MMR Impact Area Fact Sheet (Final)

[Lenny Siegel <lsiegel@cpeo.org>]

[This is the final Impact Area fact sheet from MMR. It supersedes the
draft we circulated earlier this week.]



Facts on The Impact Area Groundwater Study 
At Massachusetts Military Reservation (MMR)
June 16, 1999

Introduction

In February 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 activities at MMR on the
underlying sole source aquifer, a water supply of vital importance to
Cape Cod. The Order also created a citizens advisory committee to advise
EPA on the study.  The Impact Area Review Team, including the citizens
advisory committee, EPA, the Massachusetts Department of Environmental
Protection, the National Guard Bureau and the Massachusetts Army
National Guard,  has 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 certain 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

To date, 150 monitoring wells have been sampled over the 14,000 acre
Impact Area and Training Range, with validated results available. 
Results from an additional 100 monitoring wells are pending, and more
data will be available in the future.

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 explosive compounds 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
seventeen monitoring wells; fourteen of the wells had RDX above the
Health Advisory. Of the fourteen wells, four are in CS-19, four 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 training area used
primarily 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 600 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 one half mile to the west.

2.  IRP 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 in the central area of CS-19. 
Groundwater contamination in this area is currently being addressed by
the Air Force under the Installation Restoration Program (IRP).  

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.  A buried cache
of approximately 1,100 primarily inert artillery and mortar rounds was
exhumed  from the J-1 range in 1998.  HMX has also been detected in a
well installed near the melt-pour facility on the J-3 range at 12 ppb. 
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 Impact Area contains numerous target areas where mortar and
artillery, including high explosive and white phosphorous warheads, were
fired for many years.  To date there have been four validated detections
of explosives in groundwater above Health Advisories associated with the
central portion of the Impact Area at MW-23, MW-1, MW-2 and MW-38.  
Explosives were not detected in soils around these wells.  EPA believes
explosive are not being detected because they have already migrated
through the soil into the groundwater.  Mortar and artillery use are a
likely source of the contamination; however, NGB believes that other
activities such as munitions disposal may be contributing to the
contamination.  Studies are ongoing to establish the nature and 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 in preliminary,
unvalidated results up to 371 ppb and HMX was detected up to 2,013 ppb
in soil samples collected near targets.  The study has not yet assessed
the health effects of exposure to explosives in soils.  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 from the firing of weapons and/or from the burning of
propellants, a practice that was discontinued in 1992.

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.   EPA classifies 2,4- DNT as a Class
B2 carcinogen (a probable human carcinogen).  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 ppb.   The
study has not yet assessed the health effects of exposure to propellants
in soil.

3.  J-3 Wetlands:  The J-3 wetlands is presently located off-base and
south of the J-3 range and north of Snake Pond.  (This land was formerly
part of the base.)   Propellant compounds and their combustion
byproducts have been detected in sediment samples collected from this
area.  Nitroglycerine has been detected at concentrations up to 5,200
ppb. 

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 or Health Advisories include sodium, zinc,
lead, molybdenum, antimony and thallium.  The study will compare these
levels of metals to background levels which are naturally occurring.

2.  Herbicides and Pesticides:  Herbicides and pesticides have been
detected in soils and in groundwater 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) and Munitions

Unexploded Ordnance (or UXO) are munitions that do not function as
intended.  UXO still contain explosives compounds, which if released
present a threat to groundwater. In addition, UXO present a safety
threat to persons within the blast range. 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 prepared by the Army Corps of
Engineers for the National Guard Bureau concluded that the safety risk
posed by UXO at MMR ranked as Category I or "catastrophic" on the Corps'
safety risk assessment scale of one to four.  (The Army Corps ranking
does not assess the risk to groundwater resources.)  The Corps report
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.   The Corps recommends an engineering evaluation and cost
analysis for further response for the UXO at 15 of the 19 areas examined
at MMR.   It is worth noting that the Corps concluded that UXO risks
deserved a "catastrophic" safety 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.  Notwithstanding the
"catastrophic" safety rating, the Corps report found no evidence of an
imminent safety hazard that warrants immediate action.
  
2.  Buried Munitions and Subsurface UXO:  Prior to the 1970s, it was
common practice for the military to dispose of munitions by burial.  EPA
has required the National Guard to conduct a survey for buried munitions
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 Area 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 this survey is to locate munitions
burial pits and disposal sites that may present a continuing source of
contaminants to the underlying aquifer.  UXO discovered during this
process will be disposed of, where feasible, 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 Area 1:  The explosives in groundwater at and
downgradient of Demolition Area 1 are the result of demolition training
and/or the disposal of explosives by open burning/open detonation.

2.   IRP Chemical Spill (CS)-19:  The explosives in groundwater at and
downgradient of CS-19 are primarily the result of munitions disposal,
with some contribution from artillery and mortar training. Note that NGB
believes that the explosives in groundwater at and downgradient of CS-19
are caused by munitions disposal only.

3.  J Ranges:  The explosives in groundwater at and downgradient from
the J Ranges are 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 are the result of artillery and
mortar training.  However, the NGB does not agree with this finding and
believes artillery and mortar training is a possible, though not
necessarily probable, cause of contamination.  Munitions disposal may be
a contributing source of contamination here. 

5.  KD Range: Recently received data (as yet not validated) indicate
that explosives in soil at the KD range are the result of training
activity.

B.  Propellants

Soil contamination by propellants at the high use gun positions, the KD
Range and the J-3 wetland
is the result of firing of weapons and/or burning of propellants. 
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 certain training
activities.  Further investigation into the source, nature and extent of
metals detections above MCLs will occur, where these detections are
above background concentrations. 

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

2.  Buried UXO:  Buried munitions/UXO are 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.   It is the
sole source of drinking water for the Cape's 200,000 year round and
500,000 seasonal residents.  It is of excellent quality, and in its
natural state as drawn from the aquifer, the groundwater requires no
treatment for drinking other than pH adjustment. 

2.  The Sagamore Lens that directly underlies the Impact Area and
Training Ranges is part of the Cape Cod Sole-Source Aquifer and a vital
part of the Upper 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 Upper Cape 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 protection to maintain drinking water quality and
prudent management of water withdrawal.

3.  Upper Cape Cod communities expect to increase their water supply
production from the Sagamore Lens:   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 Lens and many public water supplies have been adversely
impacted by activities at MMR:   MMR overlies the top of the mound of
the Sagamore Lens.  Groundwater flows out radially from the mound.  The
quantity and quality of the Sagamore Lens, 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.   In 1993, it was
estimated that chemicals from areas other than the Impact Area and
Training Ranges had contaminated 66 billion gallons of water.  Thus far,
the IRP has spent over $350 million to investigate and remediate soil
and groundwater contamination.  

Recent water supply studies evaluated the use of 27 existing public
water supply sources and 38 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 might 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 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 would draw water from under the Training Ranges and
Impact Area.

The long history of MMR military use and the associated contaminant
releases at MMR has resulted in loss of private and public drinking
water supplies; has limited options for the development of future water
supplies; 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:   Given increasing demand
and past damage to the aquifer, protection of the Sagamore Lens from
activities that cause its pollution is more important than ever.

4.  Next Steps

1.  The Phase II(a) investigation has been in progress since December
1998 and will extend through 1999. Phase II(a) activities are primarily
designed to further determine 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 upgradient of the potential long range water supply
well sites and a survey for UXO and buried munitions at specific areas
within the Training Range and Impact Area.

2.  The workplan for the Phase II(b) investigation is currently being
prepared by the NGB and will focus on the nature and extent of
contamination at 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 the
nature and extent of contamination, including the delineation of any
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.   However, NGB and MAANG believe a complete history
of the Impact Area and training ranges may not exist.  NGB is working
closely with the Army Corps of Engineers to assemble a record of over 85
years of military use. 

5.  Also of significant concern to EPA is the shortage of NGB funds to
complete EPA's requirements for the study.  To date, approximately $20
million has been spent to investigate soil and groundwater contamination
at the Impact Area and Training Ranges.

6.  The Impact Area Review Team, comprised of Upper Cape citizens and
representatives from EPA, Massachusetts Department of Environmental
Protection, Massachusetts Army National Guard, the National Guard Bureau
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.

7.  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. 
 

Appendix 1

Glossary of Terms Used in the Fact Sheet

1.  Impact Area Review Team Citizen Members:

     Tom Cambareri, Cape Cod Commission, Barnstable, MA
     Joel Feigenbaum, Sandwich, MA
     Richard Hugus, Falmouth, MA
     Peter Schlesinger, Sandwich, MA
     Paul Zanis, Sandwich, MA

2.  Installation Restoration Program (IRP): The US Air Force's cleanup
at MMR under EPA's CERCLA (Superfund) program.
   
3.  Explosives:

AmDNT:  2-Amino-4,6-Dinitrotoluene or 4-Amino-2,6-Dinitrotoluene
BTEX:      Benzene, Toluene, Ethylene, Xylene
C-4:          RDX/TNT
DNT:       Dinitrotoluene
HMX:      Her Majesty's Explosive
(octahydro-1,3,5,7-tetranitro-1,3,5,7-tetrazocine) 
MCPP:     2-(2-Methyl-4-chlorophenoxy) propionic acid and its salts and
esters
PETN:      Pentaerythritol Tetranitrate
RDX:       Royal Demolition Explosive
hexahydro-1,3,5-trinitro-1,3,5-triazine)   
TNT:       Trinitrotoluene

4.  Validated Data:   Soil and groundwater sample results that have
undergone a thorough review process to assure the accuracy of the data.



-- 


Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 222B View St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/968-1126
lsiegel@cpeo.org
http://www.cpeo.org