP's recruitment methods.
Ms. Grillo informed the group that Sue Walker, one of the citizen members of the Plume Cleanup Team (PCT), circulated a letter regarding the Peters Pond situation, which some of the other PCT members also signed, and which is going to be forwarded to the Senior Management Board (SMB). With regarding to the recruitment situation, Ms. Grillo noted that there are now many citizen member teams associated with MMR, which has caused community involvement to become somewhat fragmented. Nevertheless, many individuals are involved, but perhaps don't attend all the meetings because they can get burned out.
Mr. Mullennix agreed that the small number of remaining IART citizen members is a problem and recommended considering the possibility of consolidating the groups that meet, which he said has been done in the past. He also noted that he thinks there are only three people in the room who aren't being paid to be there, and suggested that there is an overall decline in public service. He offered as an example the recent election in Bourne, in which only one of the elected positions (selectman) was contested. Mr. Mullennix also said that he thinks that there was more interest in the program earlier on when initial discoveries were being made, and that now it is not as exciting for people to participate.
Mr. Murphy suggested that community involvement staff members and the citizen members of the IART sit down after the meeting to discuss some kind of outreach strategy.
Mr. Schlesinger said that he would like a response from EPA to his question about having town-appointed members on the team. Mr. Murphy said that he thinks this idea is worth discussing during the separate meeting. Mr. Minior noted that the IRP tried this approach in the past and found that it was problematic because those individuals would not come to the meetings unless they were being paid. He also said that he thinks that interest in the cleanup programs is cyclic, and right now a great deal of interest is being generated because of the Peters Pond situation. He suggested that there's just a need to "get out there and shake the bushes a little more."
Ms. Conron said that she'd like to ask the individuals who no longer attend IART meetings why they stopped coming. She also recommended getting involved with one of the Cape Cod organizations that foster volunteers. She said that she feels certain that there are people who would could be productive and enjoy being part of the IART, and doesn't believe that the team's "time has passed."
Dr. Dahmani said that he agrees with Ms. Conron that the IART's time has not passed, and he mentioned the community members who attended the earlier part of the meeting, who might be interested in membership. He also said that he thinks that more members, like those who are currently volunteering their time, could be brought to the table if the right people are targeted.
Mr. Schlesinger noted that an all-day expo for volunteers took place in Hyannis today and that is the type of thing that he thinks the IART needs to work on. He also requested that future monthly report maps include a depiction of contamination in the Peters Pond area.
Agenda Item #8. Adjourn
Mr. Murphy noted that the IART would meet next on May 24, 2005 at the Best Western Hotel in Bourne. He then adjourned the meeting at 9:20 p.m.