Impact Area Review Team
Agenda Item #1. Welcome, Agenda Review, Approval of April 25, 2006 IART Minutes
Mr. Murphy convened the meeting at 6:00 p.m. and the Impact Area Review Team (IART) members introduced themselves. He reviewed the agenda and asked if there were any changes or additions to the April 25, 2006 IART meeting minutes. No changes were offered and the minutes were approved as written.
Agenda Item #2. Late-Breaking News, Responses to Action Items
Mr. Murphy asked if there were any comments or questions regarding Responses to Action Items from the April 25, 2006 IART meeting. Mr. Schlesinger noted that no cross-section figures were included in tonight's Remediation & Investigation presentation handout, and (as noted as an action item at the April meeting) he'd like to see cross-section figures routinely in order to have a better understanding of what's happening.
Mr. Murphy confirmed that there was no late-breaking news to report.
Agenda Item #3. Remediation & Investigation Update
Mr. Hill reported that construction of the J-2 North and J-3 Range Rapid Response Action (RRA) groundwater systems is proceeding. Installation of the extraction wells and pipelines has been completed for both systems, the well vaults are in place, performance monitoring wells to augment the existing network are currently being installed, and the footing for the J-2 North treatment building is in place, with the foundation expected to be completed in the next few weeks.
Mr. Hill also noted that the J-1 Range groundwater investigation along the fence line is continuing. The Town of Sandwich is in the process of purchasing Windsong Road in the Grand Oaks neighborhood from its private owner, after which the road will be public and the Impact Area Groundwater Study Program (IAGWSP) will be able to enter into access agreements with the town to commence drilling of two monitoring wells there. The RDX contamination detected at the fence line was not found in the three wells that were installed along Little Acorn Road, which is south of Windsong Road.
Mr. Hill then referred to the J Ranges source area investigations and reported that the J-1 Range and J-2 Range priority 1 grid anomaly investigations have been completed. The J-2 priority 1 Technical Memorandum (Tech Memo) was submitted in December 2005, the J-1 Range priority 1 Tech Memo was submitted in April, and the J-3 Range North of Demolition Area Tech Memo was submitted in early May.
Mr. Hill stated that over the past few months the IAGWSP has been investigating some anomalies identified through a statistical evaluation as representing potential burial pits on the J-2 Range. Thirty-six anomalies were identified, and to date 32 of those have been investigated, of which two were determined to be burial pits. Thirteen of the 32 were within the prioritized grids, while the remaining 19 were outside the prioritized grids. Mr. Hill noted that the table included in the handout summarizes the items removed from the pits. However, Ms. Richardson informed the group that the table was mistakenly left out of the handout, but would be forwarded to the team tomorrow.
Mr. Schlesinger asked for a description of the items that were found. Mr. Hill mentioned that one of the pits was a burn pit located in the mid-range area, and added that while some munitions items were found, the vast majority of material was classified as scrap - range-related debris such as metal plates, pieces of targets, and frag. Mr. Schlesinger asked if the metal plates were target plates. Mr. Hill confirmed that defense contractors that used the range fired at metal plates to simulate the penetration capability of particular munitions. Mr. Schlesinger asked if the plates that were found were tested for depleted uranium (DU). Mr. Hill replied that a DU study was conducted in the 2001 timeframe, but didn't indicate any use of DU. He also said that the plates currently being excavated are not being tested for DU. Mr. Gonser agreed to consult with the unexploded ordnance (UXO) experts and ensure that they're looking for the kind of impact to the metal plates that would point to DU use.
Mr. Hill stated that 41 potential pit targets were identified at the J-1 Range. Of those, 21 have been excavated, four of which were within the prioritized grids, with the others located primarily in the interberm area or the southern area. He also said that the IAGWSP has been looking at potential pits associated with known groundwater contamination, but is also looking, along with the regulators, at different ideas and theories on how to quantify the density of potential UXO that remains on the range.
Mr. Schlesinger asked if anything significant was found in grids 28/29 on the J-1 Range, which might yield a source for the plume coming out of that area. Mr. Hill replied that no smoking guns were found in any of the potential pit targets at the J-1 Range. Mr. Schlesinger asked if the modeled backtracks lead to any of the grids that were investigated. Mr. Hill replied that some burial pits were discovered during the J-1 priority 1 grid investigation, but the additional potential pit anomalies didn't turn up more disposal pits.
Ms. Dolan asked Mr. Hill to remind the group about what was found in that area of the J-1 Range. Mr. Hill mentioned the interberm area, where in witness interviews Textron employees spoke about disposal of explosives-contaminated wastewater, and there were accounts in the archives search report regarding disposal and burn pits. He further noted, however, that a good correlation to that allegation wasn't found, although some buried debris was found in the area of a conservation bunker in the vicinity of the 1000-meter berm and in a couple grids north of there.
Ms. Dolan noted that at least two or three burn pits and a handful of burial pits were identified, and suggested that the IAGWSP provide a written recap of what was found. Mr. Hill said that the Tech Memo would be a good resource for that information. Ms. Jennings said that she thinks Ms. Dolan's suggestion is a good one. However, there's an ongoing effort to review all the available and data and determine what, if any, data gaps need to be filled in order to consider the source area investigations complete. She also said that she thinks there will be good opportunities to "kind of dissect each of these areas" and provide more thorough presentations, while the purpose of tonight's presentation was to let the IART know that the target evaluations were being done. Ms. Jennings further noted that she thinks it's very reasonable to ask what the source of the plume is, but she doesn't think all the data have been collected yet to answer that question.
Mr. Dow inquired about the depth of the samples that were taken. Mr. Hill replied that with respect to burial pits where munition debris was found, sampling is typically done at the bottom of the pit until it comes up clean, and the completion of the excavation is confirmed using a Schonstedt magnetometer. In cases that don't involve munitions, sampling isn't done. Mr. Dow asked whether RDX and perchlorate are analytes for which the soil is tested. Mr. Hill confirmed that they are.
Mr. Dow also remarked that his recollection is that there are areas of low transmission beneath the soil surface, and multiple sources to the J-1 Range plume. Mr. Hill said that in three-dimensions it's obvious that there's more than one point source. Mr. Dow then inquired about backtracking to determine which grids were prioritized. Mr. Hill replied that particle backtracking was used in identifying priority 1 grids. He also noted that although he doesn't have those graphics with him, they do track back to the interberm area.
Mr. Dow then inquired about the U.S. Environmental Protection Agency's (EPA's) concern regarding expanding the priority grid areas. Mr. Hill replied that this is still under discussion with the regulators; no firm conclusion on a way forward has been reached yet. He noted that beginning with the J-2 Range Disposal Area 2 the IAGWSP and regulators are taking a hard look at all the data to see if more data collection is needed, and will continue to look at the other sub-areas and apply the same type of evaluations.
Mr. Schlesinger referred to a map in the "J-1 Range Priority 1 Grid Supplemental Geophysical Anomaly Investigation Report" and asked why some grids with "higher levels of metal" weren't investigated, while "some of the smaller ones" were. Mr. Hill noted that Mr. Schlesinger was pointing to the 1000-meter berm itself, which was a backstop for the tank munitions that were fired. He said that the berm is assumed to be fairly saturated with 105-mm metallic debris, and added that live warheads weren't typically used in the ballistic testing. Mr. Schlesinger noted that the two-dimensional view indicates that that large berm area is in fact at the beginning of the plume. He also inquired about plans for the berm. Mr. Hill replied that at this point the berm hasn't been identified as a known source area, nor has it been as excluded as one. He noted that most of the work in the interberm area has pertained to the anomalies that surround the berm - "the ones that are safer to look at." He also said that neither the witness interviews nor the archives search report indicate that any type of burial occurred on or under the berm itself; but in the vicinity of the berm because it's such a prominent feature on the range. Mr. Hill said that the berm is believed to be full of metal - but benign types of metals since live warheads weren't used.
Ms. Jennings said that EPA has completed its review of the J-2 Tech Memo and will be submitting comments on the J-1 Tech Memo. She also told Mr. Schlesinger that after the regulators have had the chance to look more closely at the information from different angles, including the cross-sections and particle backtracks, there will be a more robust presentation on what the source areas are believed to be, and why. She said that she thinks Mr. Schlesinger is asking very good questions; however, the answers are not yet available, but will be in the near future.
Mr. Schlesinger asked if there's any way to prioritize areas of lower findings of metal into higher- priority areas to investigate. Ms. Jennings replied that that's how the target approach is established - looking at signal strength in an area to decide what characteristics might be indicative of a burial pit. She also said that the EPA contractor that looked at that approach to identifying targets said that it seemed reasonable. She further noted that essentially the target approach has tried to determine the characteristics of all the metal debris at the ranges that will likely be indicative of a disposal area, and statistics based on what was found in other areas were applied such that in some cases the indication was "to look even though the colors may not give you an obvious answer." She said that some "hot pink" areas may be just metal and not anything of significance. Mr. Hill added that determining what constitutes a contaminated area, without any other information but geophysical signals, is a tough question.
Mr. Walsh-Rogalski said that he believes that the wastewater disposal associated with Textron was a combination of TNT and HMX, and asked whether the IAGWSP has any evidence of those constituents. Mr. Hill replied that there is a very good correlation between that admission on the part of Textron and the groundwater constituents in the plume. As far as the actual point where the disposal occurred, however, it's difficult to say whether or not that's been found. Mr. Walsh-Rogalski asked if the HMX shows up on the map. Mr. Hill clarified that the HMX contamination is contained within the plumes of the other constituents.
Mr. Walsh-Rogalski also spoke about historical disposal of fireworks by burning at the J-1 Range, unrelated to the pits, which he believes was associated with the shutdown of a plant in Hanover, Massachusetts owned by a company called National Northern or Northern Flare. Mr. Hill said that he thinks that fireworks disposal at the base occurred primarily at the J-2 Range, where the state police would bring loads of seized fireworks on a fairly regular frequency. He also noted that fireworks haven't been found in any of the excavations. Mr. Walsh-Rogalski reiterated that he believes that ground disposal of fireworks occurred at the J-1 Range, and asked that the IAGWSP look into any possible correlation between that and the contamination coming from the J-1 Range.
Mr. Walsh-Rogalski then noted that the historical record also indicates use of a disposal method whereby lead azide was spread on the ground and diesel oil put on top it. He then asked about sampling for that kind of constituent. Mr. Hill replied that he's quite certain that sampling has been done, but doesn't have any specifics off hand. Mr. Walsh-Rogalski requested that the IAGWSP look into whether there's any existing data on lead azide at the J-1 Range.
Mr. Schlesinger seconded that request and also asked to have available at future presentations of this sort an individual with more thorough knowledge of the historic reports associated with the sites. He also inquired about the quantity of perchlorate or RDX that's being sought, that would account for being a source to the plumes. Mr. Hill replied that attempting to estimate the mass required to produce a plume is a typical exercise that's undertaken when doing a remedial investigation report, and this will be forthcoming.
Mr. Goydas noted that there are about 10 to 12 kilograms of mass flux per year associated with the core of the J-2 North plume, whereas the trailing edge of that plume has less than one-tenth of a kilogram per year. Mr. Schlesinger clarified that he's not so interested in the rate, but wants to know if it's "bigger than a shoebox" or "the size of a footlocker." Mr. Goydas replied that it depends on the plume. Those with strong concentration gradients, like the J-2 North plume, have much smaller footprints - anywhere from several feet to the size of the head table in terms of a release - while other plumes are less likely to have point sources, or have several smaller point sources.
Agenda Item #4. J-3 Range Soil Remedial Investigation
Mr. Hill showed an aerial view of the J-3 Range, which he noted is about 300 feet wide and 3,000 feet long and adjacent to a mortar rocket impact area in the late 1930s and 1940s. In 1968 the J-3 Range proper was developed for use by AVCO, a defense contractor that was purchased in the 1970s by Textron, which conducted testing of tactical weapons systems and various munitions there up until 1997. Textron's waste management practices involved burning and burial of waste munitions and other energetic materials, as well as the release of explosives-contaminated process wastewater into several dry wells and on the ground surface. Mr. Hill also pointed out two small-scale mortar and rocket impact areas - the barrage rocket site and the hillside impact area. He also noted that over the past few years Textron has performed a number of removal actions, mainly involving the dismantling of its infrastructure at the range.
Mr. Hill reported that J-3 Range investigations involved historical record review, soil sampling, and geophysical surveys, including an aerial magnetometry (air mag) flyover in 2000 and a polygon investigation that identified 12 polygons and led to the discovery of a couple of burial pits and a burn pit. He also noted that areas of explosives and perchlorate contamination identified through soil sampling showed the highest concentrations to be a detonation pit, a burn box, several target areas, and the area around the melt/pour building. Ten sub-areas at the range were examined as part of the J-3 Range soil remedial investigation (RI), which evaluated current conditions - that is, post-RRA conditions.
Mr. Hill stated that the J-3 Range groundwater investigation, which began in 2000, identified two primary source areas for the groundwater contamination - one at the artillery range and demolition area, and the other at the area of the melt/pour building. Mr. Schlesinger said that it would help the team's understanding of what's happening underneath the ground if some cross-section figures were included. Mr. Hill noted that although he doesn't have those figures tonight, they will be provided in the upcoming J-3 Range Groundwater RI/Feasibility Study (FS) report.
Mr. Hill continued with his presentation by noting that the maximum RDX concentration detected in the J-3 Range plume was 35 parts per billion (ppb) and the maximum perchlorate concentration was 779 ppb. He then showed figures depicting red areas that represent contiguous contamination by explosives and blue outlines representing dig footprints where excavations were conducted during the RRA at the melt/pour building area and at the demolition area and artillery range.
Mr. Hill reported that the J-3 Range soil RRA involved the removal of 2,200 tons of soil. He also showed a figure depicting light blue areas representing locations where second, and in some cases, third lifts of soil were removed based on post-excavation sampling. He noted that the RRA was completed in 2004.
Mr. Walsh-Rogalski said that he thinks Mr. Hill said that the melt/pour area is a source of perchlorate contamination. Mr. Hill clarified that it is a source of primarily explosives - mostly RDX with some HMX within the footprint of the RDX plume. Mr. Walsh-Rogalski noted that the source appears to be located right where the "J-3" label is located on the plume map. Mr. Hill agreed and noted that that is the demolition area and artillery range, the other primary source. Mr. Walsh-Rogalski mentioned the target walls in that area. Mr. Hill stated that the target walls were removed by Textron, which also removed some dry wells, storage buildings, containers, and crushed drums from another area of the range, and intends to remove the remainder of its infrastructure there after signing off on an agreement with the Army, which is anticipated fairly soon.
Mr. Walsh-Rogalski asked if it would be accurate to say that the melt/pour area is not a source of perchlorate and is probably only a minor source of RDX. Mr. Hill said that a significant amount of explosives-contaminated soil was removed from the melt/pour area, and it's assumed to be one of the two primary sources. Mr. Walsh-Rogalski said that it appears to him that the melt/pour area is not a major source.
Mr. Schlesinger again noted that the team's understanding would be greatly enhanced if cross-sections had been provided. He also mentioned that he's been requesting cross-sections repeatedly over the past several IART meetings. Ms. Richardson of the IAGWSP apologized for not having provided cross-section figures at tonight's meeting, and explained that while Mr. Schlesinger's requests had been heard and a compact disc containing cross-section figures had been prepared for this presentation, because of an oversight that disc was inadvertently left behind. Mr. Schlesinger acknowledged Ms. Richardson's apology, but noted that even without the cross-sections, it would be easier to understand what's happening if a plume shell diagram were overlaid on top of the figures.
Mr. Dow asked why the perchlorate plume is so much wider than the RDX plume, given that the perchlorate plume mostly comes from the demolition area and artillery range while the RDX comes from a combination of the melt/pour area and the demolition area and artillery range. He also questioned why the concentrated area of the perchlorate contamination is closer to the source area than the RDX is, since perchlorate is known to move faster through groundwater.
Mr. Goydas explained that one reason why the perchlorate plume is wider is because the demolition area and artillery range is slightly upgradient of the melt/pour area, and there's increasingly more splaying with decreased distance to the top of the mound. So, rather than make a beeline toward Snake Pond, the plume begins to splay slightly. In addition, the cross-sectional width of the source is slightly wider for perchlorate than for RDX. Also, in terms of the travel velocities, perchlorate has slightly less retardation in entering the aquifer. Mr. Goydas also noted that the difference in pattern has to do with the source for perchlorate being more recent than for RDX; therefore, perchlorate is seen at higher concentrations closer to the source, and the RDX concentrations have begun to dissipate such that the higher concentrations are seen mid-length in the plume.
Mr. Walsh-Rogalski noted his recollection that one of the small plumelets of RDX came from the L Range. Mr. Hill noted that while plumelets of RDX from the L Range have been identified, they were not depicted on the J-3 Range map being shown, and they are distinctly separate from the J-3 Range contamination. Mr. Goydas added that Mr. Walsh-Rogalski may be referring to the inference in the L Range Groundwater Report that the leading edge of the RDX plume, which is directly upgradient of Snake Pond, may have been related to the L Range release. He also explained that although based on groundwater elevation data and some modeling there's some indication that the very leading edge of the plume might have come from the L Range, there are no analytical data to provide a clear link between that contamination and the L Range.
Mr. Walsh-Rogalski clarified that he had actually been referring to a plumelet east of the main plume that came out of the detonation pit. Mr. Goydas replied that everything "east of this point" is classified as L Range because the RDX concentrations there are all very low, with the highest being around 9 ppb. He said that it's a significant break between the L Range and J-3 Range plumes.
Mr. Goydas stated that the second half of the J-3 Range presentation pertains to the chemical data from the soil investigation. He noted that so far there have been about five workplans and five different soil reports that presented results of the various stages of investigation. About 1,300 soil samples have been collected, 1,100 of which reflect post-RRA, current conditions. Mr. Goydas also noted that the criteria that were used to evaluate the nature and extent of contamination were Region 9 preliminary remediation goals (PRGs) and Massachusetts Department of Environmental Protection (MassDEP) RCS-1 standards. For contaminants to which those criteria don't apply, background values were used, and if no background values applied, site screening levels were used. He further noted that the RRAs were very effective, having left many areas without any contamination that exceeds applicable standards. He also noted that as part of tonight's presentation he would review results of the leaching assessment and human health and ecological risk assessment.
Mr. Goydas began discussing the ten J-3 Range study areas by noting that the melt/pour area, which underwent an RRA, involved a concrete facility built around 1978, primarily for loading of munitions. The concern there was the discharge of wastewater associated with that production and the potential for explosives to reach soil and groundwater. Approximately 1,100 cubic yards of soil was removed during the RRA, and as part of the current study 170 soil samples were collected at 72 different locations. Sample results showed no explosives, perchlorate, volatile organic compounds (VOCs), or pesticides/herbicides at concentrations greater than screening levels. Mr. Goydas then noted that for the purposes of this presentation, he'll be focusing on the primary contaminants - explosives and perchlorate - but will also mention any exceedances of other constituents, whether VOCs or semi-volatile organic compounds (SVOCs). He also pointed out on a figure one location where the concentration of RDX was high enough to warrant evaluation as part of the leaching assessment, although it didn't exceed a PRG. He said that the area around that soil data point would be evaluated as part of the J-3 Groundwater RI/FS.
Mr. Dow inquired about the meaning of "PRG." Mr. Goydas replied that PRG stands for preliminary remediation goal, which is a quick way of determining the significance of contamination, or whether cleanup might be necessary. He noted that PRGs, along with MassDEP RCS-1 standards are helpful because they tend to be conservative in that they consider unrestricted land use, for example, and generally look at surface soils, where the greatest potential for exposure exists.
Mr. Schlesinger inquired about the detection of 2-nitrotoluene, outside of the excavation boundary, at a level that appears to be four times the PRG. Mr. Goydas clarified that the PRG is 36,000, not 36, so the detection does not exceed it. He also said that in terms of spatial distribution, throughout the iterations of the various workplans, decisions were made as to where to look next based on previous results, site walks, and the collection of additional data.
Mr. Goydas also mentioned, with respect to the source areas, that the plume emanating out of the eastern side of the J-3 Range tends to be much shallower in the aquifer than the main body of the plume is. He explained that this is because the melt/pour area is farther south than the demolition area and artillery range.
Mr. Goydas then discussed another J-3 Range study area - the workshop building (which was built in 1968, and where no ordnance activity occurred) and the 20mm/30mm firing ranges. He noted that 80 soil samples were collected at 12 different locations, and investigations to date showed no explosives, perchlorate, SVOCs, or pesticides/herbicides above applicable screening standards were detected. However, one VOC (total-1,2-dichloroethene) was detected above the RCS-1 standard.
Mr. Goydas then referred to the burn kettle/conex area and noted that the burn kettle was actually a U.S. Coast Guard buoy that was set in the ground and used for demolition and burning of excess propellants and munitions. The area also included a flammable storage shed and some conex boxes for the storage of munitions used at other portions of the range. Thirty-two soil samples were collected at 12 different locations and investigations to date showed no explosives, perchlorate, VOCs, SVOCs, or pesticides/herbicides above screening levels.
Ms. Jennings referred to the detection in soil that Mr. Goydas said would be evaluated further as part of the RI/FS and inquired as to the assumed size of the source area in that situation. Mr. Goydas replied that the first step would be to determine if there's leaching potential and the second step would be to determine if there's risk either by dermal contact or ingestion. He also explained that generally the method is to use "the maximum concentration in the two-dimensional approach, which is directly below the sample."
Ms. Jennings again inquired about the size of the source. Mr. Goydas replied that the determination of size would be done in the groundwater RI/FS. He also noted that the recommendation that came out of the current soil report was a "screening level worst-case conservative assumption" that evaluated about 79 contaminants and their potential to reach groundwater at the maximum concentrations. However, the determination of what the cleanup value should be won't be made until the groundwater RI/FS, which will look at the combined risk of soil plus groundwater, and whether soil in a particular location needs to be remediated. Mr. Goydas then noted that in the one case he'd mentioned earlier this evening, the location would be an "extremely small area" as the sample showed residual contamination between the boundaries of two excavations. He added that a lot of contamination was removed as part of the RRA, but there's only sample left in the ground with an elevated concentration and its potential to leach to groundwater will be evaluated in the RI/FS, when the cleanup up value also will be determined.
Ms. Jennings then inquired about any statistics pertaining to the number of samples taken around a particular area after an RRA to determine whether it's clean. She also noted that she worked on a W.R. Grace case in Acton with a simple source area - sludge that was distributed across a lagoon. She said that it was possible to take ten samples there in one day and come up with only one detection, but a statistical sampling approach was designed such that even if there was only one detection out of 20 samples, an additional foot of soil would have to be excavated. Ms. Jennings added that "there had to be some statistical basis to having enough samples to demonstrate that that one was really only representative of that one area."
Mr. Goydas stated that through the various workplans an evaluation was done as to what made sense - composite, discrete, or combination samples, and targeted versus random investigation. Through the aerial photographs, the records search, range records, and so forth, the indication was that a targeted sampling approach would most likely find contamination. However, some less targeted samples were also collected, based on site walks when somewhat disturbed areas were found. Mr. Goydas also noted that the IAGWSP looked at the frequency of detections - for example, where the one detection occurred, the frequency was less than 1%, given that there was only one detection out of 137 samples. Had all the pre-RRA samples been included, however, the frequency would have been much higher.
Ms. Jennings again referred to the W.R. Grace example and said that there are two types of sampling plans - hotspot sampling versus random sampling, "and this almost looks to me a little bit more like random sampling…" Mr. Goydas noted that there are transient effects - for example, a change in wind direction might mean that all of the contaminants end up on the other end of the lagoon. However, with the soil sampling investigation, the contamination will stay in place, with the exception of significant rainfall events. Ms. Jennings said that it was actually a soil remediation that was being implemented at the W.R. Grace site.
Mr. Goydas said that the soil investigation involved reviewing multiple lines of evidence, such as site records and aerial photographs, and determining that the highest probability of finding contamination would be to go after the many different likely source areas that were identified. That's not to say, however, that there weren't instances where samples were collected somewhat randomly, based on site walks.
Mr. Schlesinger implied that Mr. Goydas seemed to be contradicting himself by first speaking about a targeted approach, and then speaking about multiple lines of evidence and having "looked enough." Mr. Goydas clarified that multiple lines of evidence (aerial photographs, range records, witness interviews, archives search report, and site reconnaissance) were used in the selection of soil sampling locations - at the detonation pit, for example, rather than somewhere in the woods where there's no indication of potential contamination. However, there were also occasions when more random samples were taken in less targeted areas, based on site walk observations.
Mr. Schlesinger asked if Mr. Goydas thinks there's been enough sampling at the study locations to assume that they are clean. Mr. Goydas replied that a number of workplans have been implemented, and each step has identified what was needed to meet the data quality objective. He added that the most recent investigation hasn't led to the discovery of a smoking gun or new source area, and it's believed that the data quality objectives have been met.
Mr. Schlesinger referred to Figure 6-18, "J-3 Range, Artillery Range Area, Soil Concentration Explosives," pointed out a particular area, and asked why it hadn't been investigated. Mr. Goydas first provided an overview of that site by noting that it was used from about 1968 to 1983, has a multitude of firing points and target locations, and was used for different types of munitions testing. Some storage trailers were also located there. He also noted that an RRA was conducted at this site and reported that samples reflective of current conditions (of which there were 140 at 53 different locations) showed no explosives, perchlorate, VOCs, or pesticides/herbicides above screening levels. One SVOC (benzo(a)pyrene), however, was detected above its PRG. Mr. Goydas noted that benzo(a)pyrene is a byproduct of incomplete combustion, often associated with coal and oil, and is fairly ubiquitous in the environment. That contaminant was carried through the risk assessment and leaching evaluation.
Mr. Goydas mentioned the following features at the site: firing points, targets, target walls, a drum disposal area, storage, an area where gas guns were fired, a test area, an X-ray facility, and a launch area. He noted that distribution samples were based on known activities, range records, aerial photographs, and previous investigations, and were primarily located around targets, the target walls, the firing points, and different identified potential source areas. He also reported current soil results of one detection of HMX and one of 2,4,6-DNT, but at concentrations less than their respective PRGs.
Mr. Goydas then discussed the demolition area and artillery area, which he noted are in very close proximity to one another. He noted that the demolition area included a detonation pit, a burn box, and a burn area located along the north side of some target walls. He noted that an RRA was conducted at the site. He also reported that 341 samples were collected at 83 different locations at the site, which focused on the various firing points and target locations, and the munitions and projectiles testing activities that occurred there. He also mentioned the ricochet trough area, which was removed as part of the RRA, and some storage bunkers to the west, and some large concrete targets that were also removed at that time.
Mr. Goydas reported that current sampling showed no explosives, perchlorate, VOCs, or SVOCs above screening levels. However, two herbicides (MCPP and acifluorfen) were detected above screening levels, both of which were found in shallow surface soils and are likely related to normal application of pesticides and herbicides.
Mr. Goydas continued by discussing the ordnance assembly/X-ray building and environmental test building site. He described the ordnance assembly/X-ray building as a one-story wood building used for ordnance assembly and quality-control testing and the X-raying of various munitions. He also noted that the environmental test building, located to the north, was actually used to fire the various munitions to the north - with the exact location inferred to be the M550 berm area and other targets to the north. Other areas of concern that were evaluated as part of the investigation were wastewater locations associated with the site - some septic tanks and leach fields.
Mr. Goydas reported that 24 samples were collected at nine different locations. No perchlorate, VOCs, SVOCs, or pesticides/herbicides were detected above screening levels. However, two explosives (4A-DNT and 2A-DNT) were detected at concentrations greater than their screening levels. Mr. Goydas also pointed out a flare area, another area of concern, which didn't rise to the status of an independent study area.
Mr. Schlesinger referred to Figure 6-24, "J-3 Range, Demolition Area, Soil Concentration Perchlorate," noted the three locations where perchlorate was detected (although at concentrations below the PRG), stated that there may be more such locations, and inquired as to the kind of concentrations that would have to be seen in soil to result in a plume of the magnitude that's emanating from that area.
Mr. Goydas replied that just because detections are below a PRG or some other standard doesn't necessarily mean that it cannot impact groundwater, as leaching conditions are specific at each site. Therefore, each of the constituents (regardless of whether it passed or failed a PRG or RCS-1 standard) was evaluated for leaching potential. Mr. Goydas also noted that the concentrations being discussed in this case will not result in a groundwater problem, but added that in addition to concentration, a certain volume of contamination would need to leach to groundwater - and this is specific to a number of considerations, including depth to groundwater, the recharge rate, the mode of deposition (particles or chunk explosives), and the amount of mass. Mr. Goydas stated that these three isolated detections at low concentrations will not leach to groundwater; however, much higher concentrations in a localized area certainly would have the potential to do so.
Mr. Schlesinger said that his question is whether any analysis is conducted spatially from the point where perchlorate is detected (albeit at a level less than the PRG) until no more perchlorate is found. Mr. Goydas replied that it's necessary to determine when there are enough data to move forward with an FS, so there has to be some interpolation of the data. He noted, for example, that one might interpolate between a nondetect and a detection based on a linear interpolation. Mr. Schlesinger clarified that he wants to know whether additional sampling is done around the perimeter of a detection to nondetect, as is the case beneath a soil detection location. He mentioned, for example, the northernmost of the three isolated perchlorate detections on the figure. Mr. Goydas replied that that happens to be a blow-in-place (BIP) location, and BIPs are addressed under a whole different program. He also said that with respect to remaining soil contamination, the first thing to do is determine whether there's a potential to leach to groundwater, and "if the answer is no…then you look at the risk."
Ms. Dolan confirmed for Mr. Schlesinger that the investigation was designed such that whenever a PEP (propellant, explosive, or pyrotechnic) compound was detected, further sampling was conducted to try to find the nondetect boundary. She also noted, however, that the regulators are reviewing the RI report, and there might be locations where there's not a complete delineation, but for the most part there should be. Mr. Schlesinger asked if similar measures were taken to investigate beneath a detection. Ms. Dolan confirmed that they were.
Mr. Goydas then continued with his presentation by discussing the gauntlet area, which was used for a number of different types of munitions testing. He noted that all the potential sources in this large "open, cleared, sandy area" were sampled as part of the gauntlet study. Sixty-two samples were collected at 17 unique locations, and no explosives, perchlorate, VOCs, or pesticides/herbicides were detected above screening levels. However, one SVOC (pentachlorophenol) was detected above screening level.
Mr. Goydas stated the presumed M550 berm area, where it's believed that munitions were fired from the south into a cleared area to the north, was investigated earlier as part of the Munitions Survey Program, when a couple of anomalies were identified and investigated, and some soil sampling was conducted within the confines of the berm area as well. Mr. Goydas reported that 102 samples were collected at 10 locations in the M550 berm area, and no explosives, perchlorate, VOCs, SVOCs, or pesticides/herbicides above screening levels were detected.
Mr. Goydas also discussed the hillside impact study area, which he noted was found during a site walk for the barrage rocket area. He reported that an intrusive investigation ensued following the discovery of some 3.5-inch rockets and 81mm mortars there. That investigation involved a magnetometer surface sweep and some ground-based geophysics at about ten 30' x 30' grids targeted in areas of suspected land use. Mr. Goydas also noted that the hillside area, which is really an impact area without a known firing point, likely predates most of the J-3 Range, and may be related to the Former H Range or the L Range. He then reported that 138 samples were collected at 28 different locations and no explosives, perchlorate, VOCs, or SVOCs were detected above screening levels. Some concentrations of explosives below screening levels were detected, however, (2,3,5-trinitrobenzene, 2,4-dinitrotoluene, 2,6-dinitrotoluene, and 1,3,5-trinitrobenzene), and those values were evaluated further.
Mr. Goydas stated that the barrage rocket study area, which is located in the northwestern-most part of the J-3 Range, is primarily an impact area with unknown firing points. Some ground-based geophysics were conducted there, both in terms of transects and about ten grids. One-hundred-and-forty-seven samples were collected at 45 different locations and no explosives, perchlorate, VOCs, or pesticides/herbicides were detected above screening levels. However, one SVOC (benzo(a)pyrene) was detected above the screening level.
Mr. Schlesinger asked if it's correct that these areas are investigated until nothing further is found. Mr. Goydas replied that that is not the case; rather, the lines of evidence are considered in order to determine when there's sufficient data to proceed. Mr. Schlesinger clarified that his question pertains to the possibility of finding additional contamination at higher concentrations beneath locations where constituents were detected below screening levels. Mr. Goydas replied that this has been considered, but added that 98% of the soil contamination at the J-3 Range, like most other ranges, is found in very shallow surface soils. Subsurface locations (generally burial pits or large caches of munitions) have been defined though other means, such as geophysical techniques. Although it's not impossible that higher concentrations would be found, concentration profiles for almost every single location show that concentrations drop off rapidly over the course of five to 18 inches in depth. Mr. Goydas also noted that the IAGWSP looks for groundwater problems beneath potential source areas, as most of the contaminants will leach to groundwater in just a few years.
Mr. Schlesinger asked how long it will take to determine whether the soil work was effective, based on concentrations in groundwater. Mr. Goydas replied that although a longer period of time would be associated with intact munitions, where soil contamination has been removed, relatively rapid attenuation would be expected. He also mentioned, for example, that the J-2 Range and J-1 Range plumes appear to be essentially detaching from their source areas, and it's hoped that this will also be seen as rapidly at the J-3 Range plume.
Mr. Dow asked whether the benzo(a)pyrene, which is a byproduct of incomplete combustion, might be associated with fuel used in some of the burn pits. Mr. Goydas replied that that kind of pattern was not found when looking for any spatial kind of bias related to specific activities. He also noted, however, that the risk assessment indicated that that particular SVOC doesn't drive risk.
Mr. Goydas then reviewed the J-3 Range RI Report conclusions, as follows: no new significant source areas were identified; 79 contaminants were analyzed for leaching potential and of those, RDX and nitroglycerin were found to have leaching potential, which will be further evaluated in the J-3 Groundwater RI/FS; and the risk assessment indicated that values for risk are below the applicable benchmarks, and in the case of future residential scenario, at the low end of the risk criteria range. Also, some eco-toxicological risk associated with thallium and titanium was assessed, but the significance of that risk is discussed in the uncertainty section of the report. Mr. Goydas also stated that the recommended next step is to further evaluate future potential groundwater impacts in the J-3 Range Groundwater RI/FS report and risk assessment.
Ms. Jennings inquired as to the areas where the leaching potential of RDX and nitroglycerin is a concern. Mr. Goydas replied that the concern is associated only with the two locations where RDX was seen at elevated concentrations (one being at the melt/pour area), and the few nitroglycerin locations. He also noted that nitroglycerin has never been detected in groundwater in the area.
Mr. Walsh-Rogalski asked if the detonation pit is considered part of the demolition area. Mr. Goydas confirmed that it is. Mr. Walsh-Rogalski also asked if the burn box data were separated out for the purposes of tonight's presentation. Mr. Goydas replied that they were not, but those data are included in a table contained in the report.
Ms. Dolan noted that the soil RI report only includes existing data, and not data associated with the RRA. Mr. Goydas added that tonight's presentation focused on current existing data for explosives and perchlorate, but the report includes all the data for the other analytes as well. Any other data associated with the burn box would be contained in the J-3 Range RRA report, which looked at evaluating any remaining human health or ecological risks and impacts to groundwater. Mr. Walsh-Rogalski asked if this means that there are no current data with respect to the burn box. Mr. Goydas clarified that the data provided in tonight's presentation is reflective of what's currently in the ground - regardless of when those data were collected. Mr. Walsh-Rogalski suggested that what was done then was a separating out of anything where the RRA was performed. Mr. Goydas confirmed that that is the case, because it isn't reflective of current potential risk.
Mr. Schlesinger said that in terms of understanding, it would be useful to know what was removed. Mr. Goydas replied that the report contains an entire section that describes the RRA removal activities and includes graphics that show the outlines of removal areas. It does not, however, include the data or the risk or leaching potential associated with pre-RRA contamination. He also noted, however, that some link would be made between the current plume and past sources as part of the J-3 Range Groundwater report.
Mr. Schlesinger remarked that he hopes that will involve a graphic presentation to the IART, as it's difficult for the citizen members of the team "to connect what happened in a report presented five months ago with something that's being presented this night…" He also mentioned the idea of an overlay to help the team's understanding. Ms. Dolan said that she agrees with Mr. Schlesinger, and that EPA would like to see "several locations also." She also asked anyone with comments on the report to forward them to her and to the IAGWSP.
Mr. Hill stated that the best resource for information on the RRA is the J-3 Range Soil RRA Completion Report. Mr. Schlesinger explained that the issue is that that information isn't readily available tonight, which makes it difficult to put the recent data in context. Ms. Richardson clarified that graphics included in tonight's presentation included pre-excavation figures (before the RRA was conducted) as well as post-excavation figures from the Completion of Work report Mr. Hill mentioned.
Ms. Jennings said that she played a large role in trying to help the IAGWSP formulate this presentation, and it was difficult to condense the large amount of information from the RI report into something that's easily understood. She also said that she thinks that Ms. Richardson and the others who worked on the presentation "tried really hard" to do that. Ms. Jennings also encouraged the IART members to take the time to review the report. She noted that the regulators are reviewing the document and will be offering comments. Once those comments are resolved and agreement is reached on the conceptual model for the site and what the source areas are, the IART will be provided with a very concise presentation that looks at all the lines of evidence.
Mr. Dow inquired about the hazard indexes for the titanium and thallium that Mr. Goydas mentioned when talking about the ecological risk assessment. Mr. Goydas replied that although he doesn't have this answer off the top of his head, he does recall that they were not excessively high in terms of significant risk. Mr. Dow asked if the ranges were significantly different than 1. Mr. Goydas replied that he doesn't believe so.
Agenda Item #5. Small Arms Range Update
Mr. Nixon stated that there are 24 small arms ranges (current and former) where pistols, rifles, machine guns, and the like were used. Most of the small arms ranges have backstop berms, intended to the catch the bullets right behind the target line. The ranges came into use around 1940, and lead ammunition was used up until 1997 when EPA issued administrative order #2 (AO2), which ended the use of lead ammunition due to leaching concerns. Plastic ammunition came into use at that time, and then in 1999 tungsten/nylon, which was thought to be a "green" bullet, started to be used at the ranges. Use of tungsten/nylon was terminated earlier this year, and at this time only plastic bullets continue to be used.
Mr. Nixon reported that in 1998 the IAGWSP undertook a project that involved treating soil from 16 of the small arms ranges with a product called MAECTITE - a phosphorus material that binds up lead, taking it from its soluble form to an insoluble form. As part of that effort 28,000 tons of soil was excavated, screened, and treated, during which about 60 tons of lead bullet fragments were removed. In addition, about 8,000 tons of soil was treated in place. The soil that was treated was primarily associated with berms; however, the "mini-berms" located in front of pop-up target ranges were also treated with MAECTITE. Mr. Nixon noted that the maximum lead concentration detected before treatment was 12,200 parts per million (ppm). He also noted that the highest concentrations were generally found in the first two feet of soil, which made sense given that the bullets penetrated the first two feet of the berms. After treatment, the maximum lead concentration detected was about 5 ppm, using a TCLP (toxicity characteristic leaching procedure) analysis, which uses an extraction with a mild solvent to imitate rain water percolating through soil. With less than 5 ppm of leachate, all the soil passed the criteria set by EPA.
Mr. Nixon also reported that in 2002/2003 the IAGWSP undertook investigations at the small arms ranges that looked at firing points, berms, and other areas of the ranges. Soil samples were collected and analyzed for propellants, metals, and SVOCs, and contamination levels warranting further investigation were found at several of the ranges. In February 2005 the IAGWSP proposed a workplan to determine the extent of that contamination. However, that workplan was affected by construction projects that the Army Guard was planning at three of the ranges in that the IAGWSP decided to categorize them as being the top priority areas in terms of the small arms ranges investigation.
Mr. Nixon noted that at Tango Range the Army Guard will be building a berm and installing a STAPP bullet collection system, which will allow firing of ammunition other than plastic bullets. He noted that the STAPP system is comprised of a "ground-up rubber tires" material in which the bullets become trapped and from which they are later removed, without entering the environment. At the Sierra East/Sierra West Range, which is actually two separate ranges that are side-by-side and separated by a widening strip of trees, the Army Guard will be combining the two ranges into one large range and adding new pop-up targets. Mr. Nixon noted that the Sierra East/Sierra West Range, which is about 900 meters long, is used mostly for machine gun and rifle training. He also noted that Echo Range is going to be updated with some new pop-up targets.
Mr. Nixon stated that the investigation at Tango Range has been completed. He also noted that a multi-point sampling approach based on decision units, rather than the former grid approach, was used. He showed a figure depicting the ten decision units, which included firing lines, target rows, and other areas of the range. Mr. Nixon then reported that the maximum lead detection was 131 ppm and noted that the MassDEP RCS-1 standard for lead is 300 ppm. Tungsten concentrations ranged from 0.7 to 71 ppm; however, there is no standard for tungsten at this time. Nitroglycerin was found at a fairly elevated concentration of 47,000 ppb, although the significance of that detection hasn't yet been determined. Mr. Nixon noted that nitroglycerin is a propellant contained in the cartridge of the bullet to move the bullet forward, and is expelled out of the end of the gun barrel, and so it was not surprising to find it right near the firing point. He also said that before starting construction of the berm for the STAPP system, the top soil was stripped off and an additional round of sampling for tungsten was conducted, with nondetect results.
Mr. Nixon said that the final sampling plan for Sierra East/Sierra West hasn't yet been completed. However, the idea again is to divide the area up into decision units, conduct the same type of sampling, and run the samples through the same types of analyses. He noted that in the 2003 investigation, some SVOCs were detected at levels slightly above applicable standards. More samples were taken and although that effort hasn't been completed, some detectable 2,4-DNT and some nitroglycerin was detected. That contamination will be characterized further when the sampling plan has been finalized and implemented.
Mr. Nixon stated that the IAGWSP and the regulators are currently working out the details of the sampling plan for Echo Range, a pop-up target range where pistols are fired. He noted that it's hoped that sampling there can begin this week or next week at the latest. He also reported that work conducted there in 2002/2003 resulted in the detection of some metals and some SVOCs, but all below applicable standards. Mr. Nixon then noted that Echo Range is much shorter than Tango Range and displayed the figure depicting the decision units there. He also said that samples collected from Echo Range will be analyzed for metals and tungsten (focusing on areas where bullets would land) and for SVOCs and explosives (focusing on areas near firing points). Mr. Nixon remarked that using knowledge of site activities to help tailor and focus the sampling program is a big step forward.
Mr. Nixon then stated that future activities associated with the small arms ranges include completing the current investigations and determining whether any remediation is necessary. He also mentioned that nitroglycerin, when used in propellants, is generally found bound in a wood-like fiber called nitrocellulose, which lessens its potential impact to groundwater. Nevertheless, its potential to impact groundwater will be evaluated, and it's possible that monitoring wells might be installed in the future, if deemed necessary. Mr. Nixon also stated that once the investigations at Tango, Sierra East/Sierra West, and Echo Ranges are completed, knowledge from those investigations will be used in developing the workplan to address the remaining ranges.
Mr. Schlesinger asked if the fast-tracked ranges are the ones the military wants to use soon. Mr. Nixon clarified that the military wants to complete construction there soon, but probably won't used them this training season, with the possible exception of Tango Range, if the STAPP system is put in place on time. Mr. Schlesinger asked if that would require first knowing more about the concentrations of tungsten and what they mean. Mr. Nixon replied that the STAPP system is designed to catch and prevent exposure to the environment of any bullet that's fired, no matter its composition.
Mr. Begley of the Environmental Management Commission (EMC) explained that the internal component of the STAPP system is ground-up tires. Below it is a liner that serves as a leachate collection system, and above it is a rubberized material similar to a landfill cap. The bullets go through the rubberized material, which doesn't quite seal itself but also doesn't open up at the same diameter as the bullet that passes through it, thereby not allowing a lot of rainwater infiltration such that not much leachate or contamination is generated. Also, the rubberized material can be patched at areas of concentrated firing. Mr. Begley also noted that the STAPP system being installed at Tango Range is really a demonstration/validation test of the system rather than a permanent installation. He added that the system will be examined closely to determine whether it makes sense to use the tungsten ammunition. He also noted that the system has been demonstrated at other locations for use with lead ammunition.
Mr. Schlesinger inquired about the remaining eight ranges that didn't undergo the MAECTITE treatment process. Mr. Gonser said that he thinks those were former ranges and didn't include berms per se; many of them are now just wooded areas. He also said that all the ranges the military plans to use will have some mechanism to address range firing. Mr. Nixon added that those eight ranges either were included in the 2003 investigation or will be included in the ongoing investigation, after the three priority ranges have been addressed.
Mr. Schlesinger then asked if there's a plan to further break down the decision units flanking the one near the firing line identified as "north," where nitroglycerin was detected. Mr. Goydas replied that his recollection is that samples weren't taken on the flanks, only in the center. He also said that if it turns out that the detection is determined to be a potential problem, it's likely that that sampling will be done.
Mr. Dow asked Mr. Nixon to identify the ranges where testing was done for tungsten in groundwater. Mr. Nixon referred to Bravo Range (which was most heavily used for tungsten), Charlie Range, and Sierra East/Sierra West. Mr. Dow also asked how long it would take for lead or tungsten that lands in the soil and not in the STAPP system to leach to groundwater. Mr. Nixon replied that although all the parameters are not yet available to model for tungsten, it takes a long time for lead to migrate through the soil. Mr. Dow said that while inorganic lead doesn't move very fast, methylated lead has been found to move quite rapidly. He also noted that he would have assumed that tungsten is immobile, but that is contradicted by the data. Mr. Nixon noted that there's an ongoing study to determine how mobile tungsten is. Mr. Dow asked when that study is expected to be completed. Mr. Nixon replied that he doesn't know.
Ms. Baugh of Marstons Mills inquired about the possibility of air emissions from firing of tungsten bullets. She also inquired about the elevation of the small arms ranges. Mr. Nixon replied that the ranges are located on fairly high ground, a couple hundred feet above sea level, which is typical of the base. He also noted that he's uncertain how relative that is to the mobility of tungsten, but doesn't think it's enough to make any kind of difference in that regard. Ms. Baugh said that her point is that this really isn't known; therefore she questions why other studies, such as tree ring studies, aren't being conducted. Mr. Nixon agreed that the studies are focused on soil and leachability to groundwater, and do not address particulate emissions in the air.
Mr. Schlesinger remarked that if tungsten is mobile through the air and there's some deposition beyond the ranges, it could be affecting the groundwater from source locations that are unknown. Mr. Nixon replied that the evidence seems to indicate that when a tungsten bullet hits something fairly solid, like a berm, it does fragment into a coarse, powdery form, as it's made of compressed powder and so probably does spread a little bit. He also noted, however, that while he wouldn't say that it can't get into the air, he's quite sure that it would land quite close to where it impacts the ground.
Mr. Schlesinger said that he thinks it's important to find out whether the tungsten being introduced into Cape Cod's environment might be affecting people downrange. Mr. Nixon noted that tungsten firing has been halted, and if it does resume, the tungsten will be fired into the STAPP system, such that there's no release to air. Mr. Schlesinger replied that he is still concerned about the tungsten that already has been introduced to the environment. Mr. Gonser agreed to find out from the ammunition manufacturers their thoughts on how tungsten rounds react on impact - whether the tungsten could become airborne or not. He also noted that although the particles are quite small, the reason tungsten is used is because it's very heavy, and so it's unlikely to blow away too far. Mr. Gonser also said that he would discuss this issue with the U.S. Army Environmental Center (AEC), whose people have collected a large number of soil samples, and see if it's possible to link up known wind directions with areas where tungsten was detected.
Mr. Schlesinger then asked if any soil or groundwater testing for tungsten has been conducted outside of the ranges. Mr. Gonser replied that the soil sampling being conducted by the AEC and the IAGWSP is focused on the ranges because that's where most of the tungsten is expected to be found. He also said that the Sierra East/Sierra West Ranges are quite big so it might be possible to see if there's any kind of trends there, and he'll ask AEC to be aware of that sort of thing. Mr. Schlesinger added, "Not just trends spatially, but related to where there's prevailing wind."
Mr. Begley said that it might be helpful to have a cross-section illustration of Tango Range - a side view that includes the firing location and the trajectory of the bullet, which could continue past the target and off the range. He then explained that the small arms ranges are oriented toward the Central Impact Area because a projectile could travel considerably farther than the ranges that don't have berms. Mr. Begley then noted that half of Charlie Range has a berm and the other half does not, and added that there's a transition zone between the two, which is relatively flat land where there could be additional tungsten.
Mr. Schlesinger said that he thinks it's important for Cape Cod residents to understand the potential for tungsten to migrate, and for the military to try to answer questions about how range activity might affect or could have affected the health of those residents.
Agenda Item #7. Open Discussion
Mr. Schlesinger inquired about the priority for future IART agenda topics. Mr. Gonser replied that basically the priority is based on the reports that are being issued, including the forthcoming RI reports for the Northwest Corner, Gun and Mortar Positions, and the Western Boundary. Mr. Murphy said that a list of upcoming agenda items could be provided at the next IART meeting.
Mr. Schlesinger recommended adding to that list a substantive presentation on tungsten. Mr. Gonser replied that although most of the tungsten studies are currently under way, he thinks that a presentation could be made on what's currently known about tungsten. Mr. Schlesinger said that that would be helpful.
Agenda Item #8. Adjourn
Mr. Murphy noted that the IART would meet next on June 27, 2006 at the Best Western Hotel in Bourne. He then adjourned the meeting at 8:55 p.m.
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