Letter Calling for Nat'l Testing of Impact Areas

[Paul Zanis <ZAP59@aol.com>]

Subj: Re: Letter Calling For National Testing of Impact Areas

~I would like to have the opportunity to respond to CPT. Boggess's correct
information. ~I have placed the citizens correct information under Cpt
Boggess.
~Paul Zanis Impact area review team~

**** (NOTE: all of Paul Zanis's comments begin with a tilden [~]) ****

Citizen involvement in the environmental investigation and cleanup at
MMR is very important. However, this e-mail contains some inaccurate
information. I have placed the correct information along side of the
original text.

Thank you for this opportunity to correspond with you.

CPT James L. Boggess
Project Officer, Impact Area Groundwater Study
Massachusetts Military Reservation

> The following letter was generated by citizens working on a study of the
> Massachusetts Military Reservation Impact Area. A number of people from
> other bases added their signatures in support.
>
> ********************************************
> January 17, 1998
>
> Sherri Wasserman-Goodman
> Deputy Undersecretary of Defense for Environmental Security
> The Pentagon - Room 3 - E808
> Washington, DC 20301-3400
>
> Carol Browner
> Administrator
> U.S. Environmental Protection Agency
> Headquarters Building--Waterside Mall
> 401 M Street, S.W.
> Washington, D.C. 20460
>
> Dear Ms. Browner and Ms. Goodman:
>
> We wish to bring to your attention the implications of results obtained so
> far from an EPA-supervised study of the soil and groundwater at the 2,200
> acre Camp Edwards impact area at the Massachusetts Military Reservation.
>
> Since the beginning of the study in the Summer of 1997, carcinogenic
> contamination has been documented in the soil and in the aquifer below the
> impact area and at firing positions. So far twenty wells have been found to
> contain explosives contamination and twenty-one wells still need to be
> completed.

(To date explosives and explosive-associated compounds have been
detected in eleven wells at eight locations. Eight of those wells at
seven locations were recently installed as a part of this
investigation. The remaining three wells were installed by the
Installation Restoration Program in response to Chemical Spill #19
(CS-19). These wells were known to have explosive compounds and were
re-tested to confirm those findings. )

~ The citizens don't really care who puts the wells in, its whats found in
them that counts. I reported the sight thats called CS-19 in 1990. Four Wells
were finally drilled in 1994 by AFCEE. The explosive compound RDX, chromium,
acetone was detected and considered COPCs. The National Guard continued its
heavy use of the impact area eventhough they now knew explosives and its
associated products are in the soul source aquifer. In November 1996 the 
study
was expanded to only one-half-mile radius out of more than 2,200 acres and
avoiding ground zero, twelve wells were added at various depths. Range firing
continued, several wells found RDX. Then came the cease fire order by the EPA
and the impact area was set on fire by Guardsmen. A study done in 1994 by the
IRP in the area called FS-12 found TETRYL an explosive compound in well WT-3
about two miles to the east from CS-19. In July1996 TNT was detected in a 
long
range water supply exploratory well MW-3 at site 2 by Stone &webster about
four miles to the west of CS-19. The National Guard has waited to test known
areas of contamination last, example demolition area-1. Only one well was
placed where the citizens wanted it and that was MW-1, it found RDX. Phase-2
of the study we the citizens may be able to chose where wells go, we will 
find
more RDX. All detections of toxins large or small are very serious to the
people who live here. This aquifer under the impact area is our last hope for
clean water on the upper Cape Cod. ~

> Numerous soil samples in the impact area have shown an array
> explosives, heavy metals, other inorganics, herbicides, and volatile
> organic compounds. Soil samples taken from the gunnery positions show
> chemical contamination from propellants.

(Analysis of soil samples from the artillery gun and mortar
positions, taken as a part of this investigation, has not been
completed. The soil results taken from the primary target locations
indicates that explosive compounds are rare, with only trace
detections at six out over 100 locations. Additionally, only trace
levels of a few pesticides, herbicides and volatile organic
compounds have been detected in any of the soil samples.)

~Once again the soil samples were carefully chosen and placed in areas of
scaring from fires. Every year they burned the impact area using accellerants
thereby consuming the explosive compounds. After a day of artillery/mortar
firing heavy salvos of white phosphorus rained down on the target area
consuming any explosive compounds residue. (Note, white phosphorus is used
normally for spotting targets first, then high explosive is used for effect.)
When I asked for a soil sample area they told me their was to much debris.
Older studies of gun positions have shown high amounts of propellant
byproducts(DNT's). The National Guard has failed to give the team its
findings/reports on Heavy metals, pesticides, herbicides and volatile organic
compounds we must go to the library to study the huge amount of information.
Its to early in the study to say whats trace levels of anything. I have 
always
stated that the impact area was defoliated.~

> Moreover, the latest findings
> appear to confirm the existence of at least two plumes of
> explosives-related contamination spreading from the impact area toward
> remaining clean water supplies on Upper Cape Cod. As you may be aware,
> water supplies for the entire region of Upper Cape Cod have already been
> damaged by extensive groundwater contamination from Otis Air Base.

(Since the relationship between the detections has not been
completely established, it is premature to state that any "plumes"
exist. The Army National Guard is working with the U.S. Geological
Survey, the Environmental Protection Agency and the Massachusetts
Department of Environmental Protection to evaluate the data and
determine what additional investigation may be warranted.)

~If its premature to state the word plume check out the National Guards web
sight
 www.magnet.state.ma.us/guard/mmr The guard is quick to say the
contamination is minor and not from them! The Guard has spent more time
measuring the water levels and doing modeling so they can blame somebody else
for the contamination. They will model it till it works for them. Speaking of
additional investigations,a third of the information is in and we are going 
to
have a phase 2 of the study.

> It is now clear that artillery, mortar, and demolition practice threaten
> groundwater resources. Therefore we urge you, the officials most
> responsible for overseeing the environmental effects of military
> activities,to create pilot studies of the soil and water at each of the
> major artillery and mortar ranges in the United States. These studies would
> assess the danger posed by munitions firing and demolition at each of these
> ranges while providing data from a diverse set of conditions to augment the
> findings at the Massachusetts Military Reservation.

(The soil results indicate that the groundwater contamination is from
a source other than artillery and mortar firing. The trace levels of
explosives found in the soils at the target locations cannot account
for the detections of explosive compounds in the groundwater.)

~The National Guard sounds like they are making conclusions to the study with
no evidence behind their claims.
 I showed the Guard over 1000 buried mortar rounds in a high state of decay
3500 feet behind a school. The National Guard went to the school committee
with a map of false distances (bombs to school) and statements that the bombs
are perfectly safe. Now that it has been brought to their attention that the
bombs are dangerous,contents unknown and closer to the school, they want to
detonate them.
On a tour of the old ranges discussing lead removal Cpt boggess stated that a
50cal bullet contains 1% lead no cleanup needed. Yes, one out of the five
different bullets a 50cal shoots does contain 1% lead. But at training ranges
lead bullets are used. Their called called ball ammo. I picked up five 
bullets
randomly from an old berm, four were solid lead one was armor piercing(1%
lead). We also went looking for more buried munitions, do you think the
National Guard came prepared? Not even a metel detector. Did you know when a
bomb blows up its complete combustion? How about a special bulldozer that
shatters boulders? I could write a book on examples of misinformation,
explaining it away, skewing the facts, minimizing information and finger
pointing. The National Guard does not want to cleanup the fifty old gun 
ranges
and the impact area although the lease states they must.

> We would be willing to meet with you in order to discuss details of this
> proposal. Tribes, indigenous peoples and all other stakeholders should have
> a valid, active role in setting criteria and methodology for this testing.
> We look forward to hearing from you about this urgent matter.
>
> Sincerely,
>
> Joel Feigenbaum
> Alliance for Base Cleanup (MMR)
>
 James Kinney
> Alliance for Base Cleanup (MMR)
>
> Richard Hugus
> Otis Conversion Project, Massachusetts Military Reservation (MMR)
>
>~ Paul Zanis DAV
> MMR Impact Area Review Team~
>
> Laura Olah
> Executive Director of Citizens for Safe Water Around Badger (CSWAB)
>
>
> Bill McGlinn
> Ann R. Miller
> Richard B. McGlinn
> David M.McGlinn
> Peter Strauss
> Rusty Gates
> R. Bruce Johnson
> Bob Linsenman
> Dan Drislane
> Edward McGlinn
> Lenny Siegel
> Grace M. Potorti
> Tess Nelkie
> Steve Southard
> Steve Sendek
> Skip Favro
> Ruth Favro
> Ron Weber
> Pat Dwyer
> Jim Schramm
> Jay Gleason
> Dan L. Alstott

CPT James Boggess, Project Coordinator