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EPA and Mass National Guard Reach Agreement on 2011 Firing Range Training Violation Allegations at Camp Edwards

Release Date: 09/06/2012
Contact Information: David Deegan, (617) 918-1017

(Boston, Mass. – Sept. 6, 2012) – On Aug. 30, 2012, EPA issued a Consent Agreement and Final Order with the Massachusetts National Guard to resolve EPA allegations of violations of operations and maintenance requirements by the Guard in managing three firing ranges at Camp Edwards.

Camp Edwards is located on the northern portion of the Massachusetts Military Reservation (MMR) a 22,000-acre property that has been used for military training activities since 1935. The base is located over an aquifer that is the sole source of drinking water for residents of Cape Cod.

Two environmental cleanup programs (one implemented by the Army, the other by the Air Force) are addressing the areas of soil and groundwater contamination that have resulted from activities on site. The U.S. Air Force is addressing contamination from the Otis Air Force Base primarily in the southern portion of MMR under the Federal Superfund Program. The U.S. Army is addressing contamination at Camp Edwards in the northern portion of MMR as required by EPA under the authority of the Safe Drinking Water Act (SDWA).

In 1997 and 2000, EPA issued to the Guard a series of administrative orders under SDWA to protect the sole source groundwater aquifer underlying MMR.  One of those orders prohibited Guard training with live ammunition to protect the sole source Cape Cod Aquifer.  The Guard had since petitioned EPA to resume small arms training with lead ammunition at three firing ranges, known as J, K and T Ranges.  Following the petitions, EPA consented to the training with particular safeguards, including use of bullet capture systems and compliance with Operation, Maintenance and Monitoring Plans (“OMMPs”) developed for each of the three ranges. 

In 2011, EPA identified that the Guard had not complied with OMMP requirements related to the bullet capture systems at the three firing ranges.  Specifically, the Guard failed to pump and dispose of water that was collecting in the bullet capture systems and also failed to notify EPA of issues associated with water collection and disposal.

Following EPA’s identification of the alleged violations, EPA and the Guard conducted pre-enforcement negotiations and settled on a Safe Drinking Water Act Consent Agreement and Final Order.  The agreement includes a $27,500 cash penalty and the performance of a Supplemental Environmental Project by the Guard that will remove 14 acres of impervious surface at MMR.  The estimated value of the project is just over $100,000.

“This demonstrates EPA’s continuing vigilance to ensure that the environment at the Upper Cape is protected,” said Curt Spalding, regional administrator of EPA’s New England office.  “We are proud of the cleanup successes that EPA, in partnership with Mass DEP, has achieved with the Guard on many projects at MMR.  At the same time, we will not hesitate to take action when necessary to deter future violations that could impact the environment.”

The Supplemental Environmental Project will assist the groundwater underlying MMR, and will enhance protection of state-listed threatened and endangered species.

“EPA’s action  will result in the restoration of 14 acres of sandplain grassland habitat, which is critical for rare plants, moths, butterflies, and birds such as the upland sandpiper, grasshopper sparrow, vesper sparrow, and northern harrier,” said Mary Griffin, Commissioner of the Massachusetts Department of Fish and Game. “We are pleased that the EPA and Massachusetts National Guard have agreed to this important habitat restoration project under the Consent Agreement.”

EPA and the Guard continue to work together on a large number of cleanup actions pursuant to the Safe Drinking Water Act on MMR.

More information:

Additional information on EPA cleanup work at MMR can also be found at (

Regular public meetings are held on or near the MMR with representatives from the EPA, Massachusetts DEP, and the Army and Air Force cleanup programs. (

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