Draft MMR Impact Area Fact Sheet

[Lenny Siegel <lsiegel@cpeo.org>]

[Please note that the following is a draft, not the final fact sheet.-LS]

Facts on The Impact Area Groundwater Study At Massachusetts Military
Reservation (MMR)
DRAFT 6/10/99

Introduction

In July 1997, the United States Environmental Protection Agency ordered
the National Guard Bureau to conduct a study of the Impact Area and
Training Ranges at the Massachusetts Military Reservation to determine the
impacts of military training at MMR on the underlying sole source aquifer,
a water supply of vital importance to the residents of Cape Cod. The Order
also created the Impact Area Review Team, a citizens advisory committee
formed to advise EPA on the study. The Impact Area Review Team, EPA, the
Commonwealth of Massachusetts and the National Guard Bureau have developed
this fact sheet to summarize results of the study, which is ongoing, for
the public.

This Fact Sheet:

1. Summarizes information about contamination found at the Impact Area
and Training Ranges;      
2. Discusses the relationship between military training activities and
contamination;
3. Summarizes the impact of this contamination on the aquifer as a
future water supply; and
4. Summarizes additional steps to be taken in the study.

1.  WHAT WE KNOW ABOUT CONTAMINATION AT THE IMPACT AREA AND TRAINING
RANGES AT MMR

A.   Explosives

Explosives used by the Department of Defense (DOD) have been detected in
the groundwater under the Training Range and Impact Area, including RDX,
HMX, TNT, 2AmDNT, 4AmDNT, and 2,4-DNT.  The explosives most frequently
detected is RDX, which is classified by EPA as a Class C carcinogen (a
possible human carcinogen). RDX has been detected both below and above
EPA's Health Advisory of 2 parts per billion (ppb).  According to
validated groundwater data, RDX has been reported in fifteen monitoring
wells; twelve of the wells had RDX above the Health Advisory. Of the
twelve wells, four are in CS-19, two are in Demolition Area 1, two are
downgradient of the contractor-operated J ranges, and four are in the
Impact Area.  The groundwater explosives detections can generally be
grouped into five geographical areas, as follows:

1.  Demolition Area I:  Demolition Area I, a formerly used training area
for demolition, is located south of the Impact Area and north of
Pocasset-Forestdale Road.  Ordnance use included C-4 (RDX/TNT), TNT and
other explosive charges under 40 pounds. The Massachusetts Army National
Guard (MAARNG) also conducted open burn/open detonation disposal of
munitions in this area.  A monitoring well installed approximately 750
feet from the center of the demolition pit has exhibited the highest
concentrations of RDX (370 parts per billion (ppb).  The National Guard
Bureau is continuing to investigate the extent of groundwater
contamination in this area, which is known to extend downgradient at least
one half mile to the west.

2.  Chemical Spill (CS)-19:  The CS-19 site is a small area in the
west-central region of the Impact Area. The area was used for the burial
and burning of ordnance. The highest concentration of RDX detected in
groundwater at this location was 22 ppb at in the cental area of CS-19.
The extent of groundwater contamination in this area is currently being
characterized by the Air Force.  NGB, as the party ultimately responsible
for this investigation, will ensure that the investigation is conducted
according to procedures established for the Impact Area Groundwater Study.

3.  Southeast Corner of the Range:  Explosives have been detected in wells
outside of the Impact Area north of Snake Pond close to the
contractor-operated "J' ranges. This area lies close to the top of the
groundwater mound of the critically important Sagamore Lens of Cape Cod's
sole source aquifer. For the last thirty years, the J Ranges have been
operated by defense contractors. However, the MAARNG has recently
terminated the license with Textron Systems to operate on the J-3 range. A
condition of the prior license was that the premises be restored to a
condition satisfactory to the Army. Existing documentation suggests that
bulk explosives were disposed of to the ground surface as well as to below
ground holding tanks.  RDX has also been detected in a well installed near
the melt-pour facility on the J-3 range at 12 ppb. A buried cache of
approximately 1,100 primarily inert artillery and mortar rounds was
exhumed from the J-1 range in 1998. Additional investigations to determine
the extent of soil and groundwater contamination in this area are planned.

4.  Central Impact Area:  Other detections at various depths in the
aquifer track back to, or originate from, the center of the Impact Area.
The center contains two large high density target areas where mortar and
artillery with high explosive warheads were fired for many years. To date
there have been four validated detections of explosives above Health
Advisories associated with the central portion of the Impact Area at
MW-23, MW-1, MW-2 and MW-38.  Mortar and artillery use are a likely source
of the contamination; however, other activities such as munitions disposal
may be contributing to the contamination. Studies are ongoing to establish
the extent of soil and groundwater contamination.

5.  KD Range:  Soil at the KD target areas is contaminated with explosives
RDX, HMX, TNT and TNT breakdown products.  It is also contaminated with
nitroglycerin. RDX was detected up to 371 micrograms/kilograms (ug/kg) and
HMX was detected up to 2,013 ug/kg in soil samples collected near targets.
Groundwater wells will be placed at this range.

B.  Propellants

Propellants are used in the firing of artillery, mortars and small arms
and serve to propel a projectile.  Propellants may have entered the MMR
environment either from the firing of weapons and/or from the burning of
propellants, a practice that continued until the 1990s.

1.  Gun Positions:  Propellants, primarily 2,4-DNT, have been detected in
soil samples taken at several gun positions that are representative of
high, medium and low use areas.  No explosives or propellant compounds
were detected at the three mortar positions sampled. Additional soil
investigations will be conducted at the remaining mortar and gun
positions. Samples will be collected from the firing positions and at
downwind and downrange locations. Groundwater wells will be placed at the
four most heavily used gun and mortar positions.

2.  The KD Range:  The KD range is located southeast of the Impact Area,
on Pocasset-Forestdale Road.  The area was primarily used for rocket
training.  The propellant nitroglycerin was detected at several firing
points at the KD Range at concentrations up to 91,700 ug/kg.

C.   Other Chemical Contaminants

A variety of other contaminants have also been detected.  Interpretation
of the findings, including their source, is continuing.

1.  Metals:  Metals have been identified in soils and groundwater
throughout Camp Edwards. Metals detections above federal drinking water
standards known as Maximum Contaminant Levels (MCLs) were reported in
thirteen wells distributed across the study area, both in training areas
and the Impact Area, and in areas not used by the Guard. The metals
reported at levels above MCLs include sodium, zinc, lead, molybdenum,
antimony and thallium.

2.  Herbicides and Pesticides:  Herbicides and pesticides were detected in
soils and in eight monitoring wells at levels below MCLs. Many of the
detections were along the western property line of the base.

3.  Volatile Organic Compounds (VOCs): VOCs have been detected throughout
Camp Edwards at concentrations below MCLs.  Compounds reported include
toluene, chloroform, acetone, dibromochloromethane, benzene, TCE and
xylene.

D. Unexploded Ordnance (UXO)

Unexploded Ordnance (or UXO) are munitions that do not function as
intended. UXO still contain explosives compounds, which present a threat
to groundwater. In addition, UXO present a safety threat to persons within
the blast range of the munitions. UXO can be located either on the
surface, or if they were buried or fired, below the surface.

1.  Surface UXO:  A March, 1999 report conducted by the Army Corps of
Engineers for the National Guard Bureau concluded that the risk posed by
UXO at MMR ranked as Category I or "catastrophic" on the Corps' safety
risk assessment scale of one to four.  This report recommends an emergency
response for the UXO at 15 of the 19 areas examined at MMR, and concludes
that *virtually every type of OE (live ammunition or components, debris
derived from live ammunition, CWM or explosives which have been lost,
abandoned, discarded, buried, fired or thrown from demolition pits or
burning pads) has been discovered in various areas of MMR.  It is worth
noting that the Corps concluded that UXO risks deserved a catastrophic
rating despite a mistaken belief that the base had controlled public
access. In fact, large sections of the base and Impact Area boundary are
unfenced.

2.  Buried UXO:  Prior to the 1970s, it was common practice for the
military to dispose of UXO by burial. In December of 1997, a cache of over
1,100 rounds (mostly inert) was exhumed at the J- I range. Since that
discovery, EPA has required the National Guard to conduct a survey for
buried UXO as part of the groundwater study. The first phase of this
survey, to be conducted during this calendar year, will examine 50% of the
J Ranges, half of the positions from which artillery and mortar were
fired, Demolition Pit 1, several ponds that may have been disposal areas,
and one or two target areas that may contain unexploded or partially
exploded munitions. The goal of the UXO survey is to locate UXO that may
present a continuing source of contaminants to the underlying aquifer. UXO
discovered during this process will be disposed of in a mobile detonation
chamber which is scheduled for delivery to the base by July, 2000.

2.  WHAT WE KNOW ABOUT THE IMPACT OF TRAINING

While the study to date has focused on understanding the nature and extent
of contamination rather than an effort to tie specific training activities
to contamination, a number of conclusions can be drawn. These include:

A.  Explosives

1.  Demolition Pit 1: The explosives in groundwater at and downgradient of
Demolition Pit 1 are the result of demolition training and the disposal of
explosives by open detonation.

2.  Chemical Spill 19:  The explosives in groundwater at and downgradient
of CS -19 are probably a combined result of in munitions disposal and
artillery and mortar training. Note that NGB believes that the explosives
in groundwater at and downgradient of CS 19 is caused by munitions
disposal only.

3.  J Ranges:  The explosives in groundwater at and downgradient from the
J Ranges is probably the result of use and/or disposal of high explosives
by contractors on the J Ranges.  Other training activities, such as old
ranges, may have contributed to this contamination.

4.  Central Impact Area:  The explosives in groundwater at and
downgradient of the central impact area is the result of artillery and
mortar training. Munitions disposal may be a contributing source of
contamination here.

5.  KD Range: Explosives in soil at the KD range is the result of training
activity.

B.  Propellants

Soil contamination by propellants at the high use gun positions and at the
KD Range is the result of training. Investigations are ongoing as to
whether any groundwater contamination exists at these areas.

C.  Other Chemical Contaminants

1.  Metals:  Metals contamination may be related to training activities.  
Further investigation into the source, nature and extent of metals
detections above MCLs will occur if determined above concentrations
representative of the aquifer.

2.  Herbicides and Pesticides:  It is not currently known whether
herbicide and pesticide contamination are a result of training activities.

3.  VOCs: VOC contamination may be related to training activities.  It has
been reported that materials containing VOCs have been used to conduct
controlled burns of vegetation, to clean weapons in the field, to conduct
equipment maintenance, and to refuel in training areas.

D.  UX0

1.  Surface UXO: Surface contamination by UXO is the result of training
activities.

2.  Buried UXO:  contamination from buried UXO may be the result of
training activities or disposal activities.

3.  WHAT WE KNOW ABOUT THE IMPACT ON WATER SUPPLY  

1.  The Cape Cod Aquifer is designated a sole-source aquifer:  In response
to a petition by the citizens of Cape Cod, EPA designated the Cape Cod
Aquifer a sole-source aquifer on July 13, 1982.

2.  The Sagamore Aquifer that underlies the Impact Area and Training
Ranges is part of the Cape Cod Sole-Source Aquifer and a vital part of the
Cape's future water supply:  The Sagamore Aquifer (or Sagamore Lens) can
yield millions of gallons of ground water for public and private water
supply in the towns of Bourne, Falmouth, Mashpee and Sandwich. However,
the amount of water available from this aquifer is finite. Continued use
of this aquifer for drinking water supply depends on prudent management of
water withdrawal and maintenance of water quality that meets drinking
water standards.

3.  Upper Cape Cod communities expect to increase their water supply
production from the Sagamore Aquifer:  Significant growth on Cape Cod has
increased demand for water. Water Supply Studies in 1998 and 1999
evaluated water use and projected water supply demand in Bourne, Falmouth,
Mashpee, Sandwich, the South Sagamore Water District and for the Otis Air
National Guard.  Recent studies indicate that by 2020 the public water
supply maximum day deficit is projected to be 9.8 to 11.8 million gallons
per day (MGD).  This assumes that all existing and potential public water
supplies (excluding those threatened or impacted by environmental
contamination) are in production.

4.  The Sagamore Aquifer and many public water supplies have been
adversely impacted by activities at MMR:  MMR overlies the top of the
mound of the Sagamore Aquifer .  Groundwater flows out radially from the
mound.  The quantity and quality of the Sagamore Aquifer, which was once
available for drinking water without treatment, is diminished because
waste disposal, fuel and chemical leaks, training and military research
activities at MMR have contaminated underlying ground water.

Recent water supply studies evaluated use of 27 existing public water
supply sources and 33 potential new water supply sources managed by and/or
located in Bourne, Falmouth, Mashpee, Sandwich, the South Sagamore Water
District and the Otis Air National Guard that may be able to produce
enough water to help meet the projected year 2020 water supply demand.
Seven existing public water supply sources areas are characterized as
impacted or threatened by MMR activities. Sixteen potential water supply
sources areas are characterized as impacted or threatened by MMR
activities due to their proximity to potential unexploded ordnance,
proximity to known or newly identified sources of groundwater
contamination (including contamination from the use, detonation, and
disposal of explosive compounds) and potential for impacts on ongoing MMR
remediation efforts.  Many of the potential supplies draw water from under
the Training Ranges and Impact Area.

The long history of MMR military use, research and training and the
associated contaminant releases at MMR has resulted in loss of private and
public drinking water supplies; has made development of future water
supplies more complex; and has made the drinking water quality of future
supplies less certain. 5.  The Sagamore lens remains the critical key to
satisfying the future demand for drinking water on upper Cape Cod:  Even
though the long history of disposal, research and training activities at
MMR has resulted in the loss of public water supplies and made the
development of future supplies more complex, the Sagamore Lens of Cape
Cod's sole source aquifer is still a valuable and essential resource that
will help meet the demand for future drinking water. Given increasing
demand and past damage to the aquifer, protection of the Sagamore lens
from activities that cause pollution of it is more important than ever.

4. Next Steps

1.  The Phase 11(a) investigation has been in progress since December 1998
and will extend through 1999. Phase 11(a) activities are primarily
designed to further describe the nature and extent of soil and groundwater
contamination within the Impact Area, as well as at certain ranges and
training areas. The investigation includes the installation of monitoring
wells upgrading of the potential long range water supply well sites and a
survey for unexploded ordnance at specific areas within the Training Range
and Impact Area.

2.  The workplan for the Phase 11(b) investigation is currently being
prepared by the NGB and will focus on the nature and extent of
contamination at all other training areas, ranges, water bodies, and other
significant features not previously examined.

3.  The Impact Area Groundwater Study will continue to monitor and expand
upon the existing network of monitoring wells to determine whether
previous detections have created plumes of contamination.

4.  Of significant concern to EPA has been the presentation by NGB of an
incomplete record of the history of the Training Range and Impact Area and
the shortage of NGB funds to complete EPA's requirements for the study.
EPA is continuing to press the NGB to complete this important aspect of
the study.

5.  The Impact Area Review Team, comprised of Upper Cape citizens and
representatives from EPA, Massachusetts Department of Environmental
Protection, Massachusetts Army National Guard, and the Joint Program
Office continues to meet approximately every 4 to 6 weeks to review recent
data and discuss next steps in the investigation.

6.  As the study progresses and information becomes more complete as to
the extent of contamination at Camp Edwards, EPA will be examining options
for remediation.