FS-28 Coonamessett River Stakeholder
Summit
Agenda Item #1. Introductions, Goals of Meeting, Groundrules, Agenda Review Mr. Field convened the meeting at 1:30 PM and asked the attendees to introduce themselves. He thanked everyone for coming and reviewed the agenda and the groundrules. He noted that the goal of the meeting was to achieve, if possible, a consensus or focus on a preferred alternative or alternatives for moving forward with plans for the Coonamessett River. Mr. Field then introduced Ms. Balkus of the Air Force Center for Environmental Excellence (AFCEE). Ms. Balkus noted that there would be some real opportunities to excel during the week. On Friday, AFCEE would have an opportunity to update the Massachusetts congressional delegation on the status of the whole Massachusetts Military Reservation (MMR) program, including the cranberry projects. She asked for the cooperation of the attendees and noted that whatever consensus they were able to come to would be passed on to the delegation. Agenda Item #2. Outcome of Falmouth-Sponsored Meeting Mr. Field introduced Mr. Gordon of the Falmouth Conservation Commission. Mr. Gordon read a letter that the Commission had sent to AFCEE. The letter stated that the Commission had held a public meeting on September 16, 1998 to discuss AFCEEs proposed options for remediation of ethylene dibromide (EDB) contamination in the Coonamessett River. The Commission commended AFCEE and Jacobs Engineering for the thorough investigation that had been conducted to date and their efforts to convey complex information in a comprehensible manner. The letter also indicated that the Commission had voted to recommend the process that resulted in Alternative E. This recommendation evolved from continuing discussions and new information as it had become available. The letter outlined additional elements, which the Commission wished to add to Alternative E. Mr. Gordon stated that the Commission endorsed the continuation of the process and expected to actively participate in future discussions with officials. Mr. Field asked if there were any questions about the Commissions recommendations. Ms. Muramoto reiterated that the Commission voted in favor of Alternative E plus both compensation and complete separation of the river from the bog system. She clarified that Alternative E alone does not have those two extra elements. She stated that the Commission voted to strongly support the processes that lead to these two elements and noted that public involvement in the process was an important part of the entire matter. Agenda Item #3. Discussion Mr. Field asked Mr. Szymoniak to summarize the alternatives, focus in on Alternative E, delineate any questions or concerns, and provide more details. Mr. Szymoniak summarized the alternatives as follows: Alternative A: Mr. Szymoniak described this as the "no action" alternative. He also mentioned that all of the options included Extraction Well 1 (EW-1), an operation at Hatchville Road running at the current rate of 600 gallons per minute (gpm). Alternative B: Mr. Szymoniak stated that this plan involved channel realignment in the Lower Baptiste Bog from the beginning of the bog all the way through the entire Baptiste bog. Portions of that were aligned in order to create two different berms on either side of the bog, which would become holding basins for necessary passive or active treatment of the bogs themselves. Alternative C: Mr. Szymoniak noted that this alternative included the same channel realignment as Alternative B, but added active treatment using shallow well points to extract EDB where it is upwelling into the bogs and the basins. The water would be taken back for treatment at the EW-1 plant and discharged at four locations down through the river system. Alternative D: Mr. Szymoniak said that this option would entail separation of all the bogs in the river system, although treatment would not be required since EDB would still be present in the river. One of the goals with this option would be to get water flowing into Pond 14 to be non-detect. Based on word from Ocean Spray that this may or may not be acceptable, AFCEE reasoned that if the bogs can be separated from the river, some EDB in the river may be acceptable from a long-term marketability standpoint. Mr. Szymoniak noted that this could be discussed further. Alternative E: Mr. Szymoniak noted that the upwelling of EDB occurs at the confluence of Broad River and the Coonamessett River. There are some bogs that were already separated from the river channel, including the Augusta Bog and the West Thompson Bog. An alternative water source would be necessary so the bogs would have clean water for fall harvesting and winter protection. In order to keep improving on that, E-3 could be non-detect if it could be disconnected from the Broad River by berming the channel. The Adams and Lasalle Bogs would be separated from the river as well with short or shallow berms. As an alternative water source in the upper river system, Mr. Szymoniak proposed using Round Pond. The alternate water source would come from treated water at the EW-1 treatment plant. He clarified that there would be no use of Round Pond in the current alternative. On the East Thompson Bog, either the channel would need to be realigned or a berm installed on the eastern side in order to separate the river from the berm or wetland. He noted that the Chaston Bog was already separated and would only require an alternate water source. In this particular option, all of the bogs would go back into production with the exception of the Baptiste Bog. This would become one of the areas that would be used for the treatment system. The treatment would be shallow well points to lower the concentrations. The end result would not be non-detect, but it would lower the concentration ten-fold to about .01 leaving this particular bog. The goal would be to get the water that flows into Pond 14 to be non-detect. Although Alternative E would allow for some EDB in the river, the concentration would be lowered by adding clean water or maximizing the treatment from the shallow well points. Mr. Szymoniak noted that one other possibility was to use a combination of separation and providing alternate water in the upper bogs, trying to reduce the concentrations of EDB so clean water would enter Pond 14. All of the lower bogs come back into production because the water that would be used for these bogs and the river itself would be non-detect. It would be necessary to do a tracer test to determine how water flowed through Pond 14. The goal would be to get the water entering and leaving Pond 14 to be non-detect. This would make Flax Pond non-detect. With the alternatives briefly summarized, Mr. Szymoniak noted that the upper bogs represented some 86 acres with the different options being the buyout; the separation of the bogs, included in alternatives B, D, and E; and the addition of treatment included in alternatives C and E. With his understanding of the plumes migration, Mr. Szymoniak did not believe that the lower portion of the contamination would upwell and be detectable in the surface water. As a result, he did not propose at this point to deal with a portion of the Augusta Bog. He explained that the water in the upper bogs flowed into the lower bogs, so any action taken in the upper bogs should improve the lower bogs and bring them back into production. Mr. Szymoniak explained that some of the alternatives were easier to implement than others. He noted that clean water flowed through the upper Baptiste Bog, E1 and E2 on the attached map; there was no EDB upwelling in those and they should be able to go back into production immediately. He stated that the Augusta Bog, the Chaston Bog and the West Thompson Bog were already separated from the river, but needed an alternate water source. The Upper Baptiste Bog, along with the Adams and Lasalle Bogs, still needed to be separated and would also require an alternate water source. Mr. Szymoniak then went on to address the more complex alternatives that would be more difficult to implement. He explained that there were two possibilities with the East Thompson Bog that had not been discussed. One included moving the river channel over and berming on one side to keep the EDB, which may exist in low concentrations in the river, isolated from the cranberry bog. Another alternative was to berm on the other side so that the river was disconnected from the active bog or wetland. The other option involved the lower Baptiste, which represented 6.6 acres. He suggested that this could be used as a treatment cell, either actively or passively. Well points would be used for active treatment, however the possibility of expanding the EW-1 treatment plant would be examined. Mr. Szymoniak stated that AFCEEs preferred alternative was to berm the Upper Baptiste, Adams and Lasalle Bogs. Shallow well points would be used in the Lower Baptiste Bog in an effort to utilize the EW-1 treatment plant. EW-1 would drop its pumping rate to 400 gpm. The excess 400 gpm would be used to install shallow well points. He noted that the channel in the East Thompson Bog would be realigned and put on the west side. Alternate water sources would be provided using EW-1 water with the bog that had been discussed. He added that the weir at Pond 14 would be evaluated and improved if necessary. Mr. Field summarized the alternatives that Mr. Szymoniak had discussed. He noted that the goal was to get Pond 14 to non-detect. He identified the question of alternate water sources and asked whether there was any kind of storage that was required in order to provide the necessary amount of water. Mr. Szymoniak replied that the amount of alternate water was a function of time that was needed to fill the particular bog. He stated it had never been resolved how much time was needed. At 600 gpm, it would take several days and all of the bogs could not be filled at once. The purpose of the alternate pond would be to provide additional capacity to fill one or two bogs. He added that the bogs totaled some 12 acres and a considerable volume would be necessary to fill them all at once. Mr. Field clarified that one of the options for an alternate water source was a pond to provide more water at any one time. Mr. Szymoniak responded that the pond would be about 1.5 acres. He explained that it would store about eight acre feet, however to fill all of the bogs, it would require twelve to fourteen acre feet. He concluded that the pond would have enough capacity to fill the larger bogs. Mr. Field asked Mr. Szymoniak to explain the treatment that would occur at the Lower Baptiste Bog. Mr. Szymoniak responded that the pond could act as either passive or active treatment. He noted that the active treatment would be the same granular activated carbon (GAC) treatment at EW-1. The passive treatment would include ponding and dilution of the water itself. He noted that not all of the water that had upwelled into the bog area was contaminated. Mr. Field noted the question of whether to berm the river or relocate it further down the East Thompson Bog. Mr. Szymoniak said those were both options. Mr. Field remarked that the town had proposed additional berming further down the channel. He explained that AFCEE felt this might be unnecessary since the water would be non-detect. He said that the town favored additional berming for fishery protection and pathway separation of the bog. Mr. Field also mentioned the towns preference, in the short or long-term, that pieces of the bog be removed from production and compensation received. He opened the meeting to comments and questions from the attendees. Mr. Taylor asked how the holding ponds decreased the EDB concentration. Mr. Szymoniak replied that not all of the water was contaminated, but more water was mixed into the bog. Mr. Taylor asked how that would decrease the concentration that was currently in the river. Mr. Szymoniak replied that the water was diluted and if it could be controlled hydraulically, the concentration could be changed. He said this was a passive treatment that would take longer. Ms. Mack identified herself and her husband as Falmouth residents. She noted that their property overlooked the Lower Baptiste Bog and expressed her concern over flooding the bogs. In the past, there were a couple of occasions when the bogs were over-flooded and the water went onto her property. She stated that Mr. Handy had been very responsive in draining it and there was never a serious problem. She noted that she had heard nothing in the days discussions about the residents and taxpayers in the area. She asked if this would affect their septic systems. She also asked what the treatment of the lower bogs would entail. Ms. Mack stated that residents who were overlooking the bogs were concerned about "big, ugly piping systems." Mr. Mack added that he was concerned about the possibility of EDB in the water and noted that two dogs in his neighborhood had died of cancer. His own dog recently had a cancerous tumor removed as well. He asked if, when the bogs were flooded, the water would be stagnant or allowed to overflow. Mr. Szymoniak clarified that the Macks were worried about stagnation of the water, the effects of ponding on the septic systems and that there may be flooding that would affect their property. The Macks said this was correct. Mr. Szymoniak stated that the river would still flow through this particular pond. He noted that it was actually preferable for the EDB to keep coming up. Ideally, low levels of water ponding would quicken the flushing out of the EDB. He noted that lower levels of water would also lessen the likelihood that the Macks property would be affected. He explained that the treatment would be staged so small areas would be done at a time and it would be controlled by a weir to keep levels in the river low. He said the goal was to try to reduce the concentration, but this could not be done unless the EDB was removed or more clean water was added. He added that those options were limited, leaving the shallow water pool as a viable alternative. Ms. Mack asked whether the EDB would rise into the air. Mr. Szymoniak stated this was occurring right now. He reiterated that the EDB is upwelling into the bog itself. He noted on the conceptual model that the plume was flowing fairly deep underground. He pointed out that just south of Hatchville Road, the EDB began to upwell in the river. He also said that there was another plume under the Augusta Bog. Mr. Szymoniak then stated that air sampling had been done over an eight-week period last August and the concentrations of EDB were fairly high. However, he clarified that the concentrations were not considered by the Massachusetts Department of Public Health (MDPH) to be a risk. He added that with EW-1 operating, there was already a noticeable reduction in the concentrations from last year. Therefore, any ponding would produce lower concentrations than what was present a year ago and would not be a risk. He remarked that it was a very good question. Ms. Mack reiterated her concern over the number of animals in their area that had been diagnosed with cancer. She noted this was a valid concern as they were overlooking the Lower Baptiste Bog and constantly breathing in the air. Mr. Szymoniak reminded her that the levels of EDB would probably be lower than what had been sampled last year. Ms. Mack stated that she wanted to go on record as being in support of leaving the bogs as conservation land for the animals and people to enjoy. Mr. Szymoniak responded by identifying on the map (see attachment #1) the bogs that would go out of production because there was no way to separate them from the river. He noted that because it was not a viable solution to realign the river and make the bogs treatment basins, Alternative B had been developed. He stated that six acres could be reverted back to a wetland. Ms. Mack asked if the bog would be minimally flooded in the event that flooding was indeed necessary. Mr. Szymoniak stated that would be the intent, however he did not know at what level it would need to be flooded. He noted that the entire bog would be ponded in order to lower the concentration. Ms. Mack expressed her concern about the impact of flooding the bogs on her septic system. She noted that she had always contacted Mr. Handy in the past if there was a problem. She asked who would be in charge when a problem developed. Mr. Szymoniak commented that this was a good question. He noted that just the remedial system was being discussed now and clarified that Ms. Mack wanted to know who to contact if the water was flooded to an unacceptable level. He asked Mr. Field to write her question on the board. Mr. Mack asked about berming the river. Mr. Szymoniak stated that there were no berms with this alternative. He explained that the bog would remain unchanged, however an attempt would be made to actively or passively treat the areas where the EDB was upwelling in an effort to lower the concentrations. Mr. Mack asked if the water would still flow down the river. Mr. Szymoniak acknowledged there would still be EDB in the river, although the goal was to get it to a level such that downgradient would be non-detect. Mr. Mack asked what effect a heavy rain would have in terms of over-flooding the area. Mr. Szymoniak replied that the bog would drain as it did now. He added that dilution was not necessarily the preferred answer because it would take longer for the EDB to come out. Mr. Mack asked who would be responsible for maintenance around the bog. He also expressed his concern over the wiring and pipes that would be brought in for treatment of the bog. Mr. Szymoniak responded that if shallow well points were used, the well points themselves were about an inch and a half in diameter. He explained there would be header pipe on top of the bog surface, but all of the pipes that brought water back to EW-1 would be buried. He noted that power would be necessary for the pumps and indicated on the map where power poles would be located. Mr. Mack commented on the beauty of the area and the wildlife he had observed around the bogs. He concluded that it would be a shame to lose it. Mr. Costa commented that the Falmouth Conservation Commission recommendation of a modified version of Alternative E where the entire river system was separated from the bogs made sense. He recognized that with the EDB contamination, the Commission would be looking for ways to deal with fish management and run-off issues. He observed that Mr. Szymoniak seemed to be stating that if Pond 14 were clean, berming the lower bogs would be unnecessary. He noted that berming the lower bogs could be viewed as insurance in case Pond 14 did not turn out to be clear. He asked if there was anything in the Superfund process that precluded paying for the berming of the lower bogs. Ms. Balkus replied that she was not sure that the Superfund process would preclude it specifically. She said that she would need to speak with the lawyers to be sure. She also stated that if it was shown from an engineering and solution standpoint that Pond 14 was non-detect, environmental funds would be spent "cleaning up" EDB that was not in the lower bogs. She stated that she did not know if there was another way to show the beneficial aspects of berming, such as separating the river and keeping the pesticides from the bogs out of the river system and fisheries. She agreed it was a good idea, but was not sure if AFCEE could do that under the Superfund process. Ms. Kiley asked Ocean Spray to re-state its position with regard to EDB in the water. Mr. Bicki stated that Ocean Sprays official position was to have the cranberries growing in or coming in near contact with non-detect water. He noted that if option one of Alternative E, which included the shallow well points, could result in non-detect levels of EDB, it would solve the problem in terms of all the other bogs. If not, he noted that there would still be a question of marketability of the fruit coming in close contact with contaminated water. He added that it was hard to say how consumers would react given all the publicity on this issue. Mr. Szymoniak stated it might not be possible from a liability standpoint to get non-detect. He added that separating the bogs and providing an alternate water source did not necessarily mean that non-detect water entering Pond 14 would be achieved. Mr. Bicki stated that Ocean Spray was unsure about the upper sections, but the non-detect area below Pond 14 fell within the guidelines of marketability. Mr. Field summarized by stating that the water in the Lower Baptiste Bog may not get to non-detect. Mr. Szymoniak concurred that this was correct unless a large volume of water, about 1500 gpm, could be pumped to keep up with the river. He added that this option was not feasible in that a large volume would have to be pumped without a guarantee of non-detect. He suggested pumping in a few specific areas where the upwelling occurred rather than attempting to pump a large volume. Mr. McDermott stated that he had read that the Air Force wanted to be out of the cranberry business by the year 2000. He also recalled a claim made by the Air Force that there was no EDB found in the cranberries after the pre-test. He commented that the protocol that was in place for the pre-tests was developed by the state, AFCEE and the Food and Drug Administration (FDA). He questioned what would happen if the protocol testing was completed and, although the EDB was present in low levels in the water, it was shown that EDB could not enter the fruit through the roots or skin. Mr. McDermott expressed his concern that if there were no threat to human health, the Air Force would refuse to compensate the growers and would leave them to deal with Ocean Spray and the other purchasers. Mr. Field suggested that Mr. Braun from the MDPH explain any relevant protocols or guidelines and turn the rest of the question over to Ms. Balkus. Mr. Braun clarified that the protocols were strictly analytical, a methodology to do analysis on fruit. He stated that Massachusetts had a non-detect standard for fruit as well as for many other food items. He noted that results of the Kansas State University studies would not be available for over a year and any action could not be taken until then. He explained that the testing protocol had been reviewed and audited by members of the Air Force, the state lab, the MDPH and the US EPA.. He stated that a consensus had been reached that the lab chosen by the Air Force was suitable and capable of completing the analysis, therefore everyone should be comfortable with the results. He noted there was some concern about "split analysis." Mr. McDermott reiterated his concern over whether the Air Force was committed to EDB-free water or to just meeting the standard set by the state. Mr. Field rephrased the question by asking if the result was that the cranberries were non-detect, would the Air Force be concerned about EDB in the water. Ms. Balkus clarified that the intent of the bog project was to address the time period between the present and when it was determined that there was no EDB in the fruit and no possible way it could get into the fruit. She explained the two Air Force-sponsored research studies to be completed by Kansas State University: The first study would entail floating cranberries in surface water containing different concentrations of EDB to determine at what level it would be possible for EDB to enter the fruit, or if it would enter the fruit at all. The results of this study would be available in January of 1999. The second study involved determining whether a plant grown in a controlled environment could absorb EDB from the water through the roots or vines, transfer it into the flower, and eventually be present in the fruit. Because this study required that the plant go through a complete life cycle, Ms. Balkus stated that the preliminary data would be available in the year 2000. In order to make the process an actual research study that was verifiable, the growth effort had to be repeated. The complete results would be available in 2001. She noted that studies on other plants showed almost overwhelmingly that EDB could not make it into a plant, but there was not a specific cranberry study. She noted that, in the interim, the Air Force wanted to take an action that would ensure the return of the cranberry bogs to production. She concluded that after an action was taken and the data was obtained from Kansas State University, the Air Force could say it had done everything it could to return the river system to a productive market, but could not guarantee that Ocean Spray would purchase the crop. Mr. McDermott agreed with her explanation, but asked why taxpayer money would be spent on a remedy that may be considered unnecessary in two years. Ms. Balkus noted that it was more cost effective to implement a corrective action that reduced or controlled the contamination, rather than continue to pay for the crop. Mr. McDermott asked why the Adams Bog was being treated. Mr. Szymoniak noted the location of the plume on the map and stated that it would take longer than two years to achieve non-detect water. He thought it would be closer to five to seven years. Mr. McDermott asked again what the Air Force's position would be if the Kansas State University research indicated that it was impossible for EDB to get into the berries. Mr. Szymoniak asked if Mr. McDermott was suggesting that the Air Force compensate growers until the results of the studies came out. Mr. McDermott remarked that he personally did not think the bogs should be in production and that the growers should be "realistically" compensated. He noted that if it were shown that EDB could not get into the berries through the skin or roots, the amount of EDB in the river would not make a difference. Mr. Szymoniak noted that there were abutters to the bogs that wanted the EDB removed from the river. Mr. McDermott reiterated his concern that the Air Force would leave the cranberry growers to deal with Ocean Spray and other buyers if it was found that EDB could not enter the fruit because the Air Force could say there was no way it had spoiled the crop. Mr. Field noted that this was a very important question and asked if the Air Force wanted to answer it now. Mr. Szymoniak noted that there were many "what ifs?": what if the concentrations could not be reduced, what if the concentrations began to increase, what if EW-1 was not as effective as initially thought. Mr. McDermott stated that he was advocating that the growers be realistically compensated. Mr. Szymoniak stated that the Air Force was trying to restore the river to what it had been. Mr. Gordon commented that he thought the MDPH had ordered the Air Force to provide EDB-free water not only for production of the fruit, but for the health of the farms. Mr. Braun said he did not recall any order for the military to remove all of the EDB. He clarified that the MDPH was concerned about EDB exposure to workers, the bogs on the Coonamessett River, and long-term exposure to people who lived in the area. He added that this was just another unknown to add to Mr. Szymoniak's list of unknown variables. Mr. Braun remarked that although it did not believe there was an immediate health risk, the MDPH preferred to take corrective action sooner rather than later. Mr. Taylor concurred that the real question was whether the Air Force would be responsible for the perception problem. Although the concentrations of EDB could be found to be low enough, the cranberries would not be purchased because of the perception problem. He asked whether the Air Force would continue to compensate cranberry growers if this were the case. Mr. McDermott thought the Air Force would say the problem was with Ocean Spray. Mr. Boyer thought that the issue was much more complicated than Mr. McDermott suggested. He then noted he wanted to clarify a few points. He asked Mr. Szymoniak whether he understood correctly that in the Lower Baptiste Bog, there would be several extraction points, the active model would be running through EW-1 for treatment and then would be part of the alternative water supply for various functions of the bogs. Mr. Szymoniak said this was correct. Mr. Boyer noted that in the active treatment of that segment, there needed to be some form of holding pond in order to get the acre feet, depending on timing or winter flooding, or some calculated reserves to get the water to the appropriate place. Mr. Szymoniak said this was correct and explained that the bogs currently relied on the river to flood, so the reserve capacity would be an added benefit, rather than a necessity. Mr. Boyer stated this would be an additional treatment since there would continue to be some upwelling in the upper bogs, but would possibly be non-detect once the water came through the Lower Baptiste. Mr. Szymoniak said this was correct and had been demonstrated in a year and a halfs worth of surface water data. Mr. Boyer summarized the decision before the group. He thought that a consensus was forming with respect to Alternative E, with the incorporation of some of the Conservation Commissions suggestions. Specifically, if the Upper Baptiste Bogs could be weired off with passive treatment, the real decision was what to do with the Lower Baptiste Bog: extraction and treatment or dilution. He thought that realigning the channels was not a feasible solution. He suggested berming the East Thompson Bog, incorporating the shallow well points to extract and treat as much of the bog as possible and using the treated water as an alternate water source. He also recommended berming the easterly side of the river. He asked Mr. Szymoniak if there were questions remaining about the offered solutions that would delay the decision-making process. Mr. Szymoniak thought that perhaps the preferred alternative should not have been included in the presentation, as it had dictated their thinking all along. He said that it would be easier to realign the channel on the opposite side of what Mr. Boyer suggested. He also stated that the disadvantage of this option was that the Chaston bog relied on the East Thompson Bog to be proportionately flooded. However, he noted that clean water from the treatment system could be added and a smaller pond would not necessarily be needed to provide water. Mr. Boyer suggested developing a consensus regarding the treatment and berming of the East Thompson Bog and then ending the meeting. Mr. Szymoniak remarked that removal of the weir might be a good idea from a fisheries standpoint. He explained that if this option were chosen, the area could be returned to a natural wetland that would help the fish migration pathway. Mr. Field noted his understanding that there were people at the meeting who favored buying out the bogs and allowing them to return to their natural state. However, he asked whether those attendees who preferred Alternative E or a phased Alternative E favored the shallow well treatment or a more passive treatment. Mr. Gordon stated that the Falmouth Conservation Commission wanted a passive treatment, or at least a softer approach. He suggested increasing the capacity of EW-1. Mr. Szymoniak clarified that a method of extraction could be implemented to utilize the remaining capacity of EW-1. He asked if Mr. Gordon meant that some form of active treatment could be carried out as long as the treatment plant did not need to be expanded. Mr. Gordon said he thought that should be the first step. Mr. Szymoniak concluded that there should be a phased approach and suggested staying with the current plan: a combination of active and passive treatment to lower EDB to the desired levels, specifically using shallow well points, utilizing the full capacity of EW-1 and then looking at a passive approach to lowering the levels of EDB. Mr. Field summarized by stating that for the attendees who preferred Alternative E, a phased approach including active and passive treatment was favored. He noted that Mr. Boyers second question was whether there was a preference for berming or realignment of the channel. He confirmed that Mr. Boyer was against realignment of the channel. Mr. Boyer noted that from an administrative point of view, the permitting itself would be an elaborate and time-consuming event. He added that it was a "cleaner, quicker and less ambiguous solution to simply hold on to the eastern half and let the western half go." Ms. Balkus stated that AFCEE preferred the western channel because there was already a channel there. Because of this, she thought the realignment might fall under an agricultural exemption in which the Town and the Air Force could work out an agreement, which could be implemented by Mr. Handy. She said that it would reduce the permitting required because Mr. Handy would just be berming off and making the perimeter trench a bypass of that bog operation. She noted that this option also helped with some of the flooding in that putting the river on the west side of the bog would limit the flooding. She reiterated the benefits to the fisheries that Mr. Szymoniak had mentioned, including the removal of the weir. Ms. MacRae recalled that Mr. Montague, the shellfish warden, had favored leaving the channel as it was. She stated she had a great interest in the East Thompson Bog because her home was right there. She said that she preferred that the berming be done on the west side; the river should be left alone. Ms. Kiley clarified that although Mr. Field was looking for input on Alternative E, the Massachusetts Department of Environmental Protection (MA DEP) was not coming forward with a preference because there had not been a determination made as to under what authority the work would be done: CERCLA (Comprehensive Environmental Response, Compensation and Liability Act) or a wetlands perspective. She said that the MA DEPs silence should not be mistaken for approval. She added, however, that the department was willing to work with the military and the growers as far as any of the permitting aspects, in particular the agricultural exemption. Mr. Adams remarked that the location of the river might have been different anyway, due to the bog building process. He added that moving the river would help prevent flooding in that particular section of the river. Ms. Muramoto commented that there were good reasons for both berming the channel and realigning the river. Although she could not speak for the shellfish warden, Ms. Muramoto thought that it would be easier to maintain the channel by working on the channel, rather than close to land. She noted that there were wetlands along the side of the river and asked what impact the realignment of the channel would have on them. She added that there were many unknowns and there was no information on the stability of the bog. Mr. McDermott noted that it was still not clear who would be responsible for the maintenance of the bog. He asked whether the federal government had the money to compensate not only the growers, but the property owners as well. Mr. Field summarized Mr. McDermotts concerns: compensation to growers and residents that are adversely impacted and the party responsible if something were to happen when the bogs were flooded. Mr. Adams disagreed that property values were declining as a result of the EDB, although he could not say the same for his cranberry bog. He noted that town water had been supplied by the Air Force in an attempt to rectify the situation and he would prefer a solution to the problem. Mr. Field reminded the attendees that there were differences of opinion and it was important to get those out. He concluded that the group would not be able to agree at this time on whether or not it made sense to berm or divert the channel. He mentioned there were also individuals who felt strongly that the bogs should be bought out and the growers be compensated. He stated that enough uncertainties and unknowns had been identified to necessitate more research. Mr. Lim asked if at least half of the 3.1 acres in the East Thompson Bog would be lost with Option 2 of Alternative E. Mr. Szymoniak said yes. He also clarified that Option 2 included berming on the east side, Option 1 was the realignment. He noted that the figures were included in the matrix (see attachment #2). Ms. Miles stated that although the group was focusing on Alternative E, she thought the other alternatives should continue to be evaluated. She noted that Alternative C was the only option that would get the entire river system to non-detect and wanted to see that option examined further. Mr. Szymoniak stated that continued consideration of the other alternatives was implied by the phasing of Alternative E. To clarify, Mr. Field asked whether adjustments to Alternative E could get the entire river system to non-detect. Mr., Szymoniak said yes, because Alternative E begins with the well points, which is the same as Alternative C. Ms. Miles asked whether the purpose of Alternative E was to obtain a ten-fold decrease in concentration through the use of a holding basin, with or without shallow well points. Mr. Szymoniak said this was correct, but a pond would not be implemented first. There would be a pilot test initially, before realignment of the river or building a holding basin. Ms. Miles noted that in a previous meeting, Mr. Szymoniak had presented two options in Alternative C, one that included realignment and one that did not. Mr. Szymoniak stated this was correct. Ms. Miles stated that she thought Alternative C involved treatment that would capture the water at the point of upwelling, treat it and get it to non-detect, so that potentially all of the bogs could go back into production and it would have other benefits as well with the river. She thought that Alternative E did not have the same objective in that only at part of the river would the concentration decrease ten-fold, then the other bogs would be bermed off where the water could enter. She noted that the objective was only to get Pond 14 to get to non-detect. She then asked Mr. Szymoniak why there would be an increase in the treatment of the Lower Baptiste Bog. Mr. Szymoniak replied that if the concentrations were unacceptable, it might be beneficial to increase the treatment, although it was not necessarily the preferred alternative because of the large volume to be treated. He clarified that the purpose of this alternative was not to bring the entire river system to non-detect. Ms. Miles noted that this was an important point, which illustrated the need to examine the pros and cons of every alternative. She mentioned Ocean Sprays concern that contaminated water would continue to flow in close proximity to the bogs. She reiterated the need to discuss Alternative C in more detail. Mr. Field suggested further discussion of the pros and cons of Alternative C and E. Mr. Szymoniak noted that the matrix compared the pros and cons of each alternative. He explained that the matrix included a description of the location and size of each bog, the owner of the bog, the results of inflow and outflow samples, the potential actions for each bog, and the costs of the different options. He added that a time frame for each option was also provided, excluding the permitting process. Mr. Field asked Mr. Szymoniak to give a brief review of Options C1 and C2. Mr. Szymoniak explained that Option C1 relied on realigning the river. Shallow well points would be used to extract the water, pumping at approximately 1500 gpm. He noted that, at this rate, the treatment facility would need to be increased almost three-fold. He stated that this would be about 2 million gallons per day, which indicated that it was a large plume that would be treated. He added that not all of this water was contaminated. Mr. Szymoniak went on to explain that Option C2 included the same realignment, but only targeted the mass contamination using the treatment facility at 800 gpm. The flow at EW-1 would be decreased to 400 gpm, the extra 400 gpm would treat the mass to lower the concentration. He noted that a cranberry bog and a basin would be used as back up in case of a power failure, or as an additional level of treatment that may not be achieved with only shallow well points. Mr. Field noted that in both Option C1 and C2, the Lower Baptiste Bog would be taken out of production. Mr. Szymoniak replied that only a portion would be taken out of production, an acre would be functional. Mr. Field asked whether C1 would treat the entire river from the point of treatment, downward. Mr. Szymoniak pointed out that the water leaving the Baptiste Bog would be non-detect. Mr. Field noted that Option C1 would achieve non-detect further up the river than Alternative E. Mr. Szymoniak explained that if Option C was implemented and water was pumped at 1500 gpm, the river would go to non-detect. He added there would be no reason to take any further action downgradient at that point. Mr. Schweisberg noted that according to the matrix Option C2 did not include river realignment. Mr. Szymoniak stated that Alternative C always included realignment, but C2 had a smaller treatment capacity. Mr. Schweisberg reiterated that the matrix stated C1 included channel realignment and C2 did not. Mr. Szymoniak said he had made a mistake and C2 would be pumping at a lower rate. Mr. Schweisberg remarked that this was an important point. Mr. Szymoniak agreed and clarified for the record that Option C2 did not include channel realignment. Mr. Field noted that Alternative E seemed to include Option C2. Mr. Szymoniak confirmed that this was correct. Ms. Balkus clarified that the intent of C1 was to pump water at the rate of 1500 gpm and put up the berm and the holding basin, and realign the channel. She explained that the intent of C2 was not to realign the channel, but to use the well points and existing capacity at EW-1. She confirmed that C2 was identical to what was being proposed in Alternative E. Mr. Szymoniak explained that C2 would not necessarily achieve non-detect, and added that he would know more once a pilot test was completed. Ms. Kiley noted that only Option C1 would achieve non-detect. Mr. Szymoniak stated this was correct. Ms Kiley asked whether, as with the Quashnet River, there had been consideration of using other types of treatment rather than GAC at EW-1, specifically, iron pilings. Mr. Szymoniak replied that because the GAC system was already constructed and the power was there, there would be no reason not to use the proven technology. Ms. Kiley noted the capacity issue with EW-1. Mr. Szymoniak stated his belief that GAC was still the right choice. Mr. Field stated that there were essentially three options on the table for discussion. The first option included a phased approach to Alternative E that used the existing capacity of EW-1. He noted there was still some discussion over whether the East Thompson Bog should be bermed or the channel realigned. The second option involved leaving C1 up for discussion since it provided for non-detect of more of the river than Alternative E. The third option encompassed Alternative A; the bogs would be turned into wetlands and the growers would be compensated. Mr. Field asked the group if there were any questions or clarifications. Mr. LaFleur stated that he was concerned about detectable water coming out of the Lower Baptiste Bog. He asked if there was a way to determine if the shallow well pumping would work in order to get a better idea whether Alternative E would provide clean water. Mr. Szymoniak stated that there were two things that could be done. The first option would be to block Broad River and measure the concentrations at Station 14 in order to determine how to treat the water. He explained that the second option would be to do a pilot test to determine any reduction in concentration before bringing in the power. The water would be temporarily pumped to EW-1 for treatment and then measured. Mr. LaFleur noted that there was a chance that the water leaving the Lower Baptiste Bog would be non-detect. Mr. Szymoniak said this was correct. Ms Kiley noted that in order for any of the other alternatives to be considered further, the contingencies would need to be discussed. Mr. Field clarified that "contingencies" meant back-up plans should any of these alternatives not work. Mr. Gordon stated that the criteria for marketability of the berries included one-year non-detect. He asked whether the time was currently being tracked. Mr. Szymoniak said the clock had been running since August of 1997. Ms. Balkus explained that some of the bogs were already non-detect and a large portion of the bogs south of the Lower Baptiste Bog was already separated from the river. She noted that if the shallow well point system were installed, the concentrations would be decreased to .01. She also noted that the Augusta Bog and the west Chaston bog were already disconnected and did not use river water. The LaSalle and Adams Bogs would be bermed off so that they would not be using river water even though it would only be a .01 concentration. She said that she understood the concern of Ocean Spray representatives about the idea of perception. However, she believed that at such a low concentration, with a lot of explanation and detail of what actions have been taken, showing that the bogs were either separated or had an alternative water source, that the issue could be addressed. She also noted the cost differential of putting in a multi-million dollar system, compared to a more practical engineered solution. She said that she still wanted feedback from the group, but wanted to provide some perspective on the level of EDB concentrations that were being discussed. She reiterated that the concentrations were very low and over a rather short reach of the river. She also noted that the bogs in question were either already separated or would be separated from the river. Ms. Kiley asked whether steps had been taken to ensure that the Augusta Bog was no longer in contact with the river. Mr. Szymoniak replied that steps had been taken. Ms. Kiley asked if it was physically impossible for the bog to come in contact with the river. Mr. Szymoniak replied that it was not impossible, but that it would be much harder for the EDB to come into the bog. He added that the results of sampling up to this point indicated that the bog was non-detect, so it had not been disconnected from the river. Ms. Muramoto asked Mr. Bicki if any marketing research was being done currently to try to help predict consumer response and, if so, how the results of the research could be accessed. Mr. Bicki replied that some research work was done when the issue first came up, which drove Ocean Spray away from accepting the fruit. He also noted that the communications department was pursuing market research with the future crop in mind. Mr. McDermott stated that Ocean Spray had a tremendous need for cranberries that were not used in food, but in testing for shelf life and other things. He then asked Mr. Bicki how many barrels of cranberries Ocean Spray used for that purpose each year. Mr. Bicki clarified that Ocean Spray did not take in barrels of fruit for testing. He stressed that it would serve no purpose to take in contaminated fruit and contaminate the facilities with it. He also explained that the small amounts of fruit that were used internally for quality research purposes came directly from the usable fruit within the cooperative. Mr. Bicki then addressed the issue of public perception and the marketability of the fruit. He explained that a pesticide scare in 1959 had nearly destroyed the cranberry industry, even though it had turned out that there was no pesticide issue. He also mentioned the "E. Coli" outbreak in imported raspberries two years ago. Because people thought it was associated with American strawberries, it decimated the strawberry industry. He noted that there were still people today who would not buy fresh strawberries grown in California because of the fear of contamination. He reminded the attendees of the Macks concern that the neighborhood dogs were developing tumors thought to possibly be a result of EDB. He asked that the group keep in mind that public perception played a large part in the marketability of the fruit. Mr. Field again summarized the three options that were on the table for discussion: Alternatives A, C1 and E. He noted the concerns that had been expressed by abutters over the flooding of the bogs, the impact on the septic systems, and who would be responsible for maintenance and emergencies. He also noted the issue of contingency plans if these alternatives did not work and the question of public perception and its impact on the fruits marketability. Ms. Miles asked about moving on to the next step. Ms. Balkus stated she was not ready to concede. She noted that Mr. Field had just summarized the discussion so far, but she did not feel the group was ready to determine whether or not it had reached a consensus on an alternative. Ms. Miles said she understood her concern, but knew that the US EPA would not be able to recommend an alternative that day. She stated that it seemed as though the group had narrowed the field of options and the Air Force needed to determine under what legal authority it would proceed. She explained that if the Air Force proceeded under CERCLA, it would need to prepare an action memorandum, but would skip producing an engineering evaluation cost analysis (EE/CA) document that the US EPA would evaluate. She added that the Air Force would still need to do an alternatives analysis under another authority if it did not proceed under CERCLA. She concluded that it was not realistic or appropriate to narrow the field to one alternative. Mr. Boyer disagreed with Ms. Miles and suggested that the group develop a course of action rather than argue over whose authority would govern the actions or alternatives to be considered. He noted that the shallow well point testing would help determine an explicit course of action that could result in selecting Alternative E. Mr. Field suggested reviewing the next steps, not as the concluding statement of the meeting, but just in case any members of the group had questions. Ms. Kiley remarked that the next steps could help in refining any of the alternatives chosen. Mr. Szymoniak referred back to AFCEEs preferred alternative. He noted that it included parts of everything that had been discussed: berming of the Upper Baptiste and Adams Bogs, shallow well points, possible realignment, providing alternate water sources and evaluation of Pond 14. He suggested that the group look at berming the Upper Baptiste, Adams and LaSalle Bogs. He emphasized that the shallow well point test program needed to be completed before moving in a power source. He reiterated that the suggestions that had been made by the group were all part of Alternative E. Mr. Schweisberg asked if AFCEE would be unable to complete the pilot test on well point extraction if the group did not choose an alternative. Mr. Szymoniak replied that AFCEE would be able to move forward. Mr. Schweisberg stated that the group was in agreement that they needed to move in a general direction, rather than honing in on a precise alternative. He remarked that it appeared that some steps could be taken and tests be completed without an alternative being selected. He concluded that the group did not have enough information to select an alternative. Ms. Balkus disagreed with what Mr. Szymoniak had said. She explained that if the group were to agree on Alternative A, the buyout would be implemented and there would be no reason to do the pilot test. She also noted that there was a very significant time-driver associated with the project; Congress had only given the Air Force legislative authority through the 1999 crop year, therefore, an alternative needed to be selected, designed, constructed and implemented in the 1999 time frame. It would need to be working early in the season so that during that harvest period, the surface water would be non-detect. She stated that some additional legislative authority or compensation could be pursued, but Congressmen from the other states were not supportive of this project and it would be incredibly difficult to get the funds again. She emphasized that AFCEE wanted to be extremely proactive in making sure that whatever decision was made would be implemented expeditiously. She noted her concern that the longer it took to narrow the alternatives, to come to a solution, the longer it would take to get started on design and implementation. She explained that the goal initially was to make a decision in September, engineer and design it in October, and start construction in November. Looking at what had been proposed, she said the ranges of implementation took from six months for alternative E, to nine or ten months if something as big as Alternative C was chosen, due to the additional size of the treatment plant. Ms. Muramoto asked what criteria would be used to change course and implement Option C1 if Alternative E was in place. She also asked how quickly this change could be accomplished. Ms. Balkus replied that the goal of Alternative E was to reduce the concentration at the upwelling site from .1 to .01, so that by the time the water reached Pond 14, it would be non-detect. She said that it would be known within a month of the pilot test whether the 400 gpms that existed at EW-1 would be sufficient. Mr. Field noted that the group may want to discuss the buyout option further, although he did not think there would be consensus that day. He asked whether the group thought they had narrowed the discussion to what standard they wanted to achieve at the Lower Baptiste outfall. Mr. Szymoniak felt that the group had attempted to work through that in the morning meeting. He remarked that the vines and the bog could be non-detect or there could be a ten-fold drop in the concentration that would still be detectable. Ms. Balkus commented that if the Kansas State University studies confirmed that no EDB could get into the cranberries and .01 concentration or less was achieved in the river system, it could have a positive impact on the marketability of the fruit. Mr. Adams asked whether the area below Pond 14 would still be non-detect. Mr. Szymoniak said that was the goal. Mr. Adams stated that the funding did not exist for a buyout. He noted that there was only money in place for the next two years to implement either Alternative C1 or E. Ms. Balkus stated this was correct. Ms. Miles clarified that there were two types of funding involved, one to compensate the growers and the town for lost revenue, the other to cover the cost of building one of the alternatives. Mr. Adams said he understood that and Mr. McDermott remarked that, to his knowledge, no money had been appropriated. Ms. Balkus summarized that Mr. Adams was correct in that a buyout of either the crop or real estate would require an alternative to environmental funding. She stated that the funds were in place to implement any of the engineered alternatives. Mr. McDermott asked whether buying real estate was considered a form of remediation. Ms. Balkus said she would need to check with the attorneys, but for environmental clean up purposes, Defense Environmental Restoration Account (DERA) funds were used. Mr. Field asked whether there was definitely compensation for 1999. Ms. Balkus replied there was compensation for 1998 and 1999, but not 2000. Ms. Miles understood the concern regarding the authorization for compensation, but noted there was some urgency to reach a consensus on a single alternative with respect to these bogs. She noted that the Air Force seemed comfortable with agreeing to narrow the alternatives and move forward with regard to the Quashnet River system. She asked why there was a reluctance to do that now. She also expressed her concern as to whether there would be a document that compared alternatives that would be put out for public comment, like an EE/CA, or if the Air Force intended to deem the meeting the "public process", put out a document with one alternative, and move forward with it. Ms. Balkus replied that the alternatives that had been discussed at the morning meeting were very closely related and could be phased one right after the other. She noted that this was not a possibility at the present meeting because the buyout alternative was still on the table. If the group was able to narrow the selection down to engineered alternatives, but there was still a difference of opinion on the level of treatment, it would be easy to write it into the plan later. Mr. Field noted that the second part of the question pertained to AFCEEs next step in terms of producing an EE/CA or a comparison of alternatives and allowing for public comment. Ms. Balkus replied that until a process determination was made, she could not specifically say what documents would or would not be produced. However, she suggested following the FS-28 EW-1 model. Ms. Miles apologized to the other attendees for dwelling on the process. She stated that EW-1 was a time-critical removal action, but thought that what was being covered here was not time-critical. She noted that members of the public had expressed an interest in a public process if an EE/CA were done. She said she was having a problem with the fact that the process seemed to be unclear and changing at every meeting. Ms. Balkus remarked that she understood Ms. Miless concern. She noted that at the Falmouth Public Meeting, it had been stated that before any alternative would be implemented, a notice of intent would be filed, allowing for public comment. She agreed that until the process question was answered definitively, she could not say whether it would be an EE/CA, an action memorandum, or if it would go through the full notice of intent and the US Army Corps of Engineers (USACE) Wetland Program. She remarked that any of those options requires public involvement and AFCEE was not trying to subvert the process. She asked that the group try to come to consensus where possible and keep moving forward to avoid losing any time. Mr. Szymoniak suggested that if this were not a time-critical process and the action memorandum written for FS-28 was used, all of the alternatives would be included, along with cost, to derive a preferred alternative as part of that action memorandum. He noted it would not quite fit the model of the EW-1 but would have all the aspects. Ms. Miles said she did not even need that much. She was concerned that there was a rush to judgment without having a full process whereby alternatives could be compared and without an opportunity for the public to evaluate and comment on those alternatives. Mr. Schweisberg remarked that if the decision were not to go to CERCLA, the Air Force would have to go back to the Clean Water Act (CWA) and determine the range of alternatives to offer the public in terms of cost and environmental impact, both short- and long-term. He noted that the Fall Harvest Plan had backfired and thought that some lessons had been learned about proceeding too quickly and making sure certain steps were taken along the way. Mr. Spear pointed out that Alternative E included several options, should the group be concerned about having alternatives. He explained that Alternative E accounted for varying results of the different types of treatment. He felt that the real argument was between Alternative A and Alternative E. Mr. Handy expressed his frustration with the discussion. He stated that the group had been meeting since the previous March, trying to include all the stakeholders so everyone could express their concerns. He noted that Mr. Boyer, representing the Town of Falmouth, Mr. Gordon, representing the Falmouth Conservation Commission, and himself, as an operator of the bogs, all wanted to go ahead with the project and get something done. He stated it had been two years and it seemed as though the project was being held up by the regulators, despite the interests of the people that owned and managed the property in question. Mr. Field interjected to summarize the progress that had been made. He reiterated his doubt that a consensus could be reached between the buyout and Alternative E. He also noted that the question of a permitting process would not be answered at this meeting. Mr. Costa asked what would happen if there was no consensus in the group. Mr. Field said the goal was to choose and alternative that everyone could "live with." However, he noted that the regulators would have to explain what the standard process was for dealing with differences of opinion over an EE/CA or action memorandum. Ms. Miles explained that with the Superfund removal process, the Air Force would make the final decision after the EE/CA was produced and the public and the regulators were allowed to comment. Ms. Miles then addressed Mr. Handys frustration with the meeting. She said that the Air Force had not been providing the US EPA with enough information to make the alternatives work from a regulators perspective. She explained that the US EPA was unable to choose one of the alternatives without that information. Mr. Handy questioned the purpose of the meetings if the regulators were not getting any information. Ms. Miles stated that the meetings covered technical details, but she needed answers to legal questions before she could evaluate the alternatives. Ms. Balkus stated that she had met with Ms. Miles on several occasions outside of these meetings and was concerned that Ms. Miles had indicated that no one had met with her. Ms. Balkus noted that a meeting was scheduled the next day between Ms. Miles and Air Force lawyers to talk about this issue. Ms. Miles said she had no knowledge of that meeting. Mr. Field interrupted to suggest that the group focus on moving forward. He asked Mr. Szymoniak and Ms. Balkus to speak about the next steps involved in achieving AFCEEs preferred alternative. Ms. Balkus explained that if consensus were not reached at this meeting, the decision would move to the Management Review Group (MRG). If the MRG was unable to reach a decision, the matter would go to the Executive Review Group (ERG). She noted that those meetings would be taking place within the next week. She added that todays meeting was an attempt to work with the people who were the most informed and educated on the issues and narrow the alternatives. Mr. Szymoniak explained the next steps. The plan included some new wells that would be examined for contamination and identification of the plumes migration. He stated that a tracer test would be conducted at Pond 14 to evaluate the weir. The last step would be to prepare an action memorandum, or an EE/CA, which would outline the actions AFCEE was planning to take. Mr. McDermott noted that although the group mentioned the buyout option, no one had expanded on the advantages of it. He noted that EDB was not the only problem in the Coonamessett River, that herbicides and pesticides from the bogs also contaminated the river. He mentioned evidence given by Mr. Hurley of the Massachusetts Division of Fisheries and Wildlife (MDFW), at the Senior Management Board (SMB) meeting. He said that the evidence outlined the impacts of the bogs including flattening the river valley, widening the river channel, and decreasing the stability and size of the river. He noted that the total cost to the Town of Falmouth for the bogs was only $87,500. He encouraged the development of a comparative study of the environmental benefit to the Town by having the bogs returned to their natural state. He recommended that any money received by the Town as damages from the Air Force due to the EDB contamination be paid as compensation to the private growers. Mr. Field asked if any attendees had questions about the next steps. Mr. Spear asked the US EPA and the MassDEP about the environmental impacts of the alternatives. Mr. Adams asked both agencies what the delay was in considering the alternatives. Ms. Miles explained that the process through which the alternatives went meant a great deal. She noted that the Air Force would have the advantage of fewer, if any permits, if it were to go through the CERCLA/Superfund process. She noted that documents needed to be produced in order to determine whether the alternatives proposed would trigger other applicable laws. She added that even if the Air Force chose a non-CERCLA process, there were still a number of steps to be undertaken with evaluation and review in terms of the CWA. She concluded that since a process had not yet been chosen, it would be premature for either agency to make a determination. Mr. Adams stated this did not answer his question in terms of the US EPAs problem with Alternative E. Ms. Miles replied she did not have a problem with that alternative, yet. However, she noted that certain questions needed to be answered by the Air Force before she could make a judgment. Mr. Adams reiterated that the subject matter had been analyzed for months. Ms. Miles stated that he was looking at it from a technical perspective, but that the US EPA had criteria defined in certain laws that must be met. Mr. Spear asked if Ms. Miles could give some examples of the information she needed. Ms. Miles explained that the Air Force needed to present an analysis of each alternative with respect to laws applying to surface water standards. She remarked that the Air Forces delay in producing this analysis was probably due to its indecision regarding whether or not to go through the Superfund process. Mr. Spear stated that he was beginning to understand the US EPAs hesitation. He suggested making a decision on an alternative and then subjecting that alternative to all of the review necessary to determine a permit process. Mr. Schweisberg commented that it made sense to move forward in filling some of the data gaps, rather than picking an alternative. He noted that the Air Force, in the meantime, needed to make a decision on which line of authority it would pursue. He went on to explain what the process would be if the Air Force chose to go non-CERCLA. A CWA permit and a Massachusetts Wetland Protection Act permit would be required. This would involve two more agencies in making the decision, the Conservation Commission and potentially the MA DEP, if something were appealed. The USACE, who have not been a player in any of these meetings, would become the permit decision-maker under the CWA. He noted that the USACE had a very set process for the analysis of not one alternative, but several alternatives to compare all socio-economic impacts, all environmental impacts, the costs, the long-term benefits and negatives. Mr. Schweisberg explained that if there were a need for a CWA discharge permit, there would be yet another process to go through with many similarities, but also with its particulars. He concluded that it was critical that the Air Force makes a decision regarding authority in order to determine the direction of the process and the information that would have to be obtained. He stressed that a decision on an alternative could not be made until the Air Force selected a process. Mr. Field summarized that the work accomplished at the meeting, the narrowing of alternatives and scrutiny of next steps, would not be lost and a decision as to process would need to be made soon. He reminded the group of AFCEEs concern over time and possible compensation lost. He noted that some clarity had been achieved in terms of what the different stakeholders were thinking. He asked if there were any concluding remarks. Mr. Taylor asked if the group could select Alternative E, subject to the approval of the regulators. Mr. Field suggested an informal vote. The majority of the attendees, including the MDFW, the Cape Cod Cranberry Growers Association (CCCGA), Ocean Spray, the Falmouth Conservation Commission, and the United States Department of Agriculture (USDA) were in favor of Alternative E, subject to the approval of the regulatory agencies. The regulatory agencies and the abutters refrained from expressing a preference at this time. One attendee indicated that he was opposed to Alternative E. Mr. Field noted that this was a straw poll. Ms. Balkus thanked the group for their time and dedication. The meeting was adjourned at 4:25 PM. |