Impact Area Review Team
Bourne Best Western
Bourne, MA
September 25, 2001
6:00 p.m. – 9:30 p.m.
Meeting Summary
Handouts Distributed at Meeting
- September 25, 2001 Draft Meeting Agenda
- August 28, 2001 Draft Action Items
- August 28, 2001 Draft Meeting Minutes
- July 24, 2001 Final Meeting Minutes
- Presentation handout: Munitions Survey Project Review
- Presentation handout: Impact Area Decision Criteria Matrix
- Presentation handout: IAGWSP Investigation Update
- Groundwater Study Update – IART Briefing 9/25/01
- Letter to IART members re: Emissions Testing M-16 Ammo
- Letter to Mr. David Dow re: Potential sources of antimony and
vanadium detected in Phase IIb Investigation
- Characterization of Explosives Contamination at Military Firing
Ranges
- Chemical structure of explosives
- IAGWSP validated results for Cleared Area 1
- Map: Extent of RDX Contamination Demo 1 Groundwater Operable
Unit – data received through 8/10/01
- Screening Values and Standards for Detected Compounds in Soil
- Fact Sheet: Impact Area Groundwater Study Program
Agenda Item #1. Welcome, Approval of August 28, 2001 Meeting
Minutes, Review Draft Agenda
Mr. Murphy convened the meeting at 6:06 p.m. and welcomed the
attendees. He asked the team members and audience members to
participate in a moment of silence to honor the victims from the
September 11, 2001 attack.
Mr. Murphy reported that Mr. Judge’s membership on the Impact
Area Review Team (IART) is still pending, and that he (Mr. Murphy)
will soon speak with the United States Environmental Protection
Agency (EPA) regional administrator regarding this matter.
Mr. Murphy briefly reviewed the team’s groundrules, which
include limiting questions during presentations, adhering to the
agenda, being mindful of time exceedances, using placards to
indicate desire to speak, and avoiding personal attacks.
Ms. Hayes thanked Mr. Murphy for reviewing the groundrules, and
said that she believes that a professional meeting should start and
end on time.
Mr. Murphy asked if there were any comments on the August 28,
2001 meeting minutes. Ms. Hayes said that she asked a salient
question regarding the cost and length of the investigations update
at the last meeting and hoped to see it reflected in the minutes.
Mr. Gregson referred to the third paragraph on page 5 and said
that the statement refers to the latter standard, but should
refer to the former standard, which is the uniform treatment
standard. He then referred to the second paragraph on page 6 and
noted that the Gulf Range should be the Golf Range. He
also referred to page 13 under the contained detonation chamber
topic and said that 1700 items have been destroyed, not 17,000.
Mr. Murphy asked if there were any additional comments on the
minutes. Hearing none the minutes were approved with the changes. He
then briefly reviewed the proposed agenda.
Agenda Item #2. Review Action Items
- The Guard will provide the team with a copy of validated
results concerning Cleared Area 1 in the Phase IIb Report.
Mr. Murphy stated that a handout is available at the back table.
- The Guard will provide the "Fate and Transport"
laboratory study report (due this month) to the Massachusetts
Institute of Technology (MIT) representatives involved with the
IART.
Mr. Gregson stated that this report will not be available until
November, but that he will keep the team updated on its status.
- At the next IART meeting the Guard will provide a water level
survey overlay on the Central Impact Area Aerial Magnetometry data
map.
Mr. Gregson reported that AMEC currently is working on this
project.
- Ms. Pepin requests that general handout maps be updated.
Mr. Gregson said that he believes that maps are being updated.
- The Guard will provide the team with a copy of the Army
Environmental Center (AEC) Report.
Mr. Murphy reported that the report was mailed to team members on
September 18, 2001, and that a copy is also available at the back
table.
Mr. Hugus referred to the document entitled
"Characterization of Explosives Contamination at Military
Firing Ranges," which was distributed to team members. He said
that while the document bears the logo of the United States Army
Corps of Engineers (USACE), it was actually written by Jenkins and
others. He stated that the introduction of the document reads,
"An ongoing investigation at the Massachusetts Military
Reservation (MMR) has indicated that the underlying groundwater
aquifer below this site is contaminated with low concentrations of
Royal Demolition Explosive (RDX). The source of this RDX is
uncertain, but it may be related to activities on Massachusetts
Military Reservation impact ranges." He noted that the document
is dated July 2001, and stated that he believes that a correction
should be made to the statement. He asked that this issue be
discussed further under "Other Issues."
Ms. Hayes noted that she did not receive a copy of the letter to
Mr. Dave Mason regarding the Snake Pond posting. Mr. Murphy stated
that a copy of the letter will be distributed to her.
Dr. Feigenbaum referred to the letter regarding small arms and
M-16 firing, which was included in the IART mailing. He asked if it
was part of an official report. Mr. Gregson replied that the letter
consists of different parts of the study that was conducted by the
AEC. Dr. Feigenbaum said that he was under the impression that the
study would be relevant to the small arms studies. Mr. Gregson said
that the report is relevant and includes air emissions results from
green ammo rounds. Dr. Feigenbaum stated that the cartridge for the
green ammo projectile has not changed, and noted that he was not
able to find test results from the cartridge in the body of the
letter. Mr. Gregson referred to Table 3, which depicts the compounds
that were detected as part of the investigation. Dr. Feigenbaum
pointed out that Table 3 does not indicate that explosive and
propellant compounds were detected. He added that he is skeptical
about the report.
Mr. Hugus requested updates on any correspondence with Governor
Swift, and on the small arms ranges. Mr. Murphy added these two
items under "Other Issues."
Agenda Item #3. Munitions Survey Project Update
CPT Myer explained that the Munitions Survey Project (MSP) will
assist the groundwater study program, and will ultimately be
utilized in developing and selecting remedial alternatives to
address unexploded ordnance (UXO) for the ongoing soil and
groundwater investigations.
CPT Myer displayed a graphic depicting the project timeline. He
stated that the initial investigation of priority sites was
conducted from June 2000 through October 2000. He said that the
current investigation began in July 2001 and will run through
December 2001.
CPT Myer then displayed a slide listing the various geophysical
technologies that have been utilized throughout the project. He
demonstrated how a schonstedt works, and explained that a schonstedt
is a handheld magnetometer used for field verification of buried
metallic objects. He said that other technologies being employed
include cesium vapor magnetometry, an aerial magnetometer, and a
CHEMS, which is a towed array magnetometer.
CPT Myer stated that the initial investigation areas consisted of
17 areas that include gun and mortar positions, Demolition Area 1,
selected water bodies, the slit trench, the J Ranges, and aerial
magnetometer areas.
CPT Myer referred to the gun and mortar positions and explained
that excavation was done to identify the metallic anomalies. He
reported that no munition caches were found at gun position 10
(GP-10) or GP-11. Additional investigation is required at GP-12. He
said that eight gun positions and nine mortar positions were
surveyed with the geophysical survey. Ninety-four anomalies that
exceeded 45 millivolts, which is the threshold value, were
identified at GP-10. Ninety-five anomalies were identified at GP-11.
He explained that most of the items found were fuse clips and
projectile lift rings.
CPT Myer stated that 1700 anomalies were identified at Demo Area
1. Excavation work was conducted and there was evidence of six burn
pits. He explained that expended munitions were found at the burn
pits: 20-millimeter and 30-millimeter casings. Soil samples were
taken at the burn pits and analysis will be forthcoming. He stated
that a plan to address the anomalies currently is in development.
CPT Myer reported that the five ponds investigated on the MMR are
Bailey’s Pond, Donnelly Pond, Deep Bottom Pond, Gibbs Pond, and
Grassy Pond. He explained that geophysical surveys were conducted on
the water bodies using first a schonstedt, which was followed by the
EM-61. Among the objects identified were some small arms, flares,
and smoke canisters. Visual verification was conducted at Bailey’s
Pond and Donnelley Pond and 630 blank rounds for 5.56 millimeter,
eight trip flares, two unused slat flares, as well as a couple of
other types of flares were identified. CPT Myer noted that these
items have been moved to a safe holding area. He stated that
recommendations to address the water bodies include the validation
and excavation of the anomalies. He added that additional water
bodies are being considered for investigation.
CPT Myer explained that the slit trench is a suspect disposal
site in the Central Impact Area. He reported that no UXO was
identified at the slit trench and 22 anomalies were identified and
excavated. The anomalies consisted mostly of car parts. However,
soil samples were collected because crushed 105-millimeter casings
also were discovered. Future action on this site will be determined
based on the soil sample result information.
CPT Myer stated that the southeast corner of the ranges also were
part of the initial investigation, which includes the J Range. He
reported that two Volkswagens and an M-48 tank, which is a Korean
War vintage tank, were excavated from the area. Four caches of inert
munitions also were excavated from the southeast corner. CPT Myer
explained that the caches were identified during construction
support activities for the installation of monitoring wells. The
first cache, 1100 mortar rounds, was discovered in 1997 at the J-1
Range. A second cache was discovered at the J-1 Range during the
summer of 2000 – again during well installation construction. He
added that two caches also were found at the J-2 Range that same
summer. CPT Myer stated that the Guard is recommending excavation at
the J Ranges.
CPT Myer stated that the following five areas were surveyed
during the aerial magnetometry survey: Area 1, which is the U Range
and consists of 130 acres, Area 2, which is the B-9 training area
and consists of 255 acres; Area 3, which is the J Ranges and
consists of 780 acres; Area 4, which is the southern training area
and consists of 1650 acres; and Area 5, which is the Central Impact
Area and consists of 2200 acres.
CPT Myer stated that 259 anomalies were identified in the U
Range. Ten anomalies were verified visually; however, none were
excavated. Four of the anomalies were munitions-related and included
3.5-inch rockets in a berm at the edge of the U Range, 40-millimeter
grenades, and lots of caliber rounds.
CPT Myer reported that lead, loss of caliber rounds,
40-millimeter grenades, and 3.5-inch rockets were identified at the
small arms range. He noted that the aerial magnetometry survey
identified ordnance that was not found during the ground
reconnaissance work.
Ms. Pepin asked whether the items found were blown in place or
removed. CPT Myer replied that the items were left in place while
additional work is ongoing.
CPT Myer reported that 2575 anomalies were identified in Area 2.
Twenty-five anomalies were visually verified, though excavation was
not conducted. Among the anomalies was scrape metal, which is not
UXO related. However, surface UXO, consisting of small arms lead,
90-millimeter rounds, 37-millimeter rounds, and 57-millimeter rounds
was detected at the anti tank range. He reported that nothing was
detected in two areas where anomalies were identified. Ten items
were geologic material that either had ferrous properties or had a
magnetic signature to it.
CPT Myer stated that a total of 3567 anomalies were identified at
Area 3, 42 of which were visually verified. Of the 42, 12 were
non-munitions related, and one was a munitions-related anomaly,
which is located on a ridge south of the J-3 Range and appears to be
a historical firing berm. He noted that there were 29 areas where
nothing was found either on the surface or by using the schonstedt.
CPT Myer reported that 6044 anomalies were detected in Area 4.
Ninety-seven of the anomalies were visually verified and five
anomalies were excavated. There were 34 areas where nothing was
found and 12 areas where magnetic rocks were detected.
Mr. Hugus commented that it appears that 20% to 30% of the
readings in the aerial magnetometry are false readings. CPT Myer
replied that one explanation could be buried magnetic rock. Mr.
Borci explained that the survey was not a statistically-based
survey, but was intended to be a means to gather information so that
the evaluation process of the thousands of anomalies could commence.
He noted that areas were selected based on archive search report
interview information. Mr. Borci also said that the schonstedt does
have limitations, which is why digital equipment is used whenever
possible. He reported that EPA is meeting with the Guard tomorrow to
discuss possible next steps to address the anomalies.
CPT Myer reported that a total of 4667 anomalies were detected in
the Central Impact Area; 76 were visually verified, and four were
excavated. He noted that a lot of scrap metal was found in the
Central Impact Area. Four munitions-related items were found; two
155-millimeter liter rounds, and scar rockets. He also noted that
one 105-millimeter projectile, a 55-gallon drum, a metal plate, and
an angle iron were among the items excavated.
CPT Myer stated that current tasks include continuing UXO surface
clearance and continuing geophysical investigation work at selected
areas. He noted that brief letter reports will be issued on each
task to help integrate MSP data with the groundwater investigation
effort.
CPT Myer reported that surface clearance is ongoing at the former
A Range in preparation for the geophysical survey. He said that some
open detonations have taken place in the area in an attempt to clear
surface debris. AMEC already has installed some monitoring wells and
has collected soil samples in the area. CPT Myer also reported that
geophysical work is complete at the former K Range. He stated that
the Guard currently is in the preliminary stages of data evaluation.
CPT Myer reported that some geophysical work has taken place at
the ammunition supply point (ASP). He said that an interviewee from
the archive search report identified areas where ammunition might be
buried. He said that the Guard is recommending additional
geophysical work at the ASP.
CPT Myer stated that Demo Area 2 is being prepared for ground
based geophysics to evaluate the area for UXO, buried caches, or
burial pits. He added that a letter report will be drafted for
Succonsett Pond.
CPT Myer stated that the MSP has enabled the Impact Area
Groundwater Study Program (IAGWSP) Office to identify small areas
for detailed study. The MSP actually has helped to reduce the
footprint of the areas where detailed investigations are required.
It also helps in prioritizing locations for future study. CPT Myer
explained that the MSP encourages the efficient use of investigation
resources as it integrates the UXO investigation work with the soil
and groundwater work.
CPT Myer reported that future steps include the release of the
final MSP report, which is pending comments from EPA and the
Massachusetts Department of Environmental Protection (DEP). Also,
the future steps regarding the aerial magnetometry effort will be
presented to EPA and DEP for comment; this will occur at tomorrow’s
meeting. Letter reports will be issued and additional sites for
investigation will be identified. He added that additional work will
also take place at existing sites.
Mr. Borci stated that the draft MSP will be provided to team
members in CD-ROM form. Ms Pepin requested a hard copy of the
report.
Mr. Hugus said that the J Range report contained a map that
depicted one long straight road in the J Range with dots on both
sides of it representing munitions. He asked CPT Myer if he had a
copy of the graphic. CPT Myer replied that he did not. Mr. Hugus
said that he found the graphic to be useful in understanding where
munitions were found. He noted that it does not contain useless
information such as where metal debris and car parts were found. He
requested that the team be provided with pertinent information. Mr.
Borci said that he thinks the team could be provided with a copy of
the graphic. He pointed out that over the coming months the real
munitions survey work will begin and hundreds of munitions probably
will be identified and excavated.
Ms. Dolan pointed out that the CD-ROM, which the team members
will be receiving, contains graphics and maps that Mr. Hugus may
find useful.
Mr. Judge asked what the caches were comprised of. CPT Myer said
that he did not have the specifics with him tonight, but would be
happy to provide Mr. Judge with that information.
Mr. Judge stated that he is concerned about the Good News Bog and
its proximity to some anomalies. He asked if the aerial magnetometry
survey covered that area. CPT Myer replied that it did not, but that
a schonstedt was utilized and nothing but survey pins were detected.
Ms. Dolan said that the USACE is preparing a workplan that includes
the former H Range, and will address the area in question.
Mr. Hugus referred to the high explosive (HE) round that was
found on Camp Good News and said that he noticed that the Town of
Sandwich was not notified about the round because it was considered
to be in an exclusion zone. Ms. Dolen, of the IAGWSP Office noted
that Sandwich Officials; Mr. Ron Larkin, Mr. Judge, and others, were
contacted.
Mr. Hugus asked what is meant by the "exclusion zone."
Ms. Dolen explained that the exclusion zone is a 500-foot buffer
zone. When a UXO is found, a radius of where fragments might have
flown is determined; that radius is tripled to ensure that the area
is substantially safe. She said that if the radius touches anywhere
in the exclusion zone, the notification protocol is then triggered.
Mr. Hugus asked if an informal protocol was implemented in this
case. Ms. Dolen replied that it was. Mr. Hugus pointed out that the
area in question is actually part of the Town of Sandwich. Ms. Dolen
stated that the exclusion zone is clearly demarcated and has been
agreed upon by the Town of Sandwich and the IAGWSP.
Mr. Cambareri referred to the AEC report and the lack of findings
concerning pyrotechnic compounds in the soil in the small arms range
testing. He commented that the AEC report seems to be concerned
about the fate and transport dispersion of air contaminants and the
lack of detections of explosive compounds compared to detections of
pyrotechnic compounds in the soil of the MMR small arms range
testing. He said that he is interested in how the protocol was set
up for the energetic materials, the volatile organic compounds (VOCs)
and semi-volatile compounds (SVOCs), and the particulate matter. He
asked whether the particulates from the quartz filter were sampled
for energetic compounds. Mr. Gregson said that he will find out and
report back to the team on this matter.
Agenda Item #4. Using the Decision Criteria Matrix to Assess
Remedial Alternatives
Ms. Dolen explained that alternatives aimed at addressing areas
of concern associated with the Impact Area will be rigorously
examined soon, and members of the public, as well as IART members,
will be included in the analysis. She stated that a Decision
Criteria Matrix (DCM) will serve as a sophisticated checklist as it
weighs the pros and cons of each alternative. She explained that the
site-specific DCM was created at MMR in 1996 by the Air Force Center
for Environmental Excellence (AFCEE) and implemented by the
Installation Restoration Program (IRP) in its plume cleanup program.
Ms. Dolen explained that the DCM process begins with the proposed
alternatives. She pointed out that alternatives for Demo Area 1 soon
will be available following the delivery of the draft feasibility
study next week. The agencies and IART members will then weigh the
alternatives against the decision-making criteria. She explained
that the DCM shows, in graphic form, how each alternative ranks
according to the various criteria, and it is in this forum that the
alternatives are presented to the public for comment. Ms. Dolen
stated that a final decision will be made based on public input, as
well as input from the agencies, professionals, technicians, and
engineers.
Ms. Dolen explained that the DCM is driven by three guiding
principles, which she phrased as questions: "does the
alternative meet the basic cleanup requirement?" "How well
does the alternative work?" "Is the alternative acceptable
to agency groups and the public." She pointed out that the DCM
serves two functions; one is to evaluate and rank the proposed
alternatives, and the second is to provide a graphic checklist for
the public.
Ms. Dolen displayed a simplified version of what a checklist
might look like, and noted that it weighs the pros and cons of each
alternative. She explained that the alternatives will first be
measured against the threshold criteria, then the primary balancing
criteria, and then the acceptance criteria.
Ms. Dolen explained that the threshold criteria grouping is
basically a pass/fail test; if an alternative does not meet these
criteria, it does not move forward. The threshold criteria are based
on the protection of human health and the environment, and
compliance with law and regulations.
Ms. Dolen explained that the primary balancing criteria weigh the
quantitative and qualitative values of each alternative. Five
categories are covered under the primary balancing criteria;
long-term effectiveness and permanence; short-term effectiveness;
reduction of toxicity, mobility, and volume through treatment;
implementability; and cost. The acceptance criteria look at whether
the alternative is acceptable to the agencies and the public.
Ms. Dolen stated that the Impact Area DCM is evolving, and the
IART will have an opportunity to review it before it is used. She
stressed the importance of public comment and noted that it directly
influences the final decision.
Ms. Hayes thanked Ms. Dolen and said that she thinks it’s
encouraging to know that the public at large will be included among
those solicited for comment. She said that she likes the holistic
approach.
Ms. Pepin referred to the bullets listed under the primary
balancing criteria and said that not one addresses the safety of the
technology proposed for remediation. Mr. Walsh-Rogalski explained
that the groundwater study is being conducted under the Safe
Drinking Water Act (SWDA), and the DCM process was developed under
the Comprehensive Environmental Response, Compensation and Liability
Act (CERCLA) program. The final DCM used by the Impact Area program
will probably contain all the elements of the IRP DCM, with some
additional elements pertinent to the SDWA. He explained that there
is added emphasis on the fact that the cleanup involves a
sole-source aquifer that is particularly susceptible. He stated that
both ecological and human health short-term impacts will be
addressed.
Agenda Item #5. Investigations Update
New Detections Update
Mr. Gregson referred to monitoring well 174 (MW-174), which was
installed at the target berm for the former B Range, and reported
that the well tested nondetect for explosives. He stated that there
is an unvalidated detection of RDX at MW-58, which was installed by
the IRP for Chemical Spill 19 (CS-19). He reported that MW-40S, in
the Central Impact Area, had detections of trinitrotoluene (TNT) and
RDX. Mr. Hugus inquired about the concentration levels of the
detections. Mr. Gregson replied that he does not have that
information with him, but would provide Mr. Hugus with it. He then
stated that MW-45S at the L Range also had a detection of RDX, and
MW-164M2 in the J-1 Range had a detection of tetryl.
Mr. Gregson stated that he reported recently on a detection of
perchlorate at well MW-66S. Mr. Borci pointed out that the
perchlorate detection was 1.9 ppb and that EPA is requesting that
1.5 parts per billion (ppb) be used as the level to evaluate
perchlorate detections. Mr. Hugus asked whether the Guard has
accepted EPA’s guidance. Mr. Gregson replied that the Guard
currently is reviewing the letter from EPA. He noted that personnel
at the Department of Defense (DoD), the Air Force, and other groups
have questions regarding the level proposed by EPA. He reported that
the Guard will use the proposed level for the study while DoD and
other interested parties work through the issue with EPA and the
Guard.
Mr. Gregson reported that perchlorate was detected at three wells
in the Central Impact Area. All the detections were below the safe
exposure limit, but above the 1.5-ppb limit requested by EPA. He
also stated that there is an unvalidated detection of
perchloroethylene (PCE) in MW-19S at Demo Area 1.
Dr. Stahl asked whether vinyl chloride was detected in Demo Area
1. Mr. Gregson replied that he is not aware of any vinyl chloride
detections. Dr. Stahl asked at what concentration PCE was detected.
Mr. Borci replied that he believes PCE was detected between 0.5 and
1 ppb.
Snake Pond Diffusion Sampling Results
Mr. Gregson reported that the first line of diffusion samplers
extended across the north cove into the spit area of Snake Pond,
which is near MW-171 where there was a detection of RDX. He stated
that 22 diffusion samplers were installed, all of which were
nondetect for RDX.
Mr. Hugus said that the United States Geological Survey (USGS)
modeling indicated that upwelling would occur 200 feet south of the
spit. He asked if a diffusion sampler was installed at that
location. Mr. Gregson replied that the sampler is located beyond the
200 feet mark, based on the modeling. According to USGS’s
understanding of groundwater flow, there is a sharp increase in the
slope that intersects the pond bottom.
Dr. Feigenbaum noted that MW-171 had an RDX detection of 4 ppb.
He asked at what level the well was screened, and inquired whether
it was possible that there was a larger concentration either deeper
or shallower. Mr. Gregson replied that the well was profiled and the
screen was set within the 4 ppb range, which was approximately 50
feet below the water table.
Mr. Gregson reported that in excess of 100 diffusion samplers
were installed last week in an attempt to locate RDX detections near
the pond bottom. The samplers will remain in place for approximately
four weeks, and results should be available approximately six weeks
from now.
Agenda Item #6. Other Issues
Status of Correspondence with Governor Swift
Mr. Walsh-Rogalski stated that EPA has tried to reach the
Executive Office of Environmental Affairs (EOEA) for some time, and
has finally made contact. He reported that EPA sent EOEA a fact
sheet that contained a summary of the small arms range data, and
that expressed EPA’s concern about propellant concentration
levels.
Mr. Hugus thanked EPA for making the effort, but said that he is
discouraged by how difficult it has been to reach the Governor, by
the problems concerning the Impact Area study over the last four
years, and by the lack of involvement in the Master Plan process.
Ms. Garcia-Surette stated that DEP communicates with EOEA and has
been specifically discussing issues regarding the small arms ranges.
Regarding the Master Plan process, she stated that the Environmental
Performance Standards (EPS) were crafted in such a way that they do
not serve as an obstacle to the efforts of the Impact Area
Groundwater study project or the IRP.
Mr. Hugus stated that he is not concerned with the EPS, but
rather whether Governor Swift was receiving the blunt facts
regarding the Guard’s past record on MMR. Ms. Garcia-Surette
assured Mr. Hugus that DEP has provided information regarding the
technical aspects of the issue in an effort to create better
policies. She noted that information regarding the small arms ranges
is still forthcoming, and it may be just the beginning of the
process, which could warrant further assessment, decision-making,
and remediation.
Dr. Feigenbaum asked whether the Governor is aware of the RDX
that has been detected in the soil and groundwater. Ms. Garcia-Surette
said that the Governor is not making technical decisions. She
explained that data established over the past year will help to
determine whether there is a correlation between the propellants and
the 2,4-dinitrotoluene (2,4-DNT), especially regarding the small
arms ranges. She noted that some areas of the project are further
along; for example, there are a lot more data available on Demo Area
1 and the gun and mortar positions than are available on the small
arms ranges. She stated that she believes EPA and DEP share the same
sentiment that further monitoring is warranted.
Dr. Feigenbaum clarified that he is referring to artillery and
mortar firing. Ms. Garcia-Surette said that she believes that the
plume is being delineated, which means there is a connection with
past activities that would not be acceptable today. Dr. Feigenbaum
asked if it is safe to assume that everybody is on the same page
concerning the artillery and mortar firing. Ms. Garcia-Surette
indicated that that is the case.
Small Arms Ranges
Mr. Hugus suggested that team members be prepared to discuss the
AEC report at the next IART meeting. He noted that AMEC has provided
a small arms report as an addendum to the Phase IIb report, and it
includes a recommendation from the Guard for an "evaluation of
the potential impacts to groundwater from the contaminants
identified in soil." He also noted, however, that it does not
state that the firing should cease until the source of the DNT is
identified. He said that he thinks it would be prudent to cease
training in order to protect the environment. He also said that the
reports, which have been provided by the Guard, indicate that DNT is
not coming from the guns. Mr. Hugus further recommended that the AEC
report was conducted without any independent review, and he thinks
there are problems with the study. He said that he finds it
difficult to trust the AEC report when the Army has an interest in
continuing training. He recommended that both EPA and the Guard take
the DNT detections seriously and not just rely on the AEC report.
Mr. Gregson reported that EPA was involved with the AEC emissions
report. He stated that 2,4-DNT was not detected in the air
monitoring samples that were collected as part of the small arms
range study, which concurs with the AEC report. He reported that the
Guard is working with EPA on an additional soil sampling plan to
address the detections of 2,4-DNT at the Golf and India Ranges. He
noted that the Guard will provide EPA with a workplan concerning
this matter by October 19, 2001.
Dr. Stahl asked what kind of residue is left behind on the
chamber used to test air emissions. He also suggested that perhaps
particles are quite large and fall out of the air and therefore are
not tested, which may account for the DNT detections at the ranges.
Dr. Feigenbaum pointed out that 2,4-DNT, or a breakdown product
of it, was discovered at currently-used ranges also, not just
formerly-used ranges. Mr. Borci stated that 2,4-DNT was detected at
the GA/GB Range, which is a former distance rifle range. Dr.
Feigenbaum said that the 2,4-DNT has persisted for a long time. He
then asked Mr. Borci to comment on the matter. Mr. Borci said that
he believes that the Guard recommended no additional work at the
GA/GB Ranges, specifically at the firing lines. He noted that it is
difficult to define the historic firing lines precisely and EPA has
asked the Guard to confirm the accuracy of the firing line sampling.
He also mentioned that EPA reserves the right to require additional
sampling.
Dr. Feigenbaum requested that the Guard and EPA contact personnel
who participated in the AEC report to determine whether additional
comments are available. Mr. Borci and Mr. Gregson agreed to do so.
Dr. Feigenbaum said that the Army Environmental Hygiene Agency
released a report in the 1986/87 timeframe regarding 105 mortar and
M-16s. He suggested that the team members revisit that study in
light of the AEC report.
Mr. Walsh-Rogalski asked if the report in its entirety was
distributed to the team members. Mr. Gregson replied that he only
included data on the types of rounds used specifically at MMR. Dr.
Feigenbaum said that he thought 30- or 50-caliber machine guns are
used on MMR. COL Bleakley explained that a 50-caliber machine gun is
fired on MMR, but it uses plastic ammo. Dr. Feigenbaum said that he
is concerned about the propellant and is interested in the data from
the AEC report. Mr. Gregson said that he will provide that
information to the team.
Mr. Hugus stated that he is waiting to hear about the
quantification of DNT in the various cartridges, which Dr.
Feigenbaum had requested at a previous IART meeting.
Dr. Feigenbaum asked for a breakdown of the constituents found in
both the standard and the green M-16 propellant. Mr. Gregson said
that he would provide that information to the team.
Agenda Item #7. Agenda Planning and Review Action Items
Mr. Murphy reviewed the future agenda items and action items.
Future Agenda Items:
- Snake Pond Diffusion Sampling Results
- Small Arms Ranges Update
- HUTA II Scope of Work
- CS-19 Update
- Petroleum Like Material (PLM) results
- Delineated Plume for the J Ranges
Action Items:
- The Guard will respond to Mr. Cambareri’s question about
quartz filter analysis regarding the AEC report.
- Mr. Borci and Mr. Gregson will contact members of EPA and the
Army who were involved with the AEC report in an effort to
determine whether there is additional information available from
the emissions test report, beyond what was sent to the IART.
- If available in the AEC report, Mr. Gregson will distribute data
from 50 caliber machine guns using plastic ammo.
Status
of Action Items
Mr. Cambareri asked if issues concerning the pump test will be
discussed at a future meeting. Mr. Gregson said that he will provide
Mr. Cambareri with that information directly, as the rest of the
team may not be interested in the details.
Mr. Borci reported that the private investigator, who conducted
interviews for the archive search report has resumed the
interviewing process.
Mr. Murphy announced that the next IART meeting is scheduled for
Tuesday, October 23, 2001 at 6:00 p.m. at the American Legion in
Sandwich. After some discussion the team members agreed that because
of holiday conflicts the November IART would be postponed until
December 4, 2001, after which the team will resume its regular
meeting schedule.
Agenda Item #8. Adjourn