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Impact Area Review Team Meeting Minutes
Action Items:
Recommendations:
Future Agenda Items:
Handouts Distributed at Meeting:
Agenda Item #1. Welcome, Agenda Review, Approval of January 24, 2006 IART Minutes Mr. Murphy convened the meeting at 6:05 p.m. and the Impact Area Review Team (IART) members and one prospective member at the table introduced themselves. Mr. Murphy reviewed the agenda and then asked if there were any changes to the January 24, 2006 IART meeting minutes. No changes were offered and the minutes were approved as written. Agenda Item #2. Responses to Action Items, Late-Breaking News Mr. Murphy confirmed that no team members were interested in commenting on the Reponses to Action Items from the January 24, 2006 PCT meeting. Perchlorate Update Ms. Jennings reported that on January 26, 2006, the U.S. Environmental Protection Agency (EPA) Office of Solid Waste & Emergency Response (OSWER), which manages the Superfund program, issued new guidance for perchlorate. She distributed copies of the guidance to team members, noted that she'd underlined four "key points," and read the first one: "The RfD (reference dose) and its corresponding DWEL (drinking water equivalent level) of 24.5 ppb (parts per billion) are respectively the recommended TBC (to be considered) value and the preliminary remediation goal for perchlorate." Ms. Jennings said that this first point clarifies how the RfD is supposed to be converted into a DWEL and what that DWEL represents in Superfund language, which is the preliminary remediation goal. Ms. Jennings then noted that perchlorate is a contaminant and should be handled like any other contaminant, and read the second point: "The NCP (National Contingency Plan) provides that 'preliminary remediation goals should be modified, as necessary, as more information becomes available during the RI/FS'" (remedial investigation/feasibility study). She also read the third point that she'd underlined: "…the RI may indicate that individuals at a site may be exposed to perchlorate through multiple pathways. In such cases, contributions from non-water sources should be considered based on site-specific data until further national guidance on relative source contribution is developed." Ms. Jennings said that her office is seeking clarification from EPA Headquarters regarding what additional site specific-information is needed and how it should be applied in the case of the Massachusetts Military Reservation (MMR). Ms. Jennings then referred to the fourth point she'd underlined: "Frequently, the determining values are those requirements that are applicable or relevant and appropriate requirements (ARARs) under federal environmental or state environmental or facility siting laws, although ARARs may be waived." She said that this means that if and when the Commonwealth of Massachusetts promulgates its perchlorate standard, that standard would be considered the ARAR. The EPA guidance on perchlorate would not be controlling, and the state's standard would "trump the whole discussion" of how to interpret the 24.5 ppb guidance. Mr. Schlesinger referred to the third point and said that it's important to know what is meant by site-specific. He also said that he wonders whether testing would have to be done in each state because of varying factors such as "proximity to certain bases and length of activities," and he hopes some clarification is provided. Ms. Jennings agreed that clarification is needed and questioned, for example, whether the expectation is to go to local grocery stores, determine the source of lettuce and milk there, and factor that into the equation. Mr. Schlesinger said that he thinks it would be helpful if the IART could be provided with copies of the article about perchlorate levels in food around the nation that was published in an electronic journal called InsideEPA.com. Mr. Mullennix said that he doesn't understand why there's an emphasis on hoping "that the state somehow trumps EPA's recommended levels." He then read from the EPA guidance: "EPA has determined that the RfD recommended by the NRC (National Research Council) and adopted by EPA represents the best available science regarding the toxicity of perchlorate." He also noted that the guidance clearly explains what the DWEL means with respect to sensitive sub-populations, and read the following: "The RfD for perchlorate, on which the acceptable exposure level would be based, is a conservative public health-protective value derived using an uncertainty factor to ensure protection of the most sensitive population. Specifically, because the RfD includes a full ten-fold intraspecies uncertainty factor to protect the most sensitive population, the fetuses of pregnant women who might have hypothyroidism or iodide deficiency, it is also protective of other sensitive populations such as neonates and developing children." Mr. Mullennix said that this means that the DWEL of 24.5 takes into consideration all the available uncertainty factors considered appropriate. Ms. Jennings said that her choice of the word trump does not imply a hope on her part or EPA's part, but is simply "the way the law works." She explained that EPA's guidance number is a TBC, and if a standard is promulgated, it, rather than the TBC, will govern. Mr. Dow said that if he understands correctly, the 24.5 ppb figure doesn't account for perchlorate exposure from food, or beverages like milk. He asked about EPA's timeframe for providing guidance pertaining to that issue. Ms. Jennings replied that EPA does not have a timeframe for that at the moment. She also noted that the current guidance is referring to this issue when it says that EPA is in the process of evaluating the relative source contribution factor and how to apply it. She further noted that whether EPA Headquarters provides specific guidance for MMR before coming out with some kind of national guidance is unclear. Mr. Dow also said that it's his understanding that the NRC developed its RfD value based on epidemiology studies, while some states have developed regulations based in part on laboratory bioassays. He then asked why EPA is ignoring the laboratory studies on perchlorate and basing its standard on epidemiological studies. Ms. Jennings said that she doesn't think she can answer that question. She also said, "It is certainly different than what we've done in the past," but that's the number that was developed and is being adopted in EPA's IRIS (Integrated Risk Information System). Mr. Dow said that it would be interesting to hear an explanation about this from EPA Headquarters. Mr. Cambareri inquired about the process to finalize the preliminary remediation goal of 24.5 ppb. Ms. Jennings explained that the preliminary remediation goal, which is established in the RI phase, helps in directing which alternatives are selected for the FS. However, additional specific information that becomes available is factored in (as would a promulgated standard) to come up with a final cleanup level. Mr. Cambareri asked if it's correct that the comparison is between a preliminary remediation goal from the guidance versus what might be selected as a site-specific remediation goal. Ms. Jennings replied that that is correct. Mr. Cambareri then asked how the remedial goal compares to a drinking water standard. Mr. Walsh-Rogalski replied that if there was a state or federal number that was a legal requirement, it would govern as a matter of law. If the state or federal number was advisory in nature, however, the agency could take that into account but it wouldn't be controlling. Mr. Cambareri mentioned the Massachusetts Department of Environmental Protection (MassDEP) advisory of 1 ppb for perchlorate. He then asked if the current EPA guidance means that the lateral and vertical extent of areas of perchlorate contamination will now be mapped at 24.5 ppb. He also said that he thinks the 24.5 ppb number should be rounded off. Regarding the mapping, Ms. Jennings replied, "I don't think we're prepared to do that." She also mentioned again that guidance is being sought from EPA Headquarters, that 24.5 ppb is a preliminary number, and that site-specific information needs to be factored into the equation. Mr. Schlesinger said that he's seen maps and figures change over the years, doesn't want to see them change now such that they're based on a 24.5 ppb level, and believes that the Impact Area Groundwater Study Program (IAGWSP) should continue to look at the perchlorate problem with a 1 ppb number in mind. He also asked Mr. Gonser to comment on the military's document on perchlorate, which was issued the same day as EPA's. Mr. Gonser first noted that, as Mr. Cambareri suggested, the military has rounded off the number to 24 ppb. He also said that the Department of Defense (DoD) did issue a policy, and will probably issue service-specific policies for the Army and the Air Force. He noted that the policy basically states that until such time as EPA or the state promulgates a standard for perchlorate, DoD is establishing 24 ppb as the current level of concern for managing perchlorate. For the cleanup program, the policy states that where perchlorate concentrations in water exceed the level of concern, DoD components are directed to conduct site-specific risk assessments. If an assessment indicates perchlorate concentrations could potentially result in adverse health effects, DoD components should prioritize the site for appropriate risk management. The DoD policy also includes guidance on DoD drinking water systems and sampling of wastewater discharge. Mr. Gonser noted that the DoD policy on perchlorate issued in September 2003 only authorized the military to sample for perchlorate, whereas the new policy clearly states that the military can take action to address the contamination. He also said that the DoD policy is consistent with and was fully coordinated with EPA's guidance. Mr. Schlesinger asked if maps and figures will reflect the 24 ppb perchlorate guidance. Mr. Gonser replied that this issue would be discussed with the program managers. He also noted, however, that he thinks it would be appropriate to show a 24 ppb contour line, given the guidance, although that isn't to say that that's the only contour line that should be shown or that he envisions many changes to the maps. Mr. Schlesinger remarked that it would be a waste of public resources to make decisions based on 24 ppb when, for example, additional information about relative source contributions may be forthcoming. Mr. Gonser agreed that the IAGWSP doesn't want to make investments that would have to be changed down the road; rather, it wants to be as proactive and flexible as possible in terms of anticipating and meeting standards that are promulgated in future. Mr. Pinaud said that he wanted to reiterate that as of today MassDEP's 1 ppb health advisory for perchlorate still stands. Also, the proposed perchlorate standard is undergoing final review and is anticipated to be promulgated this spring. He also noted that there will be a public comment period associated with that process. Mr. Walsh-Rogalski asked whether the DoD policy speaks to whether the contamination is on range or off range. Mr. Gonser replied that it just states that DoD components will assess for off-range migration of perchlorate from operational ranges (i.e., it calls for a sampling program to determine if perchlorate is going off range). Mr. Walsh-Rogalski suggested that it shouldn't then affect cleanup, whether it's on range or off range. Mr. Gonser reiterated that the policy doesn't really speak to that. He also noted, however, that in the case of MMR, there is no point in waiting to address on-range contamination, as it will otherwise eventually migrate off range. Tungsten Update COL FitzPatrick, Deputy Director for the Massachusetts National Guard's Environmental & Readiness Center (E&RC) at Camp Edwards, stated that environmental performance standards (EPSs) pertaining to the upper 15,000 acres of MMR were developed with the Community Working Group as part of the process associated with the final environmental impact report. In addition, through a certificate of adequacy from the Executive Office of Environmental Affairs (EOEA), the Environmental Management Commission (EMC) was formed to manage oversight that was codified in 2002 under Chapter 47. Part of the EMC process was to appoint a full-time on-base environmental officer to assess current military training, and that individual is Mark Begley. COL FitzPatrick noted that there are two advisory councils to the EMC - the Community Advisory Council and the Scientific Advisory Council. All three groups meet on a quarterly basis and have been receiving briefings from the E&RC since 2001/2002, with briefings about the tungsten issue starting in 2004. COL FitzPatrick reminded the group that due to restrictions outlined in EPA's Administrative Order #2 (AO2), the Army was no longer able to use lead ammunition and so developed a green ammunition program and began using tungsten-nylon bullets, which, based on available information at the time, were believed to be insoluble, non-toxic, and a better alternative to lead. Meanwhile Mr. Begley began looking at the green ammunition program and conducting some research on the Internet and elsewhere, and found that perhaps tungsten wasn't everything that people were led to believe. COL FitzPatrick noted that in response he began doing some research of his own and determined that there was a need to embark on a study to assess whether tungsten-nylon is causing a contamination problem in the training area. In June 2005 the Army Environmental Center (AEC) began field work for an 18-month tungsten mobility study, with MMR being the first study site. COL FitzPatrick mentioned that there are no soil or water standards associated with tungsten. He also noted that AEC had agreed to release any significant findings throughout the process of the study, and that EPA had requested preliminary sampling data. About two weeks ago, on February 15, AEC notified the Mass Guard that preliminary data were available, that quality assurance/quality control (QA/QC) had been accomplished, and that the data showed a 15 ppb tungsten detection in one of the groundwater wells that was sampled. Late in the evening of February 15, this information was presented to the Adjutant General, who in turn contacted the Executive Officer of Public Safety. The Adjutant General met with the Executive Officer of Public Safety on the morning of February 16, a member of the Governor's staff was present at that briefing, and it was decided that the Governor's office would be fully engaged in terms of what the information might mean and the potential steps to be taken. At about mid day on February 16, the Governor's office began directing who would be contacted and when; that afternoon the Governor's office publicly announced the decision to suspend firing of tungsten-nylon bullets at MMR because of tungsten's mobility. COL FitzPatrick stated that the mobility study, the purpose of which was to assess the distribution and potential fate and transport of tungsten, focused on three bermed ranges: B, C, and I. Soil sampling was completed in July 2005. Lysimeters were used to look at soil pore water, and three rounds of lysimeter sampling have been completed to date. One round of groundwater sampling at four monitoring wells has been completed, with the 15 ppb detection occurring in MW-72, which is located on B Range. COL FitzPatrick showed a map of the small arms ranges and pointed out: the ranges shown in tan, where tungsten-nylon ammunition has been fired; the ranges shown in green, where it has not been fired; Upper Cape Water Cooperative supply well #1 (WS-1), WS-2, and WS-3; the PAVE PAWS facility; WS-4, which hasn't been developed; Range Control; the ammunition supply point; and B, C, and I Ranges. COL FitzPatrick noted that the other three groundwater wells that were sampled tested nondetect. He also said that if tungsten began entering the groundwater in 1999, the year it was first fired at MMR, it's assumed that it would not yet have traveled beyond the MMR boundary, but would only have reached a point about half-way down B Range. COL FitzPatrick showed a schematic drawing of B Range and pointed out the soil sampling locations and the eight lysimeter locations there. He also reviewed the preliminary tungsten data, as follows: in soils, 17 to 1,534 parts per million (ppm); in soil pore water, nondetect to 400 ppm; and in groundwater, 15 ppb in MW-72. COL FitzPatrick then noted that based on the Governor's meeting at MMR on February 17, MassDEP sampled WS-2 and WS-3 and their associated sentry wells to ensure that they hadn't been affected by tungsten. Those samples were split with the IAGWSP, and samples from both MassDEP's lab and the IAGWSP's lab came back nondetect. Mr. Minior inquired about the method detection limit. COL FitzPatrick replied that it was 4 ppb for MassDEP's lab, and less than 2 ppb for the Army Corps of Engineers' lab used by the IAGWSP. COL FitzPatrick stated that the plan is to complete the tungsten mobility study in the September/October timeframe, which will include two additional sampling rounds for the lysimeters and for groundwater. He also noted that the toxicity aspect of tungsten is under review by the U.S. Center for Health Promotion and Preventive Medicine (CHPPM) and the Agency for Toxic Substances and Disease Registry (ATSDR). Part of AEC's goal is to release its report after the CHPPM study has been completed so there'll be some sort of measuring stick to determine what the values coming out of the mobility study may or may not mean. COL FitzPatrick also mentioned that ATSDR is conducting a separate study. COL FitzPatrick further noted that the Mass Guard is in the process of updating its ranges in order to meet the current standards. This process involves the development of a range sustainment plan that addresses managing the ranges for small arms ammunition, regardless of type (tungsten or lead). COL FitzPatrick stated that the Mass Guard will have to put together a pollution prevent plan and see if it meets the criteria associated with AO2. And in order to go back to using lead ammunition, the Mass Guard would need both EPA's and the EMC's approval. COL FitzPatrick also said that future actions still need to be determined, and will depend on the final report that's scheduled to be issued in September. He further noted that the IART will be provided with updates as new information becomes available. He also mentioned that the tungsten situation illustrates that the EOEA's putting the EMC in place to provide additional oversight of current military training is a success, given that the tungsten mobility study came about as a result of Mr. Begley's initial questioning and research. Mr. Pinaud said that MassDEP was notified of the tungsten sampling results late in the day on February 16. Directly after the Governor's briefing the following day, the Commissioner directed MassDEP to meet with the Upper Cape Water Cooperative, Dave Mason from the Sandwich Board of Health, the AEC, and the IAGWSP, at which time priority sampling locations were determined with respect to water supply. Mr. Pinaud referred to the map, pointed out the wells that were sampled, and noted that the sentry wells are five years travel time upgradient of WS-2 and WS-3. He also said that the Army Corps of Engineers actually performed the sampling, and those samples were sent to a lab in Middleboro, which found them to be nondetect for tungsten. The samples were split with the IAGWSP, whose lab in Mississippi also found them to be nondetect. However, because the IAGWSP's lab's method detection limit was lower, MassDEP may have its samples tested again at a lower detection limit to ensure that they can be compared appropriately. Mr. Pinaud also remarked that the good news is that all those wells tested nondetect. Mr. Schlesinger asked if anything is known about how quickly tungsten travels to groundwater. COL FitzPatrick replied that the AEC data didn't include that information. He also noted that about one million tungsten-nylon rounds have been fired since 1999, with about 330,000 of them fired at the B Range. Mr. Minior inquired about the depth of groundwater in the area of the detection. COL FitzPatrick replied that it's 85 to 100 feet. Mr. Schlesinger asked what kind of ammunition is being used currently. COL FitzPatrick replied that essentially the Mass Guard will be using plastic bullets at MMR or will go to other locations such as Fort Drum. Mr. Schlesinger also asked about any plans to conduct sampling at ranges other than B, C, and I. COL FitzPatrick replied that next steps, such as additional sampling, will be determined after a more thorough examination of the data and consultation with the EMC and the regulators Mr. Schlesinger then inquired about any possible interaction between tungsten and other materials in the soil and groundwater at the base. Mr. Gonser replied that some studies indicate that tungsten could affect the mobility of lead or other metals. He also noted that the AEC is collecting data that will help determine whether that is the case, which is something the IAGWSP will examine. Mr. Dow mentioned a July 1977 Science Magazine article entitled "Biomethylation of Toxic Elements in the Environment," which noted that tin is a transition metal, and that many transition metals can be methylated by bacteria in soils and sediments, thereby increasing the mobility and toxicity of the element because "methylated transition metals are taken up by various kinds of other organisms and they're much more bio-available than the inorganic form." He then suggested looking at "whether it's in the inorganic form or the organic form" when the analysis is done. COL FitzPatrick replied that the concern is the tungsten-nylon bullet, not a tungsten-tin bullet. Mr. Dow clarified that he'd meant to say tungsten, not tin. He also said that he presumes that the tungsten is not in small fragments that bacteria could work on easily. COL FitzPatrick noted that in fact it's compressed tungsten powder in the bullets, so Mr. Dow's suggestion may be valid. Mr. Gonser added that it's his understanding that when tungsten dissolves "it does actually change its condition a little bit." Mr. Walsh-Rogalski asked about other countries with tungsten groundwater standards. COL FitzPatrick replied that he heard about a 50 ppb drinking water standard in Russia, and a recreational water standard of 30 ppb in Canada, but no drinking water standard there. Mr. Walsh-Rogalski asked if the recreational standard was ingestion related. COL FitzPatrick replied that this wasn't clear to him from the literature he read. Mr. Cambareri noted that from past discussions with Mr. Begley and conferences in Amherst he also had heard that tungsten can increase the mobility of the lead. He also said that he thought it was a good move on MassDEP's part to sample both the sentry wells and the far-field wells, as they are constructed differently, with the sentry wells having larger screens. Mr. Mullennix asked if the 15 ppb tungsten detection in MW-72 at the B Range had been repeated. COL FitzPatrick replied that the 15 ppb was detected as part of the first sampling round, while results from the second sampling round are not yet available. Mr. Mullennix put forth the idea that tungsten might have been on the ground surface and short-circuited down into the well. Mr. Cambareri said that that possibility had occurred to him as well. He also said that he was impressed with the speed of the tungsten's vertical migration through the 100 feet of unsaturated zone to the water table, with firing of tungsten bullets only having begun in 1999. Ms. Jennings mentioned the importance of noting the high concentrations in the pore water, which eventually will make their way to groundwater. Mr. Gregson noted that he and Mr. Begley had talked about the possibility of short-circuiting at the MW-72 and had the well checked out by the Army Corps of Engineers to ensure that it was secure and well-sealed. It was determined to be unlikely that surface runoff could have infiltrated the well and caused short-circuiting at that location, although the possibility can never be ruled out completely. Mr. Schlesinger asked if the Guard plans to cover the berms to prevent infiltration of tungsten. COL FitzPatrick replied that that option is being considered as a next step, and will be implemented if deemed prudent. Mr. Schlesinger urged that that decision be made quickly in order to be on the safe side, and added that he doesn't see why the berms wouldn't be covered, as it would be fairly simple to do. Mr. Cambareri asked for the name of the Director of the E&RC, and COL FitzPatrick replied that it is Alan Cowles. Agenda Item #3. Community Involvement Issues 2006 Meeting Topics Mr. Murphy mentioned that future IART meeting topics are listed at the bottom of tonight's meeting agenda, and the intent of the project managers is to come up with more specific meeting topics for the rest of the year to be laid out for the IART members. Mr. Gonser said that a significant number of remedial investigations will be completed this year and will be included in future meeting agendas. Mr. Murphy also pointed out that an IART Meeting Evaluation form was included in tonight's handouts. He noted that the Plume Cleanup Team (PCT) uses similar forms to provide feedback on that team's meeting presentations, and the IART is being asked to do the same. He also noted that copies of the form are available at the handout table for members of the public who would like to provide feedback. Membership Update Mr. Murphy said that he'd expected to receive word today from EPA's Regional Administrator on the status of IART applicants who've been attending recent meetings, but did not. He said that he hopes to hear by the end of the week, at which time he'll e-mail team members and let them know the membership situation, which he anticipates will be the appointment of those applicants to the team. Mr. Schlesinger asked that the team be provided with an updated membership/contact list that includes representatives from the agencies, as soon as current membership issues are resolved. Mr. Murphy said that he thinks that a list could be provided by the next IART meeting. IART/PCT Merger Concept Mr. Dow said that it's his understanding that there's been a decision to keep the IART and PCT separate. He also noted, however, that Sue Walker, a PCT member who recently relocated to California, had mentioned that it might be worthwhile to have a get-together with the PCT and the IART so the citizen members could share their experiences and gain same basic knowledge about each group's activities. Mr. Murphy said that he thinks the IART/PCT merger topic is still being discussed. Mr. Minior distributed copies of the March 8, 2006 PCT meeting agenda and noted that IART members are invited to attend as they might be interested in the presentation on wind power. He also noted that the meeting, which begins at 6:00 p.m., will take place at the Holiday Inn in Falmouth. Mr. Minior further remarked that perhaps the future agenda item "Wellhead Treatment versus Aquifer Restoration" would be an appropriate topic for a joint meeting like the one Mr. Dow mentioned. Mr. Mullennix said that he thinks that the suggestion to combine the PCT and IART deserves serious consideration going forward. Mr. Schlesinger said that he thinks it might be helpful if a meeting were set up for PCT and IART citizen members only, without involving the regulators. He also said that IART member Judy Conron, who was unable to attend tonight's meeting, had expressed to him that she is against a merger because of the IART's extensive agendas. He further noted that both he and Ms. Conron were under the impression that the plan was to hold off on a merger for the time being, which he hopes is still the case. Mr. Minior suggested that the IART citizen members contact the PCT citizen members, whose contact information is posted on AFCEE's web site, to arrange a meeting without the agencies. Mr. Schlesinger said that he thinks it would be easier if AFCEE extended the invitation at the next PCT meeting on the IART's behalf. Mr. Mullennix asked for and received confirmation that the Senior Management Board (SMB) is briefed on issues across the base, and meets every other month for about two hours. He also determined that there's quite a bit of overlap in terms of regulatory personnel who attend PCT meetings and IART meetings, in which case it makes sense to him to have combined, rather than separate, meetings. Ms. Jennings replied that it's more a matter of "content and topic," and explained that EPA is against a merger at this time because both teams' agendas are very full right. She also noted, however, that EPA does think that the Community Involvement Plans for the two programs should be integrated and that both programs should be using similar community outreach tools, which is currently not the case. EPA has also been discussing the idea of professional facilitation for IART meetings and technical meetings. Ms. Jennings also noted that EPA plans to prepare a comment letter on this issue which will be shared with IART members. She further stated that EPA thinks that a meeting with the IART and PCT - whether or not initiated by the citizen members themselves and whether or not the agencies are included - would certainly be a critical component to a future merger. Mr. Cambareri said that he agrees that now is not the appropriate time for a merger of the teams, given the IART's full agendas with the IAGWSP's work moving forward from assessment into remediation. Ms. Grillo stated that although MassDEP welcomes change, the Department agrees that "timing is everything" and considers it good that the discussion is ongoing. Mr. Murphy recommended that the IART/PCT merger topic be revisited briefly at the next IART meeting. Mr. Schlesinger took this opportunity to request that any maps used in future presentations on tungsten also include information on IAGWSP sites/areas of contamination. Agenda Item #4. Remediation & Investigation Update - Southeast Ranges Before beginning the Remediation & Investigation Update presentation, Mr. Gregson showed a series of figures pertaining to particle tracking (reverse and forward) and explained how the process is used in helping to identify source areas, additional monitoring well locations, and discharge points. Mr. Gregson then stated that the J-1, J-2, and J-3 Ranges (which are part of the Southeast Ranges) were used for military training from World War II until the 1950s, and then for weapons testing by defense contractors from the 1950s until the 1990s. Activities associated with the latter use of the ranges included munitions disposal by burning or burial, and firing and testing of munitions. Mr. Gregson reported that investigations into the Southeast Ranges included archive searches and witness interviews (conducted over the years 1997 to 2203) and remedial investigations to support feasibility studies for the J Ranges and the L Range, which continue today. Remedial investigation efforts have involved the installation of 700 well screens at 170 locations, and the collection and analysis of more than 4,500 soil samples. Mr. Gregson also noted that in 2004 soil Rapid Response Actions (RRAs) were conducted at the J-2 Range, where about 8,000 tons of soil was removed, and at the J-3 Range, where about 2,200 tons of soil was removed. That excavated soil was treated in the thermal treatment unit. Mr. Gregson showed a map depicting RDX contamination in groundwater at the Southeast Ranges, pointed out Peters Pond, the base boundary, and the Forestdale School, and noted that groundwater in that area flows radially from the top of the mound, which complicates the investigation. He also pointed out nondetect, 2 ppb, and 10 ppb plume contours, noted that the health advisory for RDX is 2 ppb, and pointed out the J-2 East, J-2 North, J-1 North, and J-3 plumes. Mr. Gregson then showed another map of the Southeast Ranges, but one depicting perchlorate contamination there. Mr. Gregson reported that two RRAs are under way to initiate cleanup of the J-2 North and J-3 plumes. He showed a map of the J-2 North plume and pointed out WS-2 and some of the sampling points that MassDEP and the Army Corps of Engineers sampled as part of the response to the tungsten detection. Mr. Gregson noted that the J-2 North plume contains both RDX (with a maximum concentration of about 11 ppb) and perchlorate (with a maximum concentration of 140 ppb). The source area, which was cleaned up as part of the soil RRA, is Disposal Area 2, located in the southern part of the J-2 Range. The groundwater treatment system will consist of three extraction wells, containerized treatments units, a small treatment plant toward the toe of the plume, and reinjection trenches along the flanks of the plume. The treatment media will be granular activated carbon (GAC) and ion exchange resin. Two of the extraction wells have been installed, the third is currently being installed, trenching for the pipelines is scheduled to begin next month, the treatment plant sites are being cleared, and the installation of the reinjection trenches is to occur in April. Mr. Gregson then showed a map of the J-3 plume and noted that it has migrated off base to property currently owned by Camp Good News and may be discharging into Snake Pond, although no perchlorate or RDX has been detected in the pond water. He noted that for the J-3 treatment system, the plan is to utilize one existing extraction well, drill two additional extraction wells, and pump the extracted water to the existing Fuel Spill 12 (FS-12) treatment plant building, where the Air Force Center for Environmental Excellence (AFCEE) is allowing the IAGWSP to use some space for a GAC/ion exchange resin treatment system. The treated water will be returned to the aquifer via AFCEE's reinjection wells. Mr. Gregson reported that the two new extraction wells have been installed and trenching for the pipeline is scheduled to begin this week. Mr. Gregson also showed several photographs, including a drill rig, a finished well, and existing containerized treatment units at the Demolition Area 1 (Demo 1) plume. Mr. Gregson continued his presentation by discussing some ongoing J Range investigations. He reported that the IAGWSP has obtained permission to install a series of drive-points on the south side of Snake Pond to ensure that the J-3 plume contamination north of the pond is not under-flowing it and migrating into the neighborhood south of the pond. The drive-point work is scheduled to begin on March 13, and results are expected to be available by the next IART meeting. Mr. Minior asked for an estimation of the depth of pond water on the discharge side of the pond, "before you get to the natural water that might be under-flowing the pond, on that south side…" Mr. Goydas said that his recollection is that the U.S. Geological Survey estimate and the modeling estimate are "about 100 feet below water level," and added, "but basically the top part of the aquifer will be pond water that's discharging, and then below that will be the water that underflows the pond." Mr. Gregson stated that for the past six months to a year the IAGWSP has been trying to define the extent of RDX contamination coming off the southern end of the J-1 Range. He showed an aerial photo/map of the area and pointed out the Forestdale School, the Grand Oaks neighborhood, the base boundary, and monitoring wells and drive points where RDX was detected. He noted that it appears that the upgradient end of the plume has been defined, so the ongoing effort is to define where the plume is going off base. He then pointed out a number of monitoring wells (at the fire station on Route 130, and on Little Acorn Lane) that had tested nondetect for RDX, and noted that the IAGWSP is currently trying to obtain access to drill wells on Windsong Road, which is a private road. Mr. Murphy pointed out that the aerial photo is a bit outdated, and in fact there are now homes along the southern extent of Windsong Road. Mr. Schlesinger noted that drive-point 386 (DP-386), DP-389, and DP-391 on the monthly map are represented by black dots rather than red, like the map being shown at this meeting. Mr. Gregson said that for the purposes of the monthly map the drive-points are considered to be similar to profile data, which is why they don't show up as validated detections there. Mr. Mullennix asked if residences in the J-1 area are connected to town water. Mr. Gregson replied that they are. Beth Donahue, a resident of Windsong Road, asked who the IAGWSP had contacted regarding access to drill wells there. Mr. Gregson replied that a group of individuals known as the Forestdale Realty Trust were identified as the owners of the road, and the IAGWSP has been dealing with the trustee of that organization. Ms. Donahue noted that research into making the road public indicated that all of the homeowners there would have to participate in that decision; therefore, she's surprised that the IAGWSP didn't contact each of the homeowners about access for drilling. Mr. Gregson said that it's his understanding that ownership of Windsong Road differs on either side of the intersection with Grand Oak. He also said that he'd be happy to talk with Ms. Donahue off line about any additional ownership information she has. Ms. Donahue said that she would think that all of the homeowners on Windsong Road would be contacted in relation to the IAGWSP's investigation work. Mr. Gregson continued with his presentation by noting that his office received an EPA comment letter today on the IAGWSP's approach to source area investigations at the J-1, J-2 and J-3 Ranges. He said that he hasn't had the chance to review the letter in detail, and would like to postpone any major discussions on this topic until after there's been a meeting with EPA to talk over and better understand the agency's concerns. Mr. Gregson also noted, however, that what the IAGWSP did was look at magnetic anomaly signatures and identify areas where it's believed to be likely that there are disposal pits. He then referred to a J-1 Range figure and pointed out the colored grids, which are other areas that warrant investigation based on magnetic anomalies and other factors such as interview records, soil sampling, and particle backtracks. He said that the IAGWSP need to prioritize with the regulators which magnetic anomalies or potential source areas to examine and in what order, and determine how that all fits into the RI report for both the J-1 and J-2 Ranges. He also noted that a similar exercise is occurring for the area of the J-3 Range northwest of where the soil RRA was conducted. Mr. Gregson stated that the Impact Area is about 2,200 acres in size, while the Central Impact Area is considerably smaller, but still large at 330 acres in size. Investigation activities at the Central Impact Area have included the investigation of 49 potential targets, 25 of which had detectable levels of RDX in soil, as well as other explosives compounds such as HMX, PETN, and TNT. Unexploded ordnance (UXO) has also been identified at the Central Impact Area. Mr. Gregson noted that wells have been installed at 123 locations in and downgradient of the Central Impact Area. Mr. Schlesinger said that he thinks that the IAGWSP refers to a 330-acre source area in order to demonstrate that the problem is so large that it prohibits if from being addressed. However, his understanding is that the source area is actually smaller. Mr. Gregson replied that it's no secret that 330 is a big number and that it would cost a lot of money to excavate an area that size, and the IAGWSP has been working with the regulators as part of the FS process to see if that can't be made a more manageable number. If it in fact turns out to be a 330-acre problem, that's what will have to be addressed. Mr. Gregson further noted, however, that he thinks that the evidence suggests that it might be a smaller area that's "the most serious contributor to groundwater contamination." Mr. Gregson showed a map of the Central Impact Area and said that the IAGWSP is currently installing drive-points to try to fine-tune the source area. He noted that the 330-acre area was defined based on a number of lines of evidence, including magnetic anomalies identified through aerial magnetometry (air mag) surveys, aerial photos of cratering, soil sampling results, target locations, and groundwater backtracks. He also said that some additional work is being done on UXO density in order to help fine-tune the source area. Mr. Gregson displayed a Central Impact Area cross-section figure and pointed out how it shows multiple areas of contamination from multiple source areas. He also noted that the drive-point work is expected to continue through the April timeframe, and that results have come back for a couple of the drive-points: one was nondetect and the other had a low-level perchlorate detection of less than 1 ppb. Mr. Dow noted that in the cross-section G-G' figure, the Central Impact Area plumes appear to be petering out, which seems difficult to reconcile with the idea that some of the plume may extend over to the Northwest Corner. Mr. Gregson explained that Mr. Dow is referring to the Northwest Corner plume, which is a relatively large area of perchlorate contamination and a very narrow plume of RDX that extends from the base boundary to the canal. He noted that the RDX plume at the Northwest Corner appears to have detached from its source, and particle backtracking indicates that it either comes "from this part of the Impact Area" or from "over here on the former A Range." He added that if indeed that RDX came from the Impact Area, it's traveled fairly rapidly where the "high permeability layer has made it all the way to the canal," while the other parts of the plume shown on the figure extend out to the edge of the Impact Area "at probably the lower permeability deposits." Mr. Dow mentioned that perchlorate, because it's a salt, travels more rapidly than RDX. Mr. Gregson noted that the majority of perchlorate detections at the Northwest Corner are shallow, right near the water table, which indicates a nearby source. The RDX plume in that area, however, is underneath those perchlorate detections; therefore it appears that there are two separate sources for those two different contaminants. Mr. Dow said that he just wants to make sure that the IAGWSP is implicating all the source areas that could potentially be implicated in terms of hotspots that get treated in the 300-acre area. Mr. Gregson noted that an infinite number of wells would have to be drilled in order to find all the "plumelets" at the Central Impact Area, but it probably isn't necessary to do so. Rather, if the decision is made to take a remedial action like pump-and-treat, the idea would be to design a system large enough to capture all of the plumelets. Mr. Schlesinger referred to some drive-point locations on the monthly map and asked if their purpose is to try to determine if there's a connection between the Central Impact Area and the Northwest Corner. Mr. Gregson replied that that is not the case, pointed out the drive-points on the map, and said that they were installed to help define "that small area of perchlorate" and "also an RDX detection in this well." Mr. Murphy said that because the meeting is running late, two agenda items will be postponed until next month's meeting: Demolition Area 1 Groundwater Rapid Response Action Annual Update, and Former K Range Remedial Investigation. Agenda Item #5. Groundwater Monitoring Plans Recap of the Southeast Ranges Mr. Goydas stated that his presentation, which is a follow-up to the groundwater monitoring presentation at the January IART meeting, is intended to provide an overview with more specific detail on the plan view locations of monitoring wells for the Southeast Ranges plumes. He reminded the group that there are two types of monitoring plans: an interim groundwater monitoring plan (IGM) and a performance monitoring and evaluation plan (PME). These have replaced the base-wide long-term monitoring program, which was not specific enough to the various needs of the individual plumes, some of which are in the investigation phase and some of which are in the remediation phase. Mr. Goydas noted that PME plans involve monitoring of the treatment system influent and effluent to verify that the system is performing, and hydraulic and chemical monitoring, which focuses on the effect of pumping on the aquifer. IGM plans are designed for plumes that don't yet have remedial systems and are intended to characterize plume nature and extent and support remedial decision-making. Mr. Goydas showed a slide that listed the number of well screens evaluated at each of the Southeast Ranges, and explained that for the most part there is an average of two to three well screens at each monitoring well location. He also noted that with the former, base-wide, long-term monitoring plan, more than half of the well screens were testing clean for contaminants of concern (COCs), which was another reason to switch to a site-specific approach. Mr. Goydas noted that he would be showing plan view maps that depict wells sampled semiannually in blue and those sampled annually in green. He also said that groundwater flow direction is indicated by an arrow on the maps. Mr. Goydas showed a map depicting chemical monitoring locations for the J-1 North IGM plan. He noted that the J-1 North plume is about 5,000 feet long from source to toe and is composed primarily of perchlorate and RDX. He also explained that the rationale for selecting the sampling frequencies is primarily based on the intent of the plan and the specific characteristics of the plume. Because the plume is not ready to go into remedial action, the monitoring is looking at its ambient characteristics. The plume is not expected to change drastically from month to month or quarter to quarter, and the field data support that; therefore the monitoring doesn't have to very frequent to provide an understanding of what's going to happen in the future, and to verify the conceptual model. Ms. Jennings asked if all existing wells in that area are shown on the map. Mr. Goydas replied that only those wells that are going to be sampled are shown, which is a large portion of the existing wells. Ms. Jennings recommended including all the existing wells in the future, as it would be helpful to know where there are wells that could potentially be monitored. Mr. Goydas showed a map depicting chemical monitoring locations for the J-2 North PME plan. He explained that there are more semiannual wells in this plan because more rapid changes are expected in plumes where active pumping is occurring. He also noted that the J-2 North plume is about 7,500 to 8,000 feet long, and that the RDX contamination exists within the larger perchlorate footprint. Mr. Goydas pointed out the semiannual wells at the edges of the plume, at the leading edge, and in the core of the plume to help in understanding how the plume is dynamically changing with time. He also noted that several wells north of the plume that were originally identified to be sampled biannually have since been changed to annual wells as part of the comment resolution process. Mr. Goydas showed a map depicting chemical monitoring locations for the J-2 East IGM plan. He noted that the J-2 East plume, which is about 5,500 feet long from source area to toe, is composed primarily of perchlorate and RDX, with some HMX in the interior. He noted that the approach here is to simply monitor and track the conceptual model while proceeding through the feasibility study and risk assessment. He also pointed out some semiannual wells at the leading edge and at the trailing edge, to determine whether the plume is detaching from the modeled source areas. Mr. Goydas also reviewed changes to the plan that came about as a result of comment resolution: the biannual leading edge well will now be sampled annually, MW-57D was added to the plan as an annual well, and another well "is being flipped with an existing one situated right here," (MW-336 and MW-342). Mr. Schlesinger observed that there's no leading edge well at the southern lobe of the plume. Mr. Goydas explained that as a result of comment resolution, a well is going to be added there. Mr. Schlesinger inquired about the frequency at which that well will be sampled, and Mr. Goydas said that he thinks it will be sampled annually. Mr. Schlesinger asked if the leading edge wells in the main part of the plume are going to be sampled semiannually because of the proximity to water supply. Mr. Goydas replied that it's more related to the higher concentrations that are upgradient in that portion of the plume; whereas the southern lobe has much lower concentrations and less dynamic changes are expected there. Mr. Dow asked if the biannual wells are located in areas where it's believed the plume has reached equilibrium, or if they're meant to act as sentinel wells. Mr. Goydas replied that it's more the latter, and added that neither of the J-2 plumes is believed to have reached steady-state. He also noted that the wells that are significantly downgradient of where the leading edge is believed to be are generally sampled biannually or annually. Mr. Schlesinger asked why the leading edge wells in the main part of the plume aren't right at the toe, given the large amount of mass Mr. Goydas said is there. Mr. Goydas explained that the mass is actually upgradient, and the wells, which are in an area of fairly low concentrations, are sampled semiannually in "anticipation that higher concentrations will arrive." Mr. Goydas showed a map depicting chemical monitoring locations for the J-3 PME plan. He noted that there's a large number of monitoring wells, with more of them sampled semiannually than annually. The reasons for this are that the J-3 plume is more internally heterogeneous than the other plumes and that more rapid changes in concentrations are expected as a result of pumping. The intent of the semiannual wells is to monitor the periphery of the plume to understand the plume geometry, to monitor the leading edge to understand how the plume is migrating toward Snake Pond, and monitor the source area to understand the plume's detachment from its source. Mr. Goydas noted that although a major soil removal activity at the J-3 Range was recently completed, relatively high concentrations continue to exist upgradient, and the IAGWSP really wants to understand how that removal action has affected the groundwater. Mr. Goydas showed a map depicting chemical monitoring locations for the L Range IGM plan. He noted that the assessment for the L Range indicated that annual monitoring is sufficient because the plume has reached a steady state. All the concentrations are declining, the plume tends to be retracting rather than advancing, and there's really no indication that the plume is doing anything other than continuing to dissipate in place. Mr. Goydas also noted that there's a fairly wide distribution of monitoring wells to try to reflect the various lobes of contamination, as the L Range plume is a series of isolated low concentration zones within the aquifer. Mr. Schlesinger asked if just monitoring the plume once in a while like this is called natural attenuation. Mr. Goydas replied that that stage in the process hasn't been reached yet. The RI was just completed and the next step is the risk assessment and then the FS. He clarified that he is not pointing to any future remedy, but is simply saying that the data clearly suggest that concentrations are declining and the plume is not migrating. Demolition Area 2 Mr. Nixon stated that Demolition Area 2 (Demo 2) is a 2,300' by 300' area in the north-central part of the installation, which was used for light demolition training. He noted that Demo 2 is not nearly as large a site as Demo 1, and wasn't as heavily used. The Demo 2 plume is much smaller than the Demo 1 plume, has lower concentrations, and contains no perchlorate. Mr. Nixon also noted that a soil RRA was performed at the Demo 2 source area in fall 2004, and the completion of work report recommends no further action. Mr. Nixon showed a map of the Demo 2 plume and pointed out the contour lines: greater than nondetect to 0.6 ppb, 0.6 ppb to 2 ppb, and greater than 2 ppb. He also pointed out two recently installed wells (MW-404 and MW-406) and one that's currently being installed to look at the downgradient extent of the plume. He noted that the RI report is expected to be completed in May 2006. Mr. Nixon stated that the Demo 2 IGM plan is designed to: monitor the source area and assess the trends following the soil RRA; monitor the downgradient extent of the plume and confirm the plume edges; and monitor the concentration trends within the plume. He also noted that the maximum RDX concentration detected so far is 3.5 ppb. Mr. Nixon then referred to the map and pointed out which wells would be sampled semiannually and which would be sampled annually. He also pointed out two wells that appear as annual wells on the map but were changed to semiannual wells as a result of the comment resolution process. Mr. Nixon also mentioned that the relatively new plume delineation depicted on the map shows that the plume has shifted a little farther to the right than it was originally thought to be. He then pointed out some estimated forward particle tracks, noting that they were not actually modeled, but assumed and drawn in by hand based on the groundwater contour. Mr. Schlesinger asked why there isn't a monitoring well east of MW-311, in line with the eastern particle track. Mr. Nixon explained that the four wells in that area (MW-311, MW-380, MW-404, and MW-406), although staggered, basically form a well fence that provides a fairly good understanding of the concentrations there. Mr. Dow asked why the higher-concentration area is near the toe of the plume rather than near the source area, as is usually the case. Mr. Nixon pointed out two areas where the highest concentrations were seen over the past couple years and said that it's probably due to some pulsing of contaminants having to do with the amount of items that were blown up in one year, how much it rained in one year, and so forth. He said that there may be another area of 3.5 ppb or higher concentrations that will eventually be detected at the monitoring wells. Mr. Gregson prompted Mr. Nixon to repeat that the Demo 2 plume contains no perchlorate and that the source area was addressed when about 700 cubic yards of soil was removed and treated in the thermal treatment unit. Mr. Schlesinger asked why MW-16 is sampled semiannually, given that it's located at the source area which is said that have been removed. Mr. Nixon explained that it's sampled semiannually in order to track the trend over time and perhaps "be able to scream hurray as soon as possible when it goes nondetect." Agenda Item #6. Open Discussion Mr. Mullennix inquired about the status of regulatory review of the recently reissued draft Northwest Corner Remedial Investigation report. Ms. Jennings said that EPA just received the report in electronic format, has requested hard copies, and hasn't yet begun its review. Mr. Schlesinger questioned how the knowledge that the team has gained from the groundwater monitoring plan presentations will be applied, and whether it's possible to fit information about monitoring frequency on maps depicting other types of information. Ms. Jennings noted that all of the information that was presented is captured in more detail in the monitoring plans, while the presentations were an attempt to provide boiled down versions of the plans for IART comment, which is why she thinks it makes sense to include existing wells that aren't currently being sampled. She also mentioned that the IAGWSP will be making periodic IART presentations on monitoring results so the team will get a picture of the plumes. Mr. Schlesinger said that he thinks it would be useful to receive updated versions of the groundwater monitoring plan maps on an intermittent basis. Ms Jennings acknowledged Mr. Schlesinger's suggestion and also noted that any feedback on how to streamline monitoring plan presentations would be welcomed. Mr. Gonser added that monitoring plans will be updated each time a plume enters a new phase in the investigation and cleanup process, and the IART will be provided with those updated versions as they occur. Agenda Item #7. Adjourn Mr. Murphy reminded everyone to leave their completed IART Meeting Evaluation forms with him on their way out. He also noted that the IART would meet next on March 28, 2006 at the Falmouth Holiday Inn, and then adjourned the meeting at 8:58 p.m. |
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| Administrative Notice |
