Six Areas of Concern
Mr. Jerry Whitaker, the public affairs specialist at the Installation Restoration Program (IRP) at the Massachusetts Military Reservation (MMR), convened the meeting at 7:02 P.M. He thanked everyone for coming and explained that the purpose of the meeting was to discuss the six Areas of Contamination (AOCs). He stated that groundwater plumes would not be discussed, that only the sources of contamination would be discussed. Mr. Whitaker briefly outlined the schedule for the meeting. He said that the introduction would be followed by a brief description of each of the 6 AOCs, with time allotted for questions and answers after each description. He also said that after the public meeting there would be a formal public hearing. Mr. Whitaker then explained that the public meeting would be interactive and the audience was encouraged to ask questions. The formal public hearing however was an opportunity for the public to have their oral comments entered into the public record and into the Record of Decision (ROD). Mr. Whitaker asked that those individuals who wanted their comments to become part of the public record and the ROD use the microphone and state their name, the town in which they lived, and their comment. Mr. Whitaker stated that the technical staff would not be responding to those comments during the public hearing but that responses to comments would be given in the form of a written Responsiveness Summary. He encouraged the audience to ask their questions during the public meeting when answers could be provided, and to then make comments during the public hearing to become part of the ROD. Mr. Whitaker briefly explained the schedule for the 6 AOCs ( see attached). He said that the thirty day public comment period for the 6 AOCs began on November 13, 1997. He also stated that the ROD would be submitted to the Environmental Protection Agency (EPA) for review and would then be issued with the Responsiveness Summary in early January of 1998. Mr. Whitaker encouraged the public to submit comments through one of the various available methods (see attached). He also said that the public hearing would be recorded verbatim via a court reporter. Mr. Whitaker then introduced Mr. Lee Perry, the Air Force Center for Environmental Excellence (AFCEE) project officer for the 6 AOCs. Mr. Perry repeated the fact that during this meeting the discussion would focus on the source areas only and not the plumes. He also said that the six areas were believed to be continuing sources for groundwater contamination. Consequently those six sites had been selected for study and it had since been decided that some of the areas would require remediation. Mr. Perry then introduced Mr. Stan Reed from ABB to present the 6 AOCs. The Six Areas of Contamination Overview: Mr. Reed briefly reviewed information about each of the 6 AOCs. He said that the information was included in the proposed plan which was available for distribution. Mr. Reed said that the proposed plan dealt with the following 6 AOC’s:
Mr. Reed said that the 6 AOCs had been combined due to similar site histories, similar site contaminants and the fact that the sites were at a common stage in the evaluation process. Mr. Reed then explained AFCEE’s proposed plan for the 6 AOCs. He said that the proposed plan summarized the site history and the investigation and also described the candidate remedial alternatives. He also said that the plan outlined the criteria needed to evaluate the alternatives and described the available opportunities for public comment. Mr. Reed then showed a map that depicted the location of the 6 AOCs (see attached). He said that SD-5/FS-5 and FTA-2/LF-2 were located in the town of Sandwich and that the other four sites were located in the town of Mashpee. He added that all of the sites were north of Johns Pond. Mr. Reed said that a field investigation to evaluate the contamination would be done and would be followed by a feasibility study. He explained that the feasibility study would evaluate ways to assess potential risk. Mr. Reed then stated that the preferred alternatives were based on the results of the field investigation and the feasibility study. Evaluated Remedial Alternatives: Mr. Reed listed the five potential approaches that had been developed: 1. No Action: Assumed that nothing would be done, and was used for comparison. 2. Limited Action: Assumed that institutional controls would be enforced i.e. testing, access restrictions, deed restrictions, monitoring, etc. 3. Biosparging: Involved injecting air into the ground, below the water table. The rising air bubbles would provide oxygen with which the bacteria would use during the degradation of site contaminants. 4. excavation and Asphalt Batching: Involved mixing the excavated material with an asphalt emulsion to coat the material and immobilize the contaminants. The material could then be used as a sub-base for paving projects. 5. excavation and Off-site Treatment and Disposal: Involved moving excavated material to an off-site treatment facility. The material would then be treated and disposed of as each facility deemed appropriate. Mr. Reed displayed a slide that summarized the different alternatives ( see attached). A member of the audience said that the diagrams showed plume-like objects and added that Mr. Perry had stated that these were not plumes. Mr. Reed replied that the diagrams were not intended to depict plumes but rather geographic areas. He then referred to SD-2/FS-6/FS-8 and SD-4 and said that the pipes from those drainage ditches extended from the base area down to the pond. Mr. Reed said that those areas were the subject of investigation for soil contamination and were not groundwater plumes. A member of the audience asked whether contaminants on the base had flowed as far as Johns Pond. Mr. Reed replied that, because of the sandy soils at MMR, it would be possible in a very strong storm for contaminants to flow as far as the pond. However in normal situations the contaminants did not flow as far as the pond. Mr. Perry added that the areas were very generalized and were depicted on the map as being much larger than the actual locations. He said that they were intended to show the location of the study areas. Mr. Perry said that in terms of clean-up, the areas were very localized. Mr. Reed said that the sites on the map were study areas and that the actual areas of concern were much smaller. He also said that in 1968 oil/water separators had been installed at SD-4 and SD-2 through which water would run, separating and capturing the oil particles. Mr. Greg Taylor from the Department of Public Works (DPW) in Mashpee asked how often the oil/water separators were cleaned versus how often they were purged with larger flows of water. He then asked whether there were any records regarding the maintenance of the oil-water separators. Mr. Perry replied that he did not have any information at this time regarding the maintenance record for the oil/water separators. He said that if the oil/water separators were in service, they were maintained. Mr. Perry said that he could make that information available. Mr. Taylor stated that this was not a satisfactory answer. He said that it was also unsatisfactory to mislead the public about the fact that the contaminants were going into the groundwater. Mr. Taylor stated that AFCEE should not be giving the public the "warm and fuzzies" with the oil water separators. He went on to say that most of the contaminants enter the groundwater and by talking oil-water separators, the problem was being minimized. Mr. Taylor that he had understood that the discussion was about cleaning up the source areas and that it was misleading to say that since 1968 there have been oil/water separators in place and therefore there was nothing to worry about. A member of the audience asked whether the ditches contributed to contamination in the ponds. Mr. Reed replied that that was not likely. He explained that the sandy soils "drain freely" and only in a very large storm would water flow into the ditch. He added that the oil water separators were in place to prevent spill. Mr. Schyler Wires asked whether the plumes would be discussed at a later date. Mr. Snyder replied that the groundwater plumes were being addressed separately through other programs. He went on to say that the public comment period for SD-5 had ended on November 21, 1997. The remediation alternative for that site was scheduled to be announced on December 15, 1997. Mr. Snyder said that this project focused on the surface sites. Mr. Wires asked whether it was correct to say that at a later date the other plumes would be discussed in this type of forum. Mr. Snyder replied that that was correct. The 6 AOCs: FTA-2/LF-2: Mr. Reed gave a brief description and history of the FTA-2/LF-2 site ( see attached). He pointed to LF-2 on the map and said that it occupied approximately eleven acres. He said that the land fill had received domestic refuse from MMR during the 1940’s and had since been covered with soil and cover material. He also said that contamination at this site included fuel and non-fuel related contaminants in deep soil and that the land fill had been covered a few times in the past and therefore the surface soil was not contaminated. Mr. Reed said that the risk assessment had not identified any human health risks in exceedence of the state and federal evaluation criteria. He went on to say however, that the area downgradient of the FTA had deep contaminations which posed a threat of leeching into the groundwater. He said that as a result of the potential risk that site had been carried forward for remedial action. AFCEE’s preferred alternative for that site was biosparging with ambient air monitoring. Mr. Phil Elia asked whether biosparging had been done before. Mr. Reed replied that biosparging had not been done at that site. He said that it had been done at the FS-12 site. Mr. Elia asked whether it had worked. Mr. Reed replied that yes it had worked, and that it was ongoing. PFSA/FS-10/FS-11: Mr. Reed gave a brief description and history of the PFSA/FS-10/FS-11 site (see attached). He said that the soil at the PFSA had been treated in three above ground tanks and that since the 1950’s had been the primary fuel distribution area at the MMR. Mr. Reed said that FS-10 and FS-11 were major components of the site. He explained that FS-10 had been a 2,000 gallon jet-fuel spill in one of the pumphouses and that FS-11 had been a 2,000 gallon fuel spill from tank overflow. Mr. Reed said that fuel related contaminants had been found in the surface soil and subsurface soil. He said that a risk evaluation had determined that there was no human health risk above the evaluation criteria. There was, however, the potential of contamination in the subsurface soils contributing to groundwater contamination. Mr. Reed said that consequently alternatives had been evaluated for site remediation. He then said that the preferred alternative for this site was biosparging. He added that ambient air monitoring and off-gas collection and treatment would be needed at this site because of the large volume of material in the soil. SD-2/FS-6/FS-8: Mr. Reed gave a brief history and description of SD-2/FS-6/FS-8 (see attached). He said that SD-2 had received stormwater runoff from the PFSA, the aircraft maintenance ramp, and the hangars. He added that there was an oil/water separator at the head of the ditch. Mr. Reed said that samples had been taken along the entire length of the drainage ditch. He went on to say that investigations at this site had detected fuel related compounds, pesticides, polychlorinated biphenyls (PCBs), and inorganic contaminants in the surface soil and sediment. He said that maximum site concentrations were found primarily at sample identifier location #6 and #1. Due to those findings it was determined that this site posed a potential risk and alternatives for remediation had been evaluated. Mr. Reed said that the preferred alternative for this site was excavation and asphalt-batching of the soil and sediment to remove the potential sources of contamination to Ashumet Pond. A member of the audience asked what the source of the PCBs was. Mr. Reed replied that he did not know. The audience member then asked how much had been found. Mr. Reed said that that information was available in the report. The audience member then asked why it was thought that asphalt-batching would work for PCBs. Mr. Reed replied that the concentration found was low enough to be within the criteria to be used in asphalt-batching. The audience member then said that according to what he had heard about PCBs, they had to be removed. Mr. Reed said that this alternative would remove the PCBs from the ditch. The audience member commented that the PCBs would be removed and then put into another ditch on the MMR with the possibility of "leaking out". Mr. Reed said that the soil with PCBs would be removed and treated. The audience member asked where this had been done successfully. Mr. Reed said that references could be found. The audience member then questioned the reliability and success of this remedial alternative. Mr. Rossoll of ABB said that asphalt-batching had been used at MMR for the Drainage Structure Removal Program. He said that the excavated material had been treated with the asphalt-batching process and then used as subgrade asphalt throughout the base. The audience member then said that he thought that PCBs needed to be removed. Mr. Rossoll said that the concentrations on the base were very small. He said that the PCBs found in the storm drain had been left over from base run-off and had been found at very low levels. Ms. Kiley from the Massachusetts Department of Environmental Protection (MA DEP) said that the levels of PCBs found had met the requirements for any asphalt-batching facility and that the MMR was also required to meet those standards. She said that if PCBs were below those concentrations, they could be used for asphalt-batching. Ms. Kiley went on to say that during the asphalt-batching procedure, testing would be required to ensure that the levels were being met. She said that if the levels of PCBs were too high, a contingency would have to be put in place to remove the material to an off-site location. A member of the audience said that the source of the PCBs was known, but wanted to know the amount. Mr. Reed said that the amount at SD-2/FS-6/FS-8 was approximately fourteen yards. He said that there were two isolated sample areas. The audience member then asked why the material wasn’t just removed. Mr. Reed replied that asphalt-batching was more cost effective. Mr. Perry said that when a site was investigated and a remedial action was proposed, all the contaminants would be identified as would the concentrations and risk factors. He said that if the soil with PCBs were mixed into the asphalt mixture and used as a subgrade paving material, the PCBs could not be leeched. A member of the audience said that the PCBs would just last longer in the asphalt and would still be there when the asphalt decayed. He then asked why not deal with the PCBs now. Mr. Perry replied that the asphalt would last long enough to maintain safety. The audience member disagreed. Mr. Rossoll encouraged individuals to express their concerns during the public hearing. SD-3/FTA-3/CY-4: Mr. Reed said that SD-3 had been constructed in the 1950’s to receive discharge from storm drains which served the aircraft hangars as well as from several streets west of Grainville Avenue. Mr. Rossoll continued with the presentation and said that approximately 42,000 cubic yards of material, representing the majority of coal and ash at CY-4, had been excavated and used as fill below the LF-1 cover system. He went on to say that FTA-3 had been used for fire-training exercises at this site, and subsequently had been back-filled with construction debris, fill, and coal ash. Mr. Rossoll went on to say that the investigations at this site had detected fuel and coal related contamination in sediment and surface and subsurface soil samples. He said that in 1994, approximately 40,000 yards of material had been removed from the site. Mr. Rossoll said that the remaining soil samples had indicated that there was no human health or ecological risk. He said that the proposed action at this site was confirmation samplings to ensure that all contaminated soil had been removed with the contingency of excavation and asphalt-batching. Mr. Reed displayed a site map for orientation purposes (see attached). He explained that samples would continue to be taken in the affected area. Mr. Taylor asked why the Department of Defense (DoD) did not know whether the removal of the 42,000 cubic yards of ash had been completed. He then asked whether there was a post excavation report. Mr. Rossoll replied that the samples taken after the excavation had included the bottom and the side walls of the excavation site, and had been clean. He said that during the removal, samples had not been taken from outside the excavation. He went on to say that the proposal was to take samples from outside of the excavation to assure that all the contaminants had been removed. Mr. Taylor said that there was written information indicating that there was no risk, while at the same time it had been said that there was a potential for risk that would be dealt with if necessary. He went on to say that if there was a determined risk, the answer would be do "next to nothing" because it was "not that bad". Mr. Taylor said that the process was very confusing and he questioned whether enough work had been done. He then asked whether or not there was a risk. Mr. Rossoll said that of all the samples that had originally been taken during the investigation, several were contaminated and had shown potential risk to human health. He went on to say that before the process of risk evaluation the site had been excavated and all of the areas from which contaminated samples had been taken, had been removed. Mr. Rossoll said that the sample areas around the edge of the site, the clean samples beyond the area of the excavation, had not shown risk. When the revised plan was proposed to the regulators, EPA and MassDEP had requested that confirmitory samples be taken to assure that there was no risk. He said that there was no indication of any remaining risk at this site. SD-4: Mr. Rossoll gave a brief description and history of SD-4 (see attached). He explained that SD-4 was located to the far east side of the installation and that the drainage way extended from Riley Road to Johns Pond. He said that this was a good example of the earlier statement that the source areas looked like plumes. He went on to say that the drainage ditch portrayed on the map looked similar to a plume (see attached) and that only the shaded area in the middle was actually contaminated and required remediation. Mr. Rossoll said that SD-4 had received runoff from aircraft hangars, runways, and ramps. He said that investigations at this site had detected fuel related compounds, pesticides, PCBs, and inorganic compounds in surface soil, sediment, surface water, and groundwater. Based on the risk assessment, the proposed remedial action for SD-4 was excavation and asphalt-batching of sediments. SD-5/FS-5: Mr. Reed gave a brief description and history of SD-5/FS-5 (see attached). He said that this site was located on the western side of Runway No. 5, and extended from North Inner Road to Lingley Avenue. He said that possible contamination sources near SD-5 included two underground fuel storage/transfer systems, the Western Aquafarm and the Eastern Aquafarm. He said after extensive investigation, several areas of contamination which exceeded the evaluation criteria had been identified. Mr. Reed said that this site contained organic and inorganic contaminants and that most of the contamination was shallow. Mr. Reed also stated that the risk assessment identified the potential for risks from exposure to soil for both current and future exposure scenarios. The preferred alternative for this site was excavation and asphalt-batching. Mr. Reed stated that there were approximately 9000 yards of material to be removed from this site. Mr. Taylor asked where the 9000 yards came from. Mr. Reed replied that it was still there. Mr. Taylor said that he could not identify on the map where the 9000 yards of material were located. Mr. Reed replied that the location was indicated by the shaded area on the map. He went on to say that sampling would be conducted during the process to confirm the extent of each of those areas. Mr. Reed said that the diagram was based on the available sample data and that additional samples would be collected as excavation was done. A member of the audience asked whether the excavated "material" was being put back in any particular area. Mr. Reed said that the excavations would be back-filled with clean material. The audience member asked whether the asphalt-batching would occur on the base. Mr. Reed replied that that was the case. The audience member then asked whether there were any sampling techniques being installed beneath the asphalt-batching in order to monitor whether there was any seepage of contaminants. Mr. Reed replied that none had been proposed. The audience member then asked whether that subject had been discussed. Mr. Reed replied that it had not been discussed. Mr. Perry said that when asphalt-batching had been studied as an alternative, it had been proposed to pave the roads with the resulting material. He said that before the decision would be made, the soil would have to be determined suitable for asphalt-batching. It could then be said that the asphalt would retain anything residing in the soil. A member of the audience said that he thought it would be more prudent to localize this material, rather than "spread it over the entire base". He explained that if something were to go wrong, it would be easier to remove a localized area than clean up the entire base. Mr. Taylor asked whether the quality of the asphalt would be suitable for runways that were upgradient of all the source areas. Mr. Perry replied that that would be more of a Civil Engineering Question. Mr. Taylor then asked whether there were any Civil Engineers present. Mr. Perry replied that there were not. Ms. Kiley added that this asphalt would only be used for sub-grade material and not for the final asphalt layer. She went on to say that the idea was to prevent any leeching. Mr. Mike Molard asked whether the asphalt would be used entirely on the base or whether it would be used elsewhere. Mr. Perry replied that it had previously all been used on the base. Mr. Peter Dinizio asked whether the PCBs would be removed during the asphalt-batching process. Mr. Perry replied that asphalt-batching did not destroy the contaminants, but rather it immobilized them. Mr. Dinizio asked whether the incineration method had been considered. Mr. Perry replied that there were environmental impacts associated with the incineration method. He went on to say that because of the low levels, the PCBs were not actually "driving" the cleanup. He said that many of the other contaminants that would be part of the asphalt "mixture" were already in asphalt. Mr. Perry said that the character of the asphalt would not be changed. He added that the PCBs had been found at trace levels. Mr. Snyder asked whether Mr. Dinizio had been referring to the treatment process for treating soil from the fire training areas that had been on the base. Mr. Dinizio replied that a few years ago, the incineration method had been considered as a way to "burn out" the contaminants from the soil. Mr. Snyder said that there had been a unit on the base for the last year that had treated approximately 40,000 tons of soil. He said that that had been strictly related to fuel related compounds. Mr. Snyder added that it was actually a low temperature heating process in which temperature would be just hot enough for the fuel compounds to vaporize and be removed with an air stream treatment process. Mr. Snyder stated that destroying PCBs would require incineration at very high temperatures and therefore the low temperature thermal desorption unit at FTA-1 would not work for PCBs. Mr. Rossoll encouraged the audience to repeat their comments during the formal public hearing. He went on to say that the presumptive remedies were specific remedial actions for sites that were assured to be effective. He said that a smaller list of remedies had been chosen based on US EPA recommendations. Ms. Keating, the project manager with US EPA. said that she would provide material about the asphalt-batching technology to those who requested more information. She said that asphalt-batching had undergone many years of testing, and would otherwise not be an option as a potential remediation strategy by US EPA. A member of the audience asked what was being done about the contaminated groundwater that had been mentioned earlier. Mr. Reed replied that contaminated groundwater was being investigated and action was being taken as part of the Southeast Regional Groundwater Operable Unit (SERGOU) and other groundwater actions being taken at MMR. He went on to say that the groundwater had been "broken away" from the source areas in order to facilitate the clean up. Mr. Reed said that it was easier to deal with the actions separately. The audience member then said that he found this answer to be very vague. Mr. Reed said that the groundwater contamination, where it existed, was being addressed under the SERGOU. Mr. Perry added that all of the groundwater on the base was being addressed under a separate "program". He said that all of the identified plumes were being treated individually and were being addressed one at a time. Mr. Perry added that a decision would be announced for SD-5 on December 15, 1997, and that a solution was being reached in regard to the LF-1 plume. He concluded that all of the plumes were ongoing. The audience member asked whether the LF-1 plume was contaminating Red Brook Harbor. Mr. Perry replied that that was correct. The audience member then asked whether there was any information regarding that plume. Mr. Perry replied that their was plenty of information available. Mr. Whitaker said that the Remedial Program Managers (RPMs) were continuing to meet and that the decision regarding LF-1 was being discussed at higher levels. He said that it was hoped that the decision would be announced soon. Ms. Elia asked whether there had been a consensus as to the number of years required to clean up the groundwater problem. Mr. Snyder replied that the clean up process for the plumes was similar to that of the source areas. He said that the risk would be assessed, and then the most appropriate remedial action would be assessed. He said that the actual clean up of the groundwater plumes would take approximately ten to twenty years once the system was in place. Mr. Whitaker said that the technical staff from AFCEE would be available to answer questions after the formal public comment period. The public meeting ended at 8:10 P.M.
|
