Future Agenda Items:
- Gun and Mortar Firing Positions Workplans
- Fate and Transport Presentation (proposed for March 24, 2003)
- Demolition Area 1 RRA/RAM for Soil (February 25, 2003)
- Update on the Programmatic Agreement being Pursued by MMR with
Respect to Cultural Resource Surveys
- Presentation to Answer Questions about Modeling
Handouts Distributed at Meeting:
- 1/22/03 EPA Memo re: Status of EPA’s Interim Assessment
Guidance for Perchlorate
- Presentation handout: Demolition Area 1 Groundwater Interim
Action
- IAGWSP fact sheet: January 2003 – Demolition Area 1 (with
map attached)
- Information sheet: Demolition Area 1 (Demo 1)
- Rapid Response Action/Release Abatement Measure (RRA/RAM)
Schedule – Demo 1 Groundwater Operable Unit
- Notice of public comment period for draft RRA/RAM for Demo 1
Groundwater Operable Unit
- Responses to Action Items from the December 10, 2002 Impact
Area Review Team Meeting – Revised as of January 28, 2003
- Presentation handout: Investigation Update
- Data Tables
- Groundwater Program Update / December 2002 – January 2003
Agenda Item #1. Welcome, Review Draft Agenda,
Approval of December 10, 2002
Meeting Minutes
Mr. Murphy convened the meeting at 6:05 p.m. and
the IART members introduced themselves. Mr. Gonser noted that he’s
been assigned as interim program manager of the IAGWSP, and a
permanent civilian program manager is expected to be hired in March
or April.
Mr. Murphy reviewed the agenda and noted that as
follow-up to the Demolition Area 1 (Demo 1) posterboard session that
occurred just before the meeting, the Demo 1 agenda item will be
discussed prior to the review of action items from last month’s
meeting, which typically occurs closer to the beginning of the
agenda.
Mr. Murphy asked if there were any changes or
additions to the December 10, 2002 IART meeting minutes. No changes
were offered and the minutes were approved as written.
Agenda Item #2. Late-Breaking News
Mr. Walsh-Rogalski announced that EPA
Headquarters recently released a document called "Status of EPA’s
Interim Assessment Guidance on Perchlorate." He then noted that
in 1992 EPA issued a provisional reference dose (RfD) of 4 parts per
billion (ppb) for perchlorate. He explained that an RfD is the
amount that EPA considers not harmful for an individual to ingest
over a lifetime, based on a daily intake. In 1995, EPA’s Office of
Research and Development was asked to look at that RfD again, after
which it was changed to 18 ppb. Since that time, EPA has seen
additional information regarding exposure pathways that would be the
most problematic for perchlorate, that is, "neuro-developmental
toxicity for in-utero fetuses." The Department of Defense (DoD)
and EPA conducted a host of studies during 2000 and 2001. In 2002
EPA issued for external peer review a draft document, which already
had undergone internal peer review, and which summarized all the
studies and proposed an RfD that would translate to a drinking water
equivalency level of 1 ppb.
Mr. Walsh-Rogalski noted that while the external
peer review isn’t yet complete, there’s been a lot of
controversy – generated primarily by parties who would be
conducting cleanups – around the 1 ppb number. Therefore, EPA
Headquarters decided that it should issue some clear guidance to the
regions with respect to which numbers should be used. The new
guidance document states that until an RfD is finalized, the 1999
EPA memorandum, which notes a 4-18 ppb range, should be followed
with respect to perchlorate cleanup decisions. Mr. Walsh-Rogalski
said that his office is trying to sort out what this means now and
in the future in terms of cleanup at the Massachusetts Military
Reservation (MMR).
Ms. Hayes asked if it’s correct that the
cleanup program should immediately begin using a 4-18 ppb range. Mr.
Walsh-Rogalski replied that the guidance document states that as a
general rule one should be guided by the 1999 policy, which noted a
4-18 ppb range. He also said, however, that the guidance document
states that in site-specific instances, the regions might want to
depart from that range, but shouldn’t do so without first checking
in with EPA Headquarters.
Mr. Gregson asked whether there’s any
information on when the new RfD will be issued. Mr. Walsh-Rogalski
replied that there is not, and mentioned that there’s been some
talk about going to an outside third party for evaluation, which he
believes would be a six-month process. He also said that his guess
is that it would be on the order of one year before the new RfD is
finalized.
Mr. Judge questioned whether the new guidance
document mentioned child exposure pathways. He also inquired about
measures that would allow reexamination of decisions based on a 4-18
ppb range, in the event that the numbers change. Mr. Walsh-Rogalski
replied that, unlike the Superfund program, which has a fairly
defined process for reevaluating decisions, the Safe Drinking Water
Act (SDWA) would be "very flexible" in that regard. He
also said that he thinks that EPA and the National Guard Bureau (NGB)
should discuss whether the NGB wants to make decisions that would
accommodate cleanups that look forward to a 1 ppb cleanup number,
which EPA would require should that turn out to be the final number.
Mr. Walsh-Rogalski then stated that the reading
he’s done suggests that exposure by ingestion, rather than dermal
and inhalation exposures, is the primary concern. He also said that
the RfD takes child exposures into account; the 4-18 ppb number
doesn’t have to be adjusted for child exposure. Mr. Walsh-Rogalski
further noted that the document includes a footnote that the
suggestions have carefully considered the lower end of the 4-18 ppb
range in light of new data that suggest that an in utero fetus could
be at risk. Mr. Judge said, "so children aren’t necessarily
mentioned there." Mr. Walsh-Rogalski replied that EPA
Headquarters looked at the fact that "children tend to be more
sensitive to certain things" and concluded that the numbers
that were derived don’t need to be adjusted for children.
Mr. Judge asked whether it was just the exposure
pathway for pregnant women that led to the change "from 18 to
1" ppb. Mr. Walsh-Rogalski replied that the studies that were
done focused on iodine uptake, and pregnant women and women of
childbearing age were identified as the most sensitive
sub-population. He also said that he believes that other risks,
among populations that aren’t as sensitive, were identified and
taken into account, and added, "but by capturing that as the
most sensitive population, you’re safe with respect to less
sensitive populations." Mr. Judge asked whether the document
specifically states that the 4-18 ppb range sufficiently covers
pregnant women and women of childbearing age. Mr. Walsh-Rogalski
replied that he doesn’t know whether it does or not.
Mr. Gonser noted that some copies of the
"Status of EPA’s Interim Assessment Guidance for Perchlorate"
document are available this evening, and the last sentence of that
document deals with the issue that’s of particular concern to Mr.
Judge.
Mr. Gonser also mentioned the issue of how to
move forward, and noted that the IAGWSP is certainly concerned about
being a steward of the federal dollar and doesn’t want to waste
money in any way. He said that the program would look toward
"the best answer in the end, so we don’t have to do things
over again," and therefore it would be flexible with respect to
designing and building systems that come as close as possible to
achieving "whatever answer they come up with."
Mr. Schlesinger inquired about obtaining reports
on the perchlorate studies that were conducted in 2000 and 2001. Mr.
Walsh-Rogalski replied that the EPA document that’s currently out
for external peer review, and can be found through a "Google"
search on the web, refers to the actual studies and is itself very
useful in terms of providing a good background on the development of
the 1 ppb number.
Mr. Schlesinger then asked whether the recent
guidance means that EPA is recommending that the Bourne Water
District resume operating the production wells that it shut down.
Mr. Walsh-Rogalski said that he doesn’t think he can provide an
answer to that right now. Mr. Schlesinger then asked whether the
state would be using a more restrictive level. Mr. Pinaud noted that
DEP received the EPA information only yesterday, and since then DEP
and EPA risk assessors have been discussing the issue. He then said
that as of today, the Massachusetts interim drinking water advice
for perchlorate that DEP issued for the Town of Bourne in April
2002, which states that for sensitive receptors the drinking water
concentration is 1 ppb, stands.
Mr. Hugus asked whether the individuals at EPA
who made the decision regarding the guidance for perchlorate are the
same ones who recently decided to lower the clean air standards. Mr.
Walsh-Rogalski replied that he believes the decision was made at the
highest levels of the organization. Mr. Hugus stated that, as a
citizen, he’d like to convey the message to EPA Headquarters in
Washington, D.C., that "we don’t think that making standards
lower is a good idea." He also asked Mr. Gonser to keep in mind
that the first concern of Cape Cod’s citizens is not "saving
federal dollars," but "protecting public health."
Ms. Pepin asked whether the iodine uptake studies
were done on pregnant women. Mr. Walsh-Rogalski replied that the
earlier studies were done on individuals with Graves’ disease, a
thyroid condition that leads to hypothyroidism. The more recent
studies, however, were done on rats, and an uncertainty factor was
applied to the translation of rat numbers to human numbers.
Ms. Hayes requested a copy of the "Status of
EPA’s Interim Assessment Guidance for Perchlorate" document,
and Ms. Dolen provided Mr. Gonser with a number of copies to
distribute among the IART members.
Mr. Judge questioned whether the head of EPA
would be held accountable in the event that this recent decision is
found to have compromised public health. Mr. Walsh-Rogalski replied,
"From a legal perspective, I don’t think so – morally,
maybe…" Mr. Judge asked whether "that person’s
boss" would then be held accountable. Mr. Walsh-Rogalski
replied that he’s "not here to defend Headquarters" as
that is something he does not do. He also explained, however, that
EPA makes decisions based on risk analyses all the time. These are
always risk management decisions – not decisions to reduce risk to
zero, but to identify an acceptable level of risk.
Mr. Judge asked whether members of the public
could submit comments to the decision-makers at EPA regarding the
recent perchlorate guidance document. Mr. Walsh-Rogalski replied
that comments could be submitted, and added that he thinks the
public would want to submit comments to those who came out with the
recent guidance document, as opposed to those who wrote the external
peer review document, which is more of a scientific document.
At this time, Mr. Cambareri requested that his
name be added to the sign-in list for the December 10, 2002 IART
meeting minutes.
Agenda Item #3. Demolition Area 1 RRA/RAM for
Groundwater
Mr. Hill stated that this presentation kicks off
the informal public comment period on the Demolition Area 1 (Demo 1)
RRA/RAM plan for groundwater. He noted that individuals can comment
on the plan this evening by speaking into one of the audience
microphones, or they can provide comments through other mechanisms,
including the IAGWSP web site, until February 11, 2003. Mr. Hill
also mentioned that Mr. Applebee and Ms. Weeks are available to help
answer questions after the presentation.
Mr. Hill noted that Demo 1 is a historic training
range on Camp Edwards, where activities included the destruction of
various types of unexploded ordnance (UXO), as well as training in
the use of explosive ordnance. He showed an aerial photograph of the
site, pointed out the "cratered area" at the bottom of the
natural depression, and noted that the Army’s soil investigations
have led to the discovery of a fair amount of explosives and other
compounds in and around that depression. Mr. Hill reported that
extensive geophysical surveys conducted at the site showed thousands
of magnetic anomalies, most of which are interpreted to represent
"kick-out" from demolition activities. He noted that there’s
evidence that burning occurred at the site, which was a common
disposal practice for items that were obsolete or had otherwise
expired. In addition, from time to time the state police brought
loads of fireworks to the site for burning. Mr. Hill stated that
dissolution by rainfall resulted in the leaching of some of these
compounds into the groundwater, where the contamination continues to
migrate coincident with the regional groundwater flow, in a
west/southwest direction.
Mr. Hill reported that to date, by the use of 91
monitoring wells in 33 locations, detectable contamination within
the plume has been tracked 8000 feet downgradient. The IAGWSP is in
the process of finishing that investigation and currently is
drilling the third well of the farthest downgradient well fence. He
noted that perchlorate was detected in profile samples at less than
0.5 ppb in the southernmost of those wells, monitoring well 252
(MW-252). He also reported that a first-time perchlorate detection
occurred recently in the middle screen of MW-214, at a concentration
of less than 1 ppb.
Mr. Hill then recounted the recent history of the
Demo 1 project. He stated that in October 2001, coincident with the
submittal of the Army’s Draft Demo Area 1 Feasibility Study
document, field data were becoming available that indicated that
contaminant concentrations in what was then thought to be the distal
portion of the plume actually were increasing rather than
diminishing. Also, it began to be recognized that perchlorate, in
addition to Royal Demolition Explosive (RDX), was a constituent of
concern at the Demo 1 plume. The Army, the regulators, and the IART
reached consensus to suspend further work on the feasibility study
until more complete delineation of the plume. As the delineation
effort proceeded, field data showed perchlorate being detected
farther and farther downgradient, and the Army became more attracted
to the idea of an interim action for this plume.
Mr. Hill stated that by spring of 2002 the IAGWSP
had proposed a number of locations where such an action might occur,
and together with the regulators and the IART, two locations were
selected. One location is in the vicinity of Frank Perkins Road,
which more or less bisects the plume. That system is intended to
head off the majority of the mass of the plume, which resides
upgradient of Frank Perkins Road, and prevent it from migrating into
the extensive wilderness area that lies to the west. The second
location generally was intended to involve pumping at or near the
toe of the plume, depending on where the investigation determined
that toe to be. The RRA/RAM plan that was sent out to IART members
last week notes that the proposal is for the downgradient portion of
the interim action to occur along Pew Road.
Mr. Hill explained that the interim action is
referred to as an RRA/RAM because it combines the term "Rapid
Response Action" from the EPA administrative orders, with the
term "Release Abatement Measure," from the Massachusetts
Contingency Plan (MCP).
Mr. Hill noted that the practical considerations
that went into selecting the two locations included ease of access,
which is one of the main reasons why the systems are located along
roadsides, and minimal ecological impacts, because construction
would occur in areas that already had been impacted. He also noted
that at the Pew Road location, there’s a symmetry to the plume
that lends itself to capture by a single extraction well. Mr. Hill
then stated that both locations would have stand-alone systems.
Mr. Hill reported that the Frank Perkins Road
system will involve a single extraction well pumping approximately
200 gallons per minute (gpm), from which the extracted water will be
piped to a treatment plant on the north side of the plume. That
plant will involve the use of a fluidized bed reactor (FBR), which
is a biologically active treatment vessel that’s been shown to be
effective at destroying perchlorate as well as explosives. To
address concerns about the reintroduction of alien bacteria into the
aquifer, and as indicated by some treatability studies conducted on
water from the Demo 1 plume, a carbon polishing unit will be added
to the lag end of the treatment train in order to optimize
efficiency of the plant. The treated water will be reintroduced to
the aquifer at two reinjection wells – one on the north side and
one on the south side of the plume. Mr. Hill stated that
approximately 85% of the total plume mass resides upgradient of
Frank Perkins Road; therefore, this component of the RRA/RAM is
fully expected to become part of the final remedy selected after
completion of the feasibility study.
Mr. Hill stated that perchlorate is the only
plume constituent in the area of the proposed Pew Road system. He
also reported that the Army is proposing to dovetail the remediation
aspects of this component of the plan with some treatment technology
evaluations aimed at better informing the feasibility study. These
evaluations will look at different forms of granular activated
carbon (GAC), as well as field testing of some ion exchange resins.
Mr. Hill said that the Pew Road system would involve a single
extraction well pumping at a rate of 100 gpm.
Mr. Hill also mentioned that while the RRA/RAM
plan contains information about a fixed-foundation treatment plant,
the IAGWSP also is looking into a technology that would lend some
portability to the treatment plant such that it could be transported
from extraction well to extraction well. He noted that this is
another aspect that will be considered in conjunction with the Pew
Road component of the RRA/RAM plan.
Mr. Hill then showed a schedule for the RRA/RAM
plan and noted that because implications of the research and
development aspects of the Pew Road component are a little bit
uncertain at this point, the schedule speaks primarily to the Frank
Perkins Road component. He noted that barring any show-stopping
issues, it’s expected that the RRA/RAM plan should be finalized by
the end of April 2003, and that construction should start in June
2003, with system start-up occurring in November 2003. Mr. Hill said
that it’s thought that the schedule for the Pew Road component
will lag by a number of months, but that there won’t be an
extensive separation in the schedules.
Discussion
Mr. Walsh-Rogalski asked Mr. Hill to identify
where the movable remedy would be implemented. Mr. Hill referred to
the map and pointed out the treatment plant location. He also
explained that rather than a fixed foundation, the idea would be a
treatment plant that’s skid-mounted on a concrete pad, with the
capability of being moved to different extraction locations. Mr.
Gonser added that if standards change, or if the situation changes,
a portable system would provide the flexibility to do what’s
required.
Mr. Walsh-Rogalski also noted that he’s curious
about Mr. Hill’s having mentioned "that this was a U.S. Army
presentation," when the cleanup is an NGB project. Mr. Gonser
explained that, as discussed with Mr. Varney last week, the Army is
taking a more active role in the program and "managing it in
response for it’s subordinate elements," which are all part
of the Army. Mr. Walsh-Rogalski noted that the NGB has the legal
obligation to do this work. Mr. Hill said that the new management
structure is similar to what’s seen at the Installation
Restoration Program (IRP), with the Air Force Center For
Environmental Excellence (AFCEE) as the management entity for
various staff members who are with the Air Guard.
Mr. Walsh-Rogalski replied that he believes that
those parties are all respondents under the Federal Facilities
Agreement (FFA). However, the Army is not a respondent under EPA’s
administrative orders (AOs). He then said that for the purpose of
clarity and so that it’s understood that the NGB is fulfilling its
legal obligation, he thinks it would be useful if NGB work were
labeled as such. He also suggested that the Army’s work is
volunteer work because it is not "under any legal obligation to
do anything here right now."
Ms. Pepin noted that it was still unclear to her
which party was responsible for this presentation. Mr. Gonser
explained that the Army and the Guard are both part of the Army
program, and while there may be some legal distinction that needs to
be worked out, the Demo 1 RRA/RAM plan is "everybody’s
plan." Mr. Hill noted that he is with the NGB, he’s the site
manager for the Demo 1 site, and his local management is from the
Army. Ms. Pepin inquired about the roles of Mr. Applebee and Ms.
Weeks, whom Mr. Hill had mentioned at the beginning of his
presentation. Mr. Hill replied that Mr. Applebee is AMEC’s project
manager, and Ms. Weeks, who also works for AMEC, the IAGWSP’s
contractor, is involved in the ongoing technology evaluation
project.
Ms. Pepin also asked about the proximity of base
housing to the proposed Frank Perkins Road system. Mr. Hill replied
that base housing is located south of Connery Avenue, and the Frank
Perkins Road system would be about four or five miles north of
Connery Avenue.
Ms. Pepin then inquired about the FBR technology.
Mr. Hill replied that the FBR is considered a relatively innovative
technology, and while there aren’t many proven technologies that
are effective in treating perchlorate, at some industrial sites in
California FBR technology has been implemented specifically for the
treatment of perchlorate, and been shown to be very effective. In
addition, a treatability study was conducted on water from the Demo
1 plume, and the FBR proved to be effective. Mr. Hill then noted
that the FBR also would degrade explosives, but not as quickly as it
degrades perchlorate. Therefore, either a very large FBR would be
required in order to accommodate a flow rate through the plant, or
else follow-up GAC treatment would be required to address the
remaining explosives contamination.
Ms. Weeks added that the study done at Frank
Perkins Road involved water from MW-114, which had perchlorate
concentrations of approximately 100 ppb and RDX concentrations of
approximately 190 ppb. She noted that the FBR was very successful in
totally destroying the perchlorate, and it reduced the RDX
concentrations down to about 1 ppb.
Ms. Pepin also mentioned the concern about alien
bacteria being reintroduced into the environment. Mr. Hill said that
it’s his understanding that the bacteria that degrade perchlorate
exist in the natural environment, but it’s a concentrated
community of these bacteria that exists in the reactor vessels. Ms.
Weeks agreed and explained that the bacteria are referred to as
"alien" because they would be within the FBR and then
reintroduced into the environment. She assured the group that these
bacteria could be found anywhere – no new bacteria are being
manufactured or genetically engineered. She also said that the FBR
probably will be "inoculated" with bacteria brought in
from a wastewater treatment plant or a similar source. Ms. Pepin
inquired about the names of the bacteria. Ms. Weeks named the
following genera to which those bacterial species belong: Desulfovibrio,
Enterobacter, Alcaligenes, Streptomyces, Clostridium, Rhodococcus,
and Pseudomonas. She also said that she’s heard at conferences
throughout the country that Dechloromonas and Dechlorosoma
are best suited toward degrading perchlorate.
Ms. Pepin asked if it’s correct that carbon
polishing is expected to take care of any leftover bacteria. Mr.
Hill clarified that a sand infiltration unit located between the two
treatment media should knock out any residual bacteria that escape
from the reactor vessel, while dissolved explosives compounds would
sorb onto the carbon in the polishing unit.
Ms. Pepin asked Mr. Hill to explain why the
schedule doesn’t apply to the Pew Road component of the plan. Mr.
Hill explained that the technology evaluations are going to build
upon one another; therefore, it’s premature to put a fixed
schedule on this part of the plan until those study results are
available. He also said that he considers the design of a compact
portable treatment plant to be more of a "wildcard" in
terms of affecting the schedule, than the treatment media evaluation
would be.
Mr. Schlesinger noted that the RRA/RAM plan
refers to an AMEC document called "Final Innovative Technology
Evaluation Groundwater Study Treatability Study Summary –
Fluidized Bed Reactor/Camp Edwards, MMR, Cape Cod/November
2002." He then asked if copies of this document could be made
available to IART members. Mr. Hill replied that copies could be
provided to the team, and he believes that copies already have been
provided to the regulators. He also noted that that particular
project was not a requirement under the administrative orders, but
one that the IAGWSP has been doing out of its own volition, and, as
such, it’s been one of the first to suffer when another priority
emerges.
Mr. Schlesinger asked whether information from
the fate and transport study figures into the interim action at Demo
1. Mr. Hill noted that the main thrust of the fate and transport
study has to do with leachability and the strength of source that
results in groundwater contamination. While these concerns don’t
have immediate bearing on the interim action as such, they might
have bearing on the feasibility study, which would look at cleanup
within 10 years, and therefore be concerned with the residual source
strength in the vadose zone following soil excavation.
Mr. Schlesinger also noted that the RRA/RAM
document doesn’t specifically say whether GAC will treat other
contaminants of concern (COCs) in the Demo 1 plume, such as High
Melting Explosive (HMX) and trinitrotoluene (TNT), which might not
be completely degraded in the FBR. Mr. Hill replied that the COCs,
if left long enough in the FBR, would be completely degraded there.
The polishing unit, however, is added to the treatment train in
order to expedite treatment of the COCs.
Mr. Schlesinger also noted that the RRA/RAM
document mentions that steps would be taken to minimize problems
with clogging of screens on the injection wells for the Frank
Perkins Road system. He asked what those actions would be. Mr.
Applebee replied that sand filtration, as well as ensuring that
settling of fine particles occurs throughout the process, would be
actions taken to help minimize any problems. He also noted that the
injection wells could be back-washed during the process, but added
that the full design of these components hasn’t yet been
completed.
Dr. Stahl asked Mr. Hill to repeat the
information about RDX detections at MW-252. Mr. Hill replied that
these were unvalidated profile detections in two intervals, at
concentrations less than 1 ppb. Dr. Stahl inquired about the depths
of these detections. Mr. Applebee clarified that in fact these were
perchlorate detections, not RDX, and they occurred at 6 feet below
the water table and at 36 feet below the water table, at
concentrations less than 0.5 ppb. Dr. Stahl noted that the figure
indicates that RDX was detected there. Mr. Hill acknowledged that
this was an error on the figure.
Dr. Stahl said that he assumes that a model was
run with the proposed treatment regime, and he inquired about
drawback beyond Frank Perkins Road. Mr. Hill replied that using the
road as a benchmark, and pumping at 200 gpm, the capture zone would
extend downgradient as well as upgradient some distance. Dr. Stahl
noted that he didn’t see any capture zone depictions in the RRA/RAM
document, and he wonders about that because the 2-ppb RDX plume
extends a fair distance beyond Frank Perkins Road. Mr. Hill
mentioned that the person who did most of the modeling is in
attendance tonight, should Dr. Stahl want to ask more specific
questions.
Dr. Stahl also asked whether there’s been any
discussion about tying the Pew Road system into the FBR at Frank
Perkins Road system to remove perchlorate, if needed. Mr. Hill
replied that while this approach is not out of the realm of
possibility, it probably wouldn’t be the first option. He said
that the program is looking to determine what the best treatment
medium is for the low concentrations of perchlorate being seen in
the Demo 1 plume, and elsewhere on Camp Edwards.
Mr. Hugus remarked that only two extraction wells
for a plume that’s 8000 feet long and 1000 feet wide doesn’t
seem like enough. Mr. Hill replied that this is an interim action
and it’s believed that those wells will be part of any ultimate
remedy, which could involve additional extraction wells. He also
said that once there’s concurrence that the plume delineation is
complete, the process would resume through the feasibility study. He
noted that the draft revised Demo 1 Feasibility Study is scheduled
to be submitted in September 2003.
Mr. Hugus stated that from his point of view, an
interim action is being implemented because it would have taken
"forever" to get to a final action by going the full
feasibility study route. He said that he it thinks that the current
proposal "is really what we’re going to get," so he
believes that the job should be done correctly now. Mr. Hugus
reiterated that he thinks that two wells are inadequate for a plume
of this size. Mr. Hill stated that the interim action is not
intended to prejudge the ultimate remedy. Mr. Hugus questioned why
it wouldn’t make sense to try to make the interim action the
ultimate remedy by installing enough extraction wells to take care
of the problem. Mr. Hill noted that part of the feasibility study
process involves soliciting input from other stakeholders, some of
whom are more concerned about the habitat than the groundwater. He
also said that there are many stresses on the aquifer and it’s not
as easy at it might seem to "start pumping lots of water."
Mr. Hugus said that his point is that he finds it
unacceptable to put an extraction well upgradient of the toe of the
plume because he thinks the entire plume needs to be captured. Mr.
Hill explained that an extraction well located in the midst of the
advection front of the plume, where fingering typically occurs,
would mean pumping a lot of clean water along with the contaminant.
In areas like that, with the concentrations that are being seen
there, an extraction well would end up moving a lot of water, but
with nothing detectable in the influent at the treatment plant.
Ms. Hayes inquired about Mr. Hill’s level of
confidence that the RRA/RAM schedule can be met. Mr. Hill replied
that while it’s very aggressive, and things would have to proceed
swiftly in order to accommodate it, the schedule is achievable.
Mr. Judge asked how much of the plume is expected
to be lost beyond Pew Road. Mr. Hill noted that while the definition
of the plume hasn’t yet been determined, his "total
guess" is that it would be less than 1% of the mass. He also
noted that more than 85% of the mass occurs upgradient of Frank
Perkins Road. Mr. Judge stated that no matter how small the
percentage that’s lost, it should be reported to the NRTC so that
a proper assessment of damages can be done.
Mr. Judge also said that he’s interested in
learning more about portable treatment plants, and noted that he was
quite involved in overcoming resistance to securing the use of a
portable contained detonation chamber (CDC) at MMR. He said that he’d
like to know about the effectiveness of a portable system, as well
as the money-saving aspects of such a system. He also acknowledged,
however, that a portable system wouldn’t be appropriate for plumes
with extended cleanup timeframes.
Dr. Feigenbaum said that he thinks that this
project getting started is a "pretty important and auspices
occasion," especially given all the past acrimony and argument
over this interim action. He offered his congratulations to the
Guard and to the agencies. He also acknowledged the Army’s recent
involvement and said that he thinks it’s important that the Army
not "slip and slide in and out of this project" whenever
it wants to. He stated that if the Army can absorb the role of
respondent, he thinks it should do so formally so that it’s
understood where everybody stands.
Dr. Feigenbaum then said that he sees no evidence
that extraction well D1-1 (EW-D1-1) would span the entire plume. Mr.
Hill replied that the proposed pumping rate at that well would be
adequate to capture the width of the plume, but not at Frank Perkins
Road. The capture zone wouldn’t propagate north/south at the
longitude of Frank Perkins Road, but would capture the width some
distance upgradient of the road. Dr. Feigenbaum suggested that it
might be a good idea to "get those extraction wells outside to
kind of pinch the plume." Mr. Hill noted that the reinjection
wells are designed with that in mind. Dr. Feigenbaum asked when the
team could expect to see some specifics and modeling. Mr. Hill
replied that the IAGWSP would be sharing information with the team
as progress is made. Dr. Feigenbaum also asked if, in addition to
the design work, AMEC would be doing the construction work as well.
Mr. Hill replied that it would.
Dr. Feigenbaum then commented that it seems like
the leading edge has just been forgotten. Mr. Hill disagreed with
that opinion, and also said that pumping at a leading edge that’s
defined at the detection limit would mean being "overwhelmed by
clean water." He also mentioned that perchlorate was detected
in MW-225, and while it’s not known exactly how far downgradient
the perchlorate is, that is a wild area that doesn’t lend itself
to drilling activities, which is why further drilling was done along
the power line. He then noted that the perchlorate detection at
MW-252 occurred in a profile sample, not a bona fide monitoring well
sample.
Dr. Feigenbaum questioned whether in fact the
leading edge would be located. Mr. Hill replied that the IAGWSP and
the agencies need to come to concurrence on whether to proceed now
with the feasibility study or continue the effort to define the
leading edge. He also noted that his opinion is that the plume is
defined enough to move forward. Dr. Feigenbaum pointed out that a
year ago it was argued that an interim action shouldn’t be taken
until the leading edge is defined, and now the interim action is
moving forward and "we may give up on ever nailing down the
leading edge."
Mr. Pinaud noted that the Frank Perkins Road
system involves a conceptual piping layout on a tank trail. He then
asked whether that trail is a hardened surface. Mr. Hill replied
that it is not. Mr. Pinaud recommended that consideration be given
to putting that piping run on Frank Perkins Road, where heavy
vehicles aren’t allowed to drive.
Mr. Pinaud asked if it’s correct that there’s
no schedule at this point for implementation of a toe extraction
system, whether it’s at Pew Road or some other location. Mr. Hill
replied that installation of an extraction well will be a precursor
activity, and the type of treatment facility to which that well is
plumbed will be the subject of the technology evaluations. He noted
that that extraction well will be used as a source for water to run
the ion exchange studies, and he mentioned that the carbon studies
are intended to be conducted in a laboratory. Mr. Pinaud asked if it’s
correct that a treatment system might not be constructed for some
time. Mr. Hill replied that it remains to be seen what the treatment
system will contain and what it will look like.
Mr. Pinaud stated that DEP is concerned that the
IAGWSP might be missing an opportunity to capture the plume down at
the toe. Mr. Hill replied that he doesn’t think that the
opportunity would be lost. He noted that the road at the power line
is "one intersection you can look at," and there’s
another road downgradient, which might be considered, depending on
how the cleanup standard issue is resolved. Mr. Pinaud asked when
the regulators could expect to see a schedule for the treatability
studies. Mr. Hill replied that the technology evaluation contract
currently is being negotiated. Then, a schedule for the treatability
studies will be developed, and from that a timeframe for follow-on
activities will be inferred.
Mr. Pinaud asked whether there’s still a
commitment from the Army to treat the toe of the plume. Mr. Hill
replied that there is, but noted that it’s uncertain at this time
what the toe of the plume might be – for example, it might be a
4-ppb contour, or an 18-ppb contour. He also noted, however that
under the MCP, treatment is evaluated to background, and the
intention is to comply with the MCP as well as the AOs.
Mr. Borci noted that the estimated plume volume
east of the Frank Perkins Road system, based on the perchlorate
plume shell, is 691 million gallons. He said that this is a
significant amount of contamination, and an almost equal amount
exists downgradient of that point. He also stated that overall EPA
thinks that the RRA/RAM is a quality plan, although there are some
questions.
Mr. Borci then clarified that the Frank Perkins
Road extraction well is not intended to be a cutoff well; therefore,
it’s expected that some contamination will pass beyond that well.
He said that EPA also has questions about placement of a toe
extraction well. And he mentioned delays because of the carbon
tests, and noted that he has a report that compares costs for an FBR
system versus a straight carbon system, which requires more frequent
maintenance by way of carbon change-outs than the type of
maintenance that an FBR system requires. Mr. Borci explained that it’s
being questioned whether it’s really necessary to go through the
technology evaluation, which might result in delays. He also said
that the concept has been that the entire system, not just one part
of it, would be turned on in November 2003.
Mr. Borci also made a point of noting that the
feasibility study process is ongoing and although some people might
"think that this is all you’re going to get," the AOs
require that more robust remedies be proposed, including a remedy
that addresses the problem within 10 years. He said that the Draft
Demo 1 Feasibility Study for Groundwater should be coming out by the
end of this year, and he asked the team members not to lose sight of
the fact that they’ll be talking about the long-term remedy.
Dr. Dahmani stated that he thinks that
pump-and-treat is the right approach for this plume. He also asked
whether the FBR has been tested at the bench-scale level. Ms. Weeks
replied that two sites where the FBR was tested are the Aerojet
facility in Rancho Cordova, California, and the Longhorn Army
Ammunition Plant in Karnack, Texas. She explained that at these
sites very robust laboratory studies were conducted, the results of
which were used to design full field-scale implementations. She also
noted that FBR systems have been operating successfully for two or
three years at these sites. Dr. Dahmani said that he expects that
the system would be monitored and optimized. He also asked whether
there would be future presentations about the system. Mr. Hill
replied that that is the intention.
Mr. Cambareri asked whether there would be a
future presentation on the modeling associated with these systems.
Mr. Hill replied that this type of presentation would occur closer
to design, when there’s better resolution on capture zones and the
like. Mr. Cambareri also questioned whether a single 80-foot
screened extraction well at Frank Perkins Road would draw evenly
throughout the thickness of the plume. Mr. Hill replied that the
system would be evaluated. He also noted that once pumping begins,
system performance would be evaluated, as would any required or
recommended modifications.
Dr. Stahl asked whether the capacity factor is
being taken into account in terms of modeling and engineering. Mr.
Hill replied that it is, and stated that the treatment plant will be
designed with expandability in mind.
Dr. Feigenbaum noted that some issues are being
framed in terms of "the Guard intent," but he thinks that
the emphasis should go to "in accord with the administrative
orders and the Safe Drinking Water Act, because that’s the guiding
way for this project."
Mr. Dow asked whether there’s an interim action
plan to deal with contaminated soil at the Demo 1 source area. Mr.
Hill replied that there is, and noted that the RRA/RAM for Demo 1
Soil will be presented at next month’s IART meeting. Mr. Dow asked
if it’s correct that the groundwater and source area cleanups will
occur more or less simultaneously. Mr. Hill replied that it is.
Ms. Crocker requested that every effort be made
to drill no more than is needed and advisable, as she believes that
a great deal of land throughout Camp Edwards already has been
damaged unnecessarily. She also said that the perchlorate standards
that have been used at MMR have seemed overly cautious to many
people. She then questioned whether continuing to use a 1.5-ppb
standard at MMR, rather than the 4-18 ppb range, wouldn’t really
be "an insubordination to the highest levels of the
decision-making…"
Mr. Seaver stated that perchlorate’s status as
a carcinogen is an issue that continues to be raised. He noted that
the Cape Cod Times has referred to it as a carcinogen, and
EPA frequently does too. He then noted that the National Institutes
of Health (NIH) web site contains a report that lists about 1000
known and possible carcinogens, and perchlorate is not among them.
He also noted that Dr. Zoeller of the Institute for Science and
Interdisciplinary Studies at UMASS Amherst and Hampshire College,
who was a member of the review committee that looked at interim
standards for perchlorate, said, "Perchlorate is not a
cancer-causing agent…" Mr. Seaver said that he thinks that
the references in the literature and on the web that perchlorate is
not a carcinogen should be respected.
Mr. Borci said that he wants to clarify that the
Pew Road system is a 4-ppb remedy. He noted that the concentrations
at the proposed extraction well location have been and are currently
3 ppb, and it’s reasonable to assume that the area immediately
upgradient has 4-ppb concentrations. Mr. Borci said that the
question is whether the best location is based on technical
practicability. He also said that he wouldn’t want to hear two
months from now that the design needs to be restructured toward a
4-ppb remedy, because "what you see in front of you does
that." Mr. Walsh-Rogalski asked whether the IAGWSP also views
the Pew Road system as a 4-ppb remedy. Mr. Gonser replied that he
doesn’t disagree with Mr. Borci’s analysis. Mr. Walsh-Rogalski
asked if it’s correct that the public would be commenting on a
remedy that’s not going to change, six months from now, for
instance. Mr. Gonser replied that he wouldn’t anticipate a change.
Mr. Skelly noted that an extraction well ahead of
the toe would pull the contamination down towards it, and he thinks
that the well should be installed at the proposed location because
it would slow migration of the toe. He also suggested installing an
injection well ahead of the toe to help reverse the flow of
contamination.
Mr. Judge stated that right now it really isn’t
known where the toe of the plume is located. He said that if EPA
ultimately establishes a 1-ppb standard for perchlorate, it would be
very important to know where that toe is.
Mr. Schlesinger said that he finds it confusing
that Mr. Borci and Mr. Walsh-Rogalski were talking about a 4-ppb
solution, yet the state holds the program to a 1.5-ppb or 1-ppb
standard for perchlorate. Mr. Borci clarified that DEP provided the
Town of Bourne with specific guidance pertaining to the situation in
the Monument Beach wellfield. He also explained that, as it
currently stands, the interim action at Demo 1 is going to treat
groundwater starting at 3 ppb for perchlorate. The technical issue
that needs to be examined is whether moving the extraction well
farther downgradient would mean pumping too much clean water.
However, it should be understood that the interim action at Pew Road
is designed to clean up to 4 ppb. He also noted that if the standard
for perchlorate turns out to be 1 ppb, but that decision isn’t
made in time for the interim remedy, that issue would be addressed
as part of the feasibility study process this fall. Mr. Gonser added
that basically the point is that this is a good place to start for
remedial action, with further discussion to occur during the
feasibility study process.
Mr. Mullenix asked whether it’s correct that
the FBR is designed to treat perchlorate to a level of less than 1
ppb. Ms. Weeks confirmed that this is correct, but noted that it’s
not yet certain which type of treatment technology will be used at
the toe.
Ms. Garcia-Surette asked whether sufficient
funding had been programmed for whatever technology is chosen for
the toe. Mr. Hill replied that the program has the necessary funding
to implement both the Pew Road and the Frank Perkins Road components
of the RRA/RAM. Mr. Gonser added that this project is the IAGWSP’s
priority.
Agenda Item #4. Review Responses to Action
Items from December 10, 2002 IART Meeting
Mr. Hugus referred to Action Item #2, and asked
when the perchlorate plume at the Monument Beach area would be
mapped. Mr. Gregson replied that while he can’t provide a specific
date, the IAGWSP is working on that plume map and today presented a
version to EPA, DEP, and the Bourne Water District’s consultant.
Mr. Hugus indicated that he thinks it’s very important that the
public has a visual representation of that contamination, which led
to the shutdown of a significant percentage of Bourne’s water
supply.
Mr. Hugus referred to Action Item #4, and asked
whether the estimate of contaminated groundwater pertains to just
the Central Impact Area plume or to all plumes associated with the
Impact Area. Mr. Gregson clarified that the estimate pertains just
to the Central Impact Area plume itself.
Mr. Hugus also referred to Action Item #11, his
request that EPA Regional Administrator Robert Varney attend an IART
meeting. He noted that last week Mr. Varney met privately with
representatives of the Guard and the Army, and he feels that Mr.
Varney also should hear the citizens’ point of view on issues such
as the Army audit’s recommendation that the management structure
of the IAGWSP needs to be changed. Mr. Murphy noted that he had
conveyed Mr. Hugus’s request to Mr. Varney, who initially planned
to attend the March IART meeting. As it turns out, however, Mr.
Varney can’t make that meeting, but intends to attend another IART
meeting in the near future.
Mr. Schlesinger noted that the estimate of
contaminated groundwater in the Central Impact Area plumes refers
only to RDX, but there are other COCs there that he believes should
be included in that estimate. He also referred to Action Item #13
and asked why Mr. Mullenix was denied membership in the IART, and
whether Mr. Mullenix would be able to apply again – and if so,
when. Mr. Murphy replied that he’s been directed by Mr. Varney to
conduct an outreach effort to find citizens of Bourne who would be
interested in being considered for membership on the IART. He noted
that Mr. Mullenix had communicated to Mr. Varney the point that
currently there is no citizen representation from Bourne, which is a
void on the team. Mr. Murphy said that Mr. Mullenix’s application
for membership would be reconsidered along with any new applications
that come in as a result of EPA’s outreach effort.
Mr. Judge inquired about the nature of
communication between Mr. Mullenix and Mr. Varney. Mr. Murphy said
that Mr. Mullenix wrote to Mr. Varney, but he doesn’t think that
Mr. Varney has written back as yet. Mr. Judge explained that he’s
wondering whether the IART should write a letter to Mr. Varney to
ask him to attend a future IART meeting. Mr. Murphy assured Mr.
Judge that Mr. Varney intends to attend a future meeting. Mr. Judge
asked that Mr. Murphy convey to Mr. Varney that he, and perhaps
other members of the IART, are extremely disappointed that Mr.
Varney didn’t meet with the entire IART, rather than just those
select parties with whom he met last week, when he "may not
have gotten a balanced presentation." Mr. Murphy agreed to
convey this message to Mr. Varney.
Mr. Judge also referred to Action Item #3,
regarding the request for an update from the NRTC and stated,
"We’re looking for Bruce Leighton to come and do a
presentation to this board here." He said that he thinks Dale
Young is great, "but she’s not a voting member of the NRTC."
Ms. Grillo clarified that the Commonwealth of Massachusetts is a
trustee and co-lead on the NRTC because the Secretary of
Environmental Affairs, which had been Bob Durand and is now Ellen
Roy, is the trustee for the groundwater of the Commonwealth. She
explained that Mr. Durand had designated Ms. Young, who is the
director for NRTC activities for the Commonwealth, as his
representative on the NRTC. Ms. Grillo confirmed that Ms. Young is a
voting member and a co-lead on the NRTC. She further noted that the
other co-lead, the Air Force, has taken on the administrative
responsibilities for the NRTC, and Mr. Leighton was the first person
designated with that responsibility.
Mr. Judge repeated his request for Mr. Leighton
to address the IART, especially since Mr. Leighton is "in
charge of the money end of the game." He said that the damages
that are awarded by the NRTC will be used for environmental
reclamation purposes on Cape Cod, and he thinks that that money will
be in the billions of dollars, and could be used toward solving the
problems that the Cape is having with nitrates in the water from
septic systems.
Mr. Minior clarified that Mr. Leighton is not
currently the designated trustee representative of the Secretary of
the Air Force. He noted that Henry Byers has taken over that role at
this time, while Mr. Leighton is fulfilling other duties in San
Antonio, Texas. Mr. Minior also reported that yesterday the NRTC
issued a news release containing information about some recent
progress made at a meeting last week in terms of future activities
the Council plans to undertake in order to resolve the Preliminary
Assessment Screen (PAS) document by the end of this April.
Mr. Judge stated that he then wants Mr. Byers to
update the IART on NRTC activities. He said that he thinks it’s
very important that the NRTC process be transparent to the public,
especially with respect to considerations such as "what is a
pollutant and what is not a pollutant" and "what is making
the Cape whole and what is not."
Mr. Gregson referred back to Mr. Schlesinger’s
comment on Action Item #4, and explained that there aren’t any
mappable plumes for COCs other than RDX in the Central Impact Area.
He also said that, as noted in the action item response, the IAGWSP
is in the process of defining and mapping the extent of perchlorate
contamination. He further noted that perchlorate is the only
propellant that’s been detected there. Mr. Borci stated that the
greatest extent of contamination at the Central Impact Area is from
RDX. He also mentioned that the contaminated groundwater estimate
from 2001, as noted in the action item response, would be updated at
some point.
Ms. Hayes referred to Mr. Mullenix’s request to
join the IART, and asked whether it would be possible to ask Mr.
Varney to provide the acceptance criteria he uses when considering
new membership applicants. She explained that she thinks it would be
appropriate for individuals who are interested in joining the team
to at least know whether they are going to meet those criteria. She
also said that she doesn’t think it’s good public relations to
invite someone to volunteer to serve on the team and then reject
him. Ms. Hayes said that if interested individuals were informed
about the requirements for membership, no one’s time would be
wasted. Mr. Murphy said that he would bring this request back to Mr.
Varney. Ms. Hayes also asked if there had ever been an IART member
from Bourne. Mr. Minior replied that the IART member from Bourne had
died. Ms. Hayes repeated her request for the acceptance criteria so
that "people don’t waste their time or ours, and they don’t
face rejection inappropriately."
Mr. Cambareri stated that the previous
representative from Bourne had been his friend, Dick Prince. He also
said that he hadn’t received the sampling results from the Bourne
landfill monitoring wells. Mr. Murphy noted that those results were
attached to the action item response document.
Mr. Cambareri then stated that calculating areas
of contaminated groundwater could be "very objective
science." He noted, for example, that while a 50-foot thick
plume in a 100-foot thick aquifer might technically be the
contaminated piece of aquifer, its presence there likely affects the
availability of other parts of the aquifer for water supply. He
mentioned the IRP’s policy of offering water hookups to residents
whose homes are within a certain buffer zone of a defined plume. Mr.
Cambareri suggested that two calculations might be appropriate when
looking at volume of contaminated water – the actual volume of
contaminated water, and the volume of aquifer loss in terms of
potential water supply.
Dr. Feigenbaum said that he thinks it’s
unacceptable that Mr. Varney hasn’t met with the IART, and he
wants Mr. Murphy to draft a letter asking him to do so. Mr. Murphy
replied that he thinks it would be better if someone else wrote a
letter. Dr. Feigenbaum asserted that as the facilitator of the IART,
Mr. Murphy should write the letter. Mr. Murphy agreed to write the
letter. Dr. Feigenbaum also remarked that he thinks it would be
suitable to send a similar letter to Ms. Roy, Secretary of
Environmental Affairs for the Commonwealth.
Mr. Gregson referred to the estimate of
groundwater contamination noted in the 2001 Central Impact Area
Groundwater Report and said that certain assumptions, which are
detailed in that report, were made when arriving at that estimate.
He explained that it’s a complicated area in that it involves not
just a single plume, but fingers and multiple areas of
contamination.
Mr. Dow said that he thinks that at one point
Russell Cookingham of Bourne was a member of the IART. Mr. Murphy
replied that he thinks that Mr. Cookingham used to attend IART
meetings frequently, but was not a member at the table.
Mr. Mullenix said that he’d like to thank
everyone who supported his application for membership on the IART.
He noted that he’s lived in Bourne for 11 years, is committed to
the town and its people, has a lot of friends there, and is active
in the community. He also said that because of his background and
education, he’s often asked questions about activities occurring
at the base.
Mr. Mullenix then said that Mr. Murphy called him
this past spring and said that he’d heard that he (Mr. Mullenix)
might make a good addition to the IART. Mr. Mullenix said that, at
Mr. Murphy’s suggestion, he attended a couple IART meetings to see
if he might like to apply for membership. He noted that during those
meetings there was discussion about the perchlorate issue, which
directly affects the Town of Bourne and, specifically, affects the
source of his own water supply. Mr. Mullenix said that he became
more interested in IART membership, submitted his application in
June, and recently was informed that his application has been
rejected.
Mr. Mullenix also said that he appreciated the Cape
Cod Times article regarding his situation, and he has since
received a number of phone-calls from Bourne residents
"offering their support and wondering what happened." He
then said that at this point he’s at a loss. He noted that he’s
asked Mr. Varney by letter why he was not accepted on the team, and
still would like to know the rationale for that decision. Mr. Murphy
said that he couldn’t respond any more than to say that Mr.
Mullenix will be getting a letter from Mr. Varney, in which he hopes
Mr. Mullenix finds some satisfaction.
Mr. Schlesinger noted that when he wrote a letter
asking to become a member of the IART, no one told him that other
Sandwich residents were being solicited and he had to vie for the
position. He said that this may be something new with the current
EPA Regional Administrator, but it didn’t occur when he applied
for IART membership.
Agenda Item #5. Investigations Update
New Areas - Recent Detections
Mr. Gregson referred to a map entitled
"Northwest Corner of MMR" and reported that perchlorate
was detected in well 4036009, located on U.S. Army Corps of
Engineers (USACE) property next to the Cape Cod Canal. He also
pointed out the location of the nearby Schooner Pass well. He noted
that initial sampling at well 4036009 showed a validated 5.3-ppb
perchlorate detection, and follow-up sampling came back with a
validated 6.1-ppb perchlorate detection. Mr. Gregson said that while
it’s not known where the screen is in well 4036009, a particle
track from the bottom of that well ran back to the Central Impact
Area. He also said, "if you take a particle track from the
water table, it’s right near the well," based on the modeling
alone, a possible source of the perchlorate is somewhere between the
well and the Central Impact Area. Mr. Gregson also reminded the
group that the contaminant detected previously in the Schooner Pass
well was RDX, while the contaminant detected in well 4036009 was
perchlorate. He noted that his office is working with DEP and EPA to
look at additional sampling locations in that area to get a better
handle on the source of the perchlorate.
Mr. Cambareri asked if there are any plans to
test the well at the Upper Cape Regional Technical School. Mr.
Gregson replied that there are some mechanical problems with access
to that well, and he believes that the plan is to take a closer look
at the "95" series of wells shown on the map. He also
noted, however, that there will be an effort to do a repair on the
irrigation well at the school so that a sampled can be collected.
Mr. Cambareri also asked Mr. Gregson to identify the red dot to the
east on the map. Mr. Gregson identified that location as gun
position 16 (GP-16), where perchlorate also has been detected.
Mr. Hugus noted that contamination has now been
detected at two different locations in this area, and he thinks that
anyone on private water supply there should be advised not to use
that supply, and should be provided with an alternate water supply.
He noted that the residents of the Schooner Pass development
continue to use water from their supply well.
Mr. Judge asked if it’s correct that the Upper
Cape Regional Technical School’s irrigation system draws water
from that area. Mr. Gregson said that he believes that the school’s
irrigation well is broken down and hasn’t been used in a while. He
also noted that for drinking water supply, the school is on town
water. Mr. Judge said that he’s glad to hear that the school’s
irrigation system isn’t working because otherwise it might be
pumping up that contamination and dispensing it on the grass. He
then asked whether the school was notified of the recent nearby
perchlorate detection. Mr. Gregson replied that he’s not sure, but
will make certain that the school is informed. Mr. Judge also
inquired about the party responsible for keeping the Schooner Pass
residents informed about detections in their well. Mr. Gregson
replied that as provider of water supply for that community, it’s
up to the water supply manager at Schooner Pass to keep his
customers informed.
Mr. Murphy asked Mr. Gregson to say who was
notified of the perchlorate detection in well 4036009. Mr. Gregson
replied that his office notified the Town of Bourne, the Bourne
Board of Health, and the USACE.
Mr. Schlesinger inquired about the possibility of
installing a monitoring well upgradient of well 4036009 – perhaps
near the base boundary. Mr. Gregson replied that upgradient
locations on the base boundary, along the particle track, are being
considered. He also noted that this would be part of a larger plan
that the IAGWSP, along with the agencies, is working on. Mr.
Schlesinger also asked whether information about the detection would
be in the newspapers. Mr. Gregson replied a news release was issued
last Friday.
Dr. Dahmani said that in order to have some
comfort about the accuracy of the particle tracking, he thinks the
team should see information about any sensitivity analyses conducted
by the modeler with respect to those particle tracks. Mr. Gregson
noted that there’s a higher level of confidence in particle tracks
in that area of the base because it’s off the edge of the mound,
where groundwater flow direction doesn’t fluctuate as much as it
does near the top of the mound. Dr. Dahmani stated that he thinks it
would benefit the whole team to understand the limitations
associated with the depictions that are modeled. He said that while
he doesn’t think a great deal of detail is necessary, he thinks
that it would be good to know "that you have done this, you’ve
evaluated it, you’ve calibrated it, that you have done the
sensitivity analysis, and based on that, this is what you have come
up with." Mr. Gregson said that he would contact the AMEC
modelers for this information.
Mr. Gregson then referred to a map entitled
"Northeast MMR Boundary" and reported that RDX was
detected in profile samples taken at MW-254, formerly known as KP-2.
He explained that MW-254 was drilled as an offset to MW-18, which
has had fairly consistent detections of RDX at levels between 0.34
and 0.52 ppb. He noted that at MW-254, profile results showed RDX
detections from 0.53 to 1.2 ppb, and screens are being set at those
interval locations. Mr. Gregson then stated that backtracking from
MW-18 goes back to the former K Range, or perhaps as far back as the
J-2 Range. He noted that RDX has not been detected in soil at the
former K Range, and he mentioned that while trichloroethylene (TCE)
also has been detected in MW-18 historically, it was not detected in
profile samples from MW-254.
Mr. Schlesinger referred to the "Northeast
MMR Boundary" map and asked when the detection at MW-215
occurred. Mr. Gregson replied that MW-215 was installed fairly
recently, and is located at the firing point for the former K Range.
He also noted that the detection at that location was RDX and it was
at a level just above the health advisory. Mr. Schlesinger asked if
additional samples from that area are being pursued. Mr. Gregson
replied that additional work is planned or under way for the J-2
Range, a possible source area for that detection at MW-215.
Ms. Adams asked if it’s correct that the zones
of contribution (ZOCs) shown on the map are based on each of the
Upper Cape Water Supply Cooperative production wells pumping 1
million gallons per day (mgd). Mr. Gregson replied that he believes
that is correct. Ms. Adams noted that it’s her understanding that
the three production wells could be increased to pump 4.5 mgd total,
in which case she questions whether MW-254 or the potential source
areas (the former K Range and the J-2 Range) would fall within those
increased ZOCs. Mr. Gregson replied that he couldn’t comment on
this without seeing what those ZOCs would look like.
Mr. Pinaud stated that the Commonwealth approved
the ZOCs and the pumping rate for each of the wells from 1 to 1.5
mgd, for a total of 4.5 mgd. He said that the ZOCs did get a little
bit bigger, and although DEP tried to have that map ready for
tonight, it was unable to do so. Ms. Adams said that she thinks it
would be good to have future maps showing the updated ZOCs.
Mr. Gonser noted that the 4.5-mgd rate is only
for a peak demand day, while the average annual rate is still only 3
mgd. He said that perhaps Denis LeBlanc of the U.S. Geological
Survey (USGS) could shed some light on the immediate impacts versus
long-term impacts; however, it’s his understanding that "the
aquifer doesn’t see short-term changes like that, and so from the
aquifer’s perspective, it would see 3" mgd. Ms. Adams replied
that although that’s a refinement of which she wasn’t aware, she
maintains that contaminants within the larger ZOC could at some time
be drawn into the production wells, and she thinks that the map
should represent that, even if it’s not happening on an average
annual basis.
Ms. Pepin asked that a request for DEP to provide
updated ZOC maps at the next IART meeting be noted as an action
item.
Mr. Judge stated that it’s his understanding
that last week the Senior Management Board (SMB) voted and agreed
that "4.5 mgd was enough," although 10 mgd is the amount
that’s been discussed historically. He also said that given the
situation with the Bourne Water District shutting down some of its
supply wells, it was just lucky that the 3-mgd system was overbuilt
to be a 4.5-mgd system, but he wants to be sure that "that
overbuilt system isn’t the final answer…" Mr. Gonser
replied that he’s not aware that the SMB had determined that
anything beyond 4.5 mgd wouldn’t be necessary. He also said that
he thinks that the potential for the development of additional water
supply exists, although concerns such as impacts to ponds would have
to be taken into consideration.
Dr. Dahmani stated that a ZOC is also a depiction
of a set of values associated with a number of parameters, some of
them sensitive parameters. He said that, again, he would like at
least some indication from the modeler as to what sensitivity
parameters were changed so that the team could have some comfort in
terms of where the ZOCs are. Mr. Gregson replied that the modeling
for the ZOC determination was done outside of the IAGWSP, through a
consultant who coordinated with DEP Water Supply under DEP’s
standard water supply development procedures. He also said that he
thinks DEP could provide a copy of the report and modeling that went
into that effort. Dr. Dahmani said that he thinks the team should
see not just one ZOC, but several, based on the changes made to some
of the important parameters. He noted that he knows from experience
that changing just one of the sensitive parameters by 20 to 30%
could increase the ZOC such that it includes MW-215. Mr. Pinaud
stated that DEP approval was based on a pump test report provided
through the Upper Cape Water Supply Cooperative. He said that he
could obtain a copy of that report for whoever wants one.
Mr. Hugus suggested that the best way to answer
Dr. Dahmani’s questions would be to have a presentation on
modeling. Dr. Feigenbaum agreed, and suggested that Dr. Dahmani put
his questions in writing to ensure that such a presentation would
provide the answers. Mr. Gregson said that he has no objection to
adding this topic to the next IART agenda, or to Dr. Dahmani sending
the IAGWSP an e-mail specifying what he’d like that presentation
to cover. Mr. Borci said that while he agrees this is a worthy
topic, the next IART meeting agenda includes the potentially lengthy
topic of the Demo 1 RRA/RAM for Soil. Therefore, the team should be
aware of the possibility that there won’t be time for the modeling
agenda item at that meeting.
Southeast Ranges – Recent Unvalidated
Detections
Mr. Gregson showed a map entitled "Southeast
Ranges Perchlorate Plume Recent Detections" and reported that
at MW-251, which is located on the northern shore of Snake Pond,
perchlorate was detected at concentrations from 0.37 to 0.53 ppb in
profile samples at three intervals between 95 and 125 feet below the
water table. He noted that well screens are being set at those
locations. He also reported that the first sampling event at MW-239
showed perchlorate at 0.7 ppb, which was consistent with profile
results. He also said that no explosives were detected at location,
nor were they detected at MW-243-M2, where perchlorate was detected
at 1.4 ppb, which also was consistent with profile results.
Agenda Item #6. Adjourn
Mr. Murphy suggested that the IART forego the
review of action items, which would later be e-mailed out to team
members. There were no objections from the team. Mr. Murphy also
announced that the IART would meet next on February 25, 2003 at the
Falmouth Holiday Inn. He then adjourned the meeting at 9:10 p.m.