2001 CPEO Military List Archive

From: joelf@cape.com
Date: 5 Mar 2001 17:56:34 -0000
Reply: cpeo-military
Subject: [CPEO-MEF] Munitions Toxics in MMR Soil, Water
 
Please Post

Dear Folks,

For those of you living near bombing or artillery ranges who believe 
that munitions training may be polluting your soil and/or drinking 
water, I am posting the findings (as of January, 2001) extracted from 
EPA Region 1 Administrative Order #4. The first three paragraphs 
summarize Orders 1-3 under the Safe Drinking Water Act.. ("MW" is an 
abbreviation for "monitoring well".)



18.    On February 27, 1997, pursuant to Section 1431 of the Safe 
Drinking Water Act (SDWA),  42 U.S.C. 300i, EPA issued Administrative 
Order SDWA I-97-1019, which required the National Guard Bureau to 
investigate contamination at and emanating from the Training Ranges 
and Impact Area.

19.   On April 10, 1997, EPA issued Administrative Order SDWA 
I-97-1030, which required the National Guard Bureau and the 
Massachusetts National Guard to cease certain training activities 
pending the completion of environmental investigations at the 
Training Ranges and Impact Area.  Administrative Order SDWA I-97-1030 
was later modified on July 25, 1997.

20.   On January 7, 2000, EPA issued Administrative Order SDWA 
I-2000-0014, which required the National Guard Bureau and the 
Massachusetts National Guard to undertake rapid response actions and 
remedial actions to address contamination in certain areas at the 
Training Ranges and Impact Area.  Administrative Order SDWA 
I-2000-0014 required the National Guard Bureau, among other things, 
to undertake a feasibility study to address unexploded ordnance (UXO) 
and munitions which have been disposed of at the Training Ranges and 
Impact Area, and upon approval by EPA, to implement remedial measures 
relating to UXO and munitions.


21.  Munitions and other materials used at the Training Ranges and 
Impact Area, both currently and in the past, contain solid wastes, 
hazardous constituents and/or hazardous wastes, including the 
compounds detected in groundwater and soil discussed in paragraph 28 
below.  A partial list of the munitions used at MMR and their 
components is contained in the Ordnance and Explosives Archive Search 
Report (Army Corps of Engineers, March, 1999), the Draft Range Use 
History Report (Ogden Environmental, June, 1997) and Draft Chemical 
Composition of Munitions Report (Ogden Environmental, June, 1997).

22.    Munitions used by Respondents in artillery and mortar firing 
at MMR contained explosive compounds.  High explosives used at MMR in 
the past for mortar, rocket and artillery firing and for grenades 
include trinitrotoluene (TNT) and Royal Demolition Explosive (RDX), 
hexahydro-1,3,5-trinitro-1,3,5-triazine.  

23.   Propellants used in the past at MMR for artillery include 
single base propellants.  The constituents of single base propellants 
include, among other things, dinitrotoluene (DNT), dibutylphthalate 
and diphenylamine.  The isomers 2,4-DNT and 2,6-DNT are compounds 
that compose technical grade DNT.

24.  Propellants that were used at MMR for mortar and rocket firing 
included double-base propellants, including M7, M8, and M9 
propellants.  Generally, double-base propellants include 
nitroglycerin as one of the constituents.  Nitroglycerin and 
diethylphthalate together account for 46% of the reported weight of 
M8 propellants.  M9 propellants also contain diphenylamine.  

25.  Munitions used by Respondents at MMR contained metals that have 
been found in soil in the Training Ranges and Impact Area, including 
lead, antimony, beryllium, molybdenum, copper, barium, aluminum, 
magnesium, cadmium, and thallium.  

26.  Pyrotechnics were also used in training operations at MMR. 
 Available information indicates that many of the pyrotechnics have 
hazardous constituents, including but not limited to contaminants 
detected in soil and groundwater in the Impact Area and Training 
Range.  Many pyrotechnics used at MMR contain hazardous constituents 
such as lead thiocyanate, nitroglycerin, diethylphthalate, 
 hexachlorobenzene, magnesium, aluminum, and acetone.

27.   Portions of the Training Ranges and Impact Area have been 
investigated for groundwater, soil and sediment contamination 
pursuant to EPA's Administrative Order SDWA I-97-1019.  To date, this 
study has revealed that a number of areas in the Training Ranges and 
Impact Area have been contaminated by Respondents' disposal and 
training related activities.   Contamination from explosives, 
propellants, metals, herbicides, pesticides, volatile organic 
compounds, semivolatile organic compounds and UXO have been 
discovered in soil and/or groundwater in numerous areas. 
Investigations regarding the nature and extent of contamination at 
the Training Ranges and Impact Area  are ongoing.  

28.    Information gathered to date under this study indicates that 
specific areas at or near the Training Ranges and Impact Area 
 require response action, as described in Administrative Order SDWA 
I-2000-0014.  The specific areas, and some of the levels of 
contamination detected, are as follows:

         A.  Demolition Area I:    Demolition Area I, a training area 
used primarily for demolition, is located south of the Impact Area 
and north of Pocasset-Forestdale Road.  Types of materials used for 
training purposes at this location included C4, TNT, dynamite, shape 
charges, cratering charges, bangalore torpedoes, claymore mines and 
detonating cord. This area was also used for open burn/open 
detonation disposal of munitions.

RDX has been detected in groundwater monitoring wells in the vicinity 
or downgradient of Demolition Area 1 at concentrations in excess of 
EPA's Health Advisory for RDX of 2 ppb, as follows:

               MW 19     260 ppb
               MW 34         6.2 ppb
               MW 31     370 ppb
               MW 73      63 ppb
               MW-76      37 ppb
               MW 77    150 ppb

          MW34 is approximately one half mile west of Demolition Area 1.

2,4,6-TNT has been detected in groundwater in MW 19 at Demolition 
Area 1 at 16 ppb, which is in excess of EPA's Lifetime Health 
Advisory for TNT of 2 ppb.
        
The following is an incomplete list of contaminants which have also 
been detected in surface and subsurface soils at Demolition Area 1:
        
          Surface Soils:
RDX                                     14,000,000 ppb
HMX                                      1,300,000 ppb        
2A-4,6-DNT                                      800 ppb
4A,2,6-DNT                                      400 ppb
2,4,-DNT                                       1,800 ppb
Hexachlorobenzene                       7,400 ppb
dioxin (TEQ 2,3,7,8-TCDD)                  27.03 pg/g
2,6-DNT                                             40 ppb
Di-N-Butylphthalate                            290 ppb
N-nitrosodiphenylamine                     930 ppb

Subsurface Soils:
         RDX                               9,300 ppb
         HMX                                380 ppb
         2A-4,6-DNT                      360 ppb
         4A-2,6-DNT                      340 ppb
         2,4-DNT                          150 ppb
         Di-N-Butylpthalate             200 ppb
         N-nitrosodiphenylamine        34 ppb

The contaminants found in soil and groundwater in and downgradient of 
Demolition Area 1 lie within the zone of contribution for active 
public water supply wells in Bourne, Massachusetts.  A zone of 
contribution defines the land area from which groundwater flows into 
a drinking water well under pumping conditions.  Contaminants in soil 
and groundwater in a zone of contribution may be drawn into a 
drinking water well.

          The contamination in soils at Demolition Area 1 has entered 
and is likely to continue to enter the underlying groundwater.

B.  Chemical Spill (CS)-19:  The CS-19 site is a small area in the 
west-central region of the Impact Area that was used for the disposal 
of munitions, among other things.

RDX has been detected in groundwater monitoring wells in the vicinity 
or downgradient of CS-19, in excess of EPA's Health Advisory of 2 ppb 
for RDX as follows:

MW 25                  4.1 ppb
58 MW 0002          20 ppb
58MW0009E     17 ppb

         Contaminants have also been detected in surface and subsurface 
soils at
at CS-19, including, but not limited to, the following:

         Surface Soils:        
         RDX                                    580 ppb
         HMX                                  2,713 ppb
        diethylphthalate                14,000 ppb
         Hexachlorobenzene             4,600 ppb
         2,4-DNT                                710 ppb
         N-nitrosodiphenylamine           380 ppb
         OCDD                                      3.5 ppb
         dioxin (2,3,7,8-TCDD TEQ)      11.38 pg/g
         DCDF                                      2.9 ppb
         Total HpCDD                           .31 ppb
         MCPP                                 232,000 ppb        
         Aluminum                            26,100 ppm
         Lead                                      1,830 ppm
         Magnesium                           12,200 ppm                      

         Subsurface Soils:

         HMX                                789 ppb
         Hexachlorobenzene        3,500 ppb
         OCDD                               1.9 ppb
         Total HxCDF                       .68 ppb
         Total Hp CDF                     .67 ppb
         DCDF                                3.9 ppb
         Aluminum                        9,050 ppm
         Lead                                1,500 ppm
         Magnesium                       2,100 ppm

Contamination in soils at CS-19 has entered and is likely to continue 
to enter the underlying groundwater.

The soil and groundwater contamination related to CS-19 lie within 
the zone of contribution for Long Range Water Supply 8, a potential 
water supply well site being investigated as a future public drinking 
water well.  

         C.  Southeast Corner of the Ranges:   This area is close to 
the top of the groundwater mound of the Sagamore Lens.   Explosives 
have been detected in wells outside of the Impact Area north of Snake 
Pond close to the J Ranges.  Explosives were disposed on the ground 
surface and into underground holding tanks.  

RDX has been detected in groundwater monitoring wells in the vicinity 
or downgradient of the J Ranges in excess of EPA's Health Advisory of 
2 ppb for RDX as follows:

90WT 013            5.2 ppb
90MW 0022         5.4 ppb
MW-58            7.4 ppb

HMX has been detected in a well installed near the melt-pour facility 
on the J-3 Range at concentrations ranging to 12 ppb.  

Contaminants have also been detected in surface soils at the steel 
lined pit at the J Ranges including the following:

RDX                                24,000 ppb
HMX                                   9,300 ppb
2,4-DNT                               200 ppb
di-n-butylphthalate                  80 ppb
pentachlorophenol                    70 ppb
aluminum                           24,600 ppm
lead                                       616 ppm
magnesium                          2,720 ppm
barium                               1,140 ppm
copper                                2,350 ppm
cadmium                                  33.3 ppm

Contamination in soils at the steel lined pit is likely to enter the 
underlying groundwater. The soil and groundwater contamination 
related to the J Ranges lie within the zone of contribution for Long 
Range Water Supply Wells 95-6 and 95-15, potential water supply well 
sites which are being investigated for future public drinking water 
wells.  This contamination may also lie within the zone of 
contribution for the J Well, a current water supply well for MMR.

D.  Groundwater under and emanating from the Central Impact Area: 
Numerous detections of explosives in groundwater at various depths in 
the aquifer track back to, or originate from, the center of the 
Impact Area.  The Impact Area contains numerous target areas where 
mortar and artillery, including high explosive and white phosphorous 
warheads, were fired over time.

  RDX has been detected in groundwater monitoring wells in the 
vicinity or downgradient of the targets in the Central Impact Area at 
levels in excess of EPA's Health Advisory of 2 ppb for RDX, as 
follows:

MW-107        4.0 ppb                MW-2                13 ppb
MW-23          6.6 ppb                MW-85           29.0 ppb
MW-38          3.0 ppb                MW-86             2.5 ppb
MW-1M2        4.6 ppb                MW-1S             3.1 ppb
MW-90           3.4 ppb                MW-105           5.9 ppb
MW-25           4.1 ppb                MW-91S        12.0 ppb
MW-91M1      18.0 ppb                MW-40           3.0 ppb
MW-37           3.6 ppb                MW-101         2.5 ppb
MW-100         4.3 ppb                MW-99           6.9 ppb
MW-87           6.5 ppb                MW-89           8.3 ppb
MW-93M1        2.2 ppb                MW-98           2.1 ppb
MW-93M2       5.2 ppb                 MW-107         4.0 ppb
MW-88          7.0 ppb                 MW-95           2.2 ppb
        
        
MW-2 and MW-23 are located within the zone of contribution for Long 
Range Water Supply Well 95-6, a potential water supply well site 
being investigated for a future public drinking water well.

RDX at levels below the Health Advisory of 2 ppb has also been 
detected at numerous wells within and downgradient of the Impact 
Area.  

The detection of RDX emanating from the Impact Area at levels below 
and above the Health Advisory indicates that RDX has been introduced 
into the aquifer in the Impact Area, that it is migrating in 
groundwater at concentrations above the Health Advisory level from 
source areas toward potential drinking water supplies, and that it 
has migrated as far as 9,000 feet from its probable source.    

In addition, the following contaminant has been found in surface 
soils in Study Area 2 within the Impact Area, which lies within the 
zone of contribution for Long Range Water Supply Well 95-6, a water 
supply well site which is being investigated for a potential drinking 
water supply well:

1,2-dibromoethane        190 ppb
        
The contamination in soils in Study Area 2 is likely to enter the 
underlying groundwater.

         E.     The KD Range:  The KD Range is located southeast of 
the Impact Area, on Pocasset-Forestdale Road.  Ordnance known to have 
been used at KD Range has included:  all pistol calibers; 5.56 mm and 
7.62 mm ball and tracer rounds; 14.5 mm subcaliber training devices; 
40 mm High Explosive (HE) and practice grenades; Dragon High 
Explosive Anti-tank (HEAT) and practice artillery rockets, 90 mm 
recoilless rifle HEAT and practice rounds, and TOW practice rounds. 
The area was primarily used for rocket training.

The following contaminants, including but not limited to explosives 
and propellants, have been found in surface soil near targets used in 
the KD Range:

RDX                                        43,000 ppb
HMX                                         10,100 ppb
TNT                                           2,100 ppb
2A-4,6-DNT                                   220 ppb
4A-2,6-DNT                                  140 ppb
copper                                        1,820 ppm
lead                                                816 ppm
dieldrin                                         1,800 ppb
nitroglycerin                                6,400 ppb


In profile samples collected during drilling,  2,6-DNT and HMX were 
detected in MW 61M at 10.2 feet below the water table and 20.2 feet 
below the water table, respectively. Consultants for NGB have 
concluded that shallow detections of 2,6-DNT and HMX in MW-61 are 
likely to have originated from the KD Range target area.

In addition, the following contaminant (a constituent of propellants) 
was found in surface soil near the firing position for the KD Range:

                 Nitroglycerin                                130,000 
ppb                        

Contamination in soils at the KD Range  is likely to enter the 
underlying groundwater.  The contaminants in soil at the KD Range are 
within the zone of contribution of current public drinking water 
wells of Bourne, Massachusetts.

F.  J-3 Wetland:  The J-3 Wetland is located south of the J-3 Range 
and north of Snake Pond.  The property on which the J-3 Wetland is 
located was formerly part of the MMR.

The following contaminants, which include propellants and their 
byproducts, as well as the pesticide dieldrin, have been detected in 
sediment samples at the following levels at the J-3 Wetland:

Nitroglycerin                        5,200 ppb
Di-n-butyl phthalate                             37 ppb
N-nitrosodiphenylamine            240 ppb
Dieldrin                                    200 ppb

The NGB has conducted a rapid response action to address 
contamination in soils and sediments at the J-3 Wetland pursuant to 
EPA Administrative Order No. SDWA I-2000-0014.

G.  Gun Positions:  The following contaminants, which include 
propellants, propellant breakdown products, pesticides and metals, 
have been found in soils at the following gun positions:

                 i.  Gun Position 7

2,4-DNT                        1,300 ppb
2,6-DNT                             26 ppb

                 ii.  Gun Position 16

2,4-DNT                            600 ppb

                 iii.  Gun Position 9

2,4-DNT                         17,000 ppb
2,6-DNT                             960 ppb
N-nitrosodiphenylamine       930 ppb
Pentachlorphenol                 180 ppb
Arsenic                                 17 ppb
Di-N-butylthalate              6,000 ppb
        

In addition, contamination, most notably the explosive and propellant
component
2,4-dinitrotoluene, has been found at numerous other gun and mortar 
firing positions. Contamination in soils at these gun positions is 
likely to enter the underlying groundwater.

H.  Armored Personnel Carrier:    The following explosives and 
explosives breakdown products have been found in soil beneath a pile 
of UXO and debris near the Armored Personnel Carrier to the east of 
Turpentine Road in the Impact Area:

         Surface Soils

                 2A46 DNT         230 ppb
                 RDX                1,150 ppb
                 HMX                  150 ppb

         Soils 6-12" below Surface

                 2A46 DNT        155 ppb
                 RDX                  565 ppb
                 HMX                  150 ppb
        
The NGB has conducted a rapid response action to address contaminants 
in soil at the Armored Personnel Carrier pursuant to EPA 
Administrative Order No. SDWA 1-2000-0014.
-- 
Joel Feigenbaum
24 Pond View Drive
E. Sandwich MA 02537
(508)-833-0144


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