AOC 65 Environmental Cleanup Plan Section 1

Environmental Cleanup Plan for AOC 65

Section 1 - Introduction

The objective of this project is to address the groundwater contamination at Area of Concern (AOC) 65 located at Camp Stanley Storage Activity (CSSA), Boerne, Texas. Additionally, the project aims to evaluate the use of soil vapor extraction as a remedial alternative and investigate subsurface features that affect contaminant migration in groundwater. This Environmental Cleanup Plan describes the interim corrective measures and the environmental studies and investigations to be performed.

Parsons intends to achieve these objectives by executing a removal action of contaminated media underlying Building 90 and from areas surrounding the suspected contaminant source area(s). Parsons will install soil vapor extraction wells and vapor monitoring points to conduct a soil vapor extraction treatability study. A surface geophysical study will be implemented to identify probable fractures in the upper formation to assist in the selection of well placement. Following completion of the treatability study, Parsons will prepare an evaluation of soil vapor extraction and bioremediation system to remediate volatile organic contamination remaining in vadose soils and fractured media, and will assess other potential technologies that may be applicable to enhancing remediation.

1.2 - Scope of Work

The scope of work as detailed in the task order authorizing this project includes:

	Preparation of project and/or site specific addenda to the planning documents to be incorporated into CSSA’s Environmental Encyclopedia.
	Development of a Quality Program Plan, which consists of a Work Plan addendum to conduct site activities and analysis (CDRL A014), a project-specific addendum to the Health and Safety Plan (CDRL A017), and a project-specific addendum to the Sampling and Analysis Plan (CDRL A018).
	Providing support for the environmental management and geographical information systems; all data will be collected and recorded in a format compatible with CSSA’s GIS.
	Submitting all analytical data, including quality control results and cross-reference tables. Raw data, case narratives, AFCEE forms, data verification, data validation summary reports, a copy of approved project variances, and a listing of the project data quality objectives will also be provided.
	Performing treatability studies to determine optimum methods of contaminant delineation and/or removal, and the degree of treatment anticipated using various processes. This task includes completion of a treatability study of soil vapor extraction, implementation of the selected treatment technology, sampling and analysis of soil and water samples to support the treatability study and interim actions, and conducting removal of contaminated media from beneath and around Building 90 as an interim measure.
	Evaluating the cost, performance, and applicability of methods and technologies for the project. Recommendations will consider cost, schedule, protection of human health and the environment, public acceptance, and technical risk.
	Preparing photo documentation of field activities and sample locations.
	Submittal of deliverables to AFCEE and the submittal of individual ERPIMS data files (e.g., analytical results, groundwater level data, etc.).

1.3 - Data Quality Objectives

The overall data quality goal for this project is to gather sufficient information to guide the selection of remedial alternatives and interim corrective measures. Data quality is defined by its representativeness, precision, comparability, and completeness. Representativeness of the data is dependent on site selection and the number of samples taken, which are easily addressed in the sampling plan design. The requirements for precision, comparability, and completeness of the data vary between data types but all are enhanced by the use of standardized sampling and analysis protocols and standardized reporting procedures. DQOs are dynamic documents that are continually being updated as the project progresses and data is generated. The most current DQOs are presented in Appendix A. Detailed information on sampling techniques are given in the Draft AOC 65 Treatability Study Sampling and Analysis Plan Addendum, Parsons, February 2002.

The types of data to be collected for this project are listed below, along with a discussion of their uses and requirements.

	Geophysical data – Electrical resistivity, ground penetrating radar, gravity, electromagnetic, seismic, and other geophysical surveys will be conducted to identify subsurface features that might influence groundwater and contaminant movement. Data will be validated or “ground-truthed” by soil borings, cores obtained during the installation of piezometers and vapor extraction wells planned for the AOC 65 area. Requirements for the geophysical surveys are presented in the TO 58 DQOs included in Appendix A.
	Soil borings – Soil samples will be collected from the borings advanced in and around Building 90 for the purpose of delineating the extent of contaminated material that might need to be excavated during the removal action and to profile the waste for disposal. The requirements for soil samples are included in the TO 58 DQOs included in Appendix A.
	Soil gas – Soil gas samples will be collected during the SVE treatability study testing and the extraction packer test. Samples will be collected to provide “point in time” data to establish baseline conditions, evaluate zones with the highest levels of contamination, and determine zones where the greatest removal rates are anticipated. The DQO requirements for the soil gas samples are presented in the TO 58 DQOs in Appendix A.
	Groundwater characterization – Groundwater samples will be collected from the VEWs, piezometers, and existing shallow wells to evaluate the migration of VOCs in groundwater through subsurface fracture networks; natural attenuation parameters will also be measured. DQO requirements for groundwater samples are included in the TO 58 DQOs in Appendix A.
	Air Emissions – Air emissions samples will be collected from the blowers attached to the subslab ventilation and SVE systems to validate the calculations made in support of the standard exemptions and to assess VOC removal rates. The requirements for the air emission sampling are included in the TO 58 DQOs in Appendix A.
	Ambient air monitoring – During the removal action inside Building 90, the ambient air quality will be monitored to ensure the health and safety of workers and CSSA personnel. Requirements for the ambient air monitoring sampling are included in the TO 58 DQOs in Appendix A.
	Investigation derived waste characterization – Liquid from the blowers’ moisture separators and from groundwater wells needs to be characterized to determine applicable disposal requirements and appropriate waste handling procedures. Requirements for liquid waste characterization are included in the TO 58 DQOs in Appendix A.
	Field measurements – Numerous data will be collected in the field including, but not limited to, groundwater levels in wells and piezometers, rain gauge levels, dissolved oxygen in water, oxygen, carbon dioxide, and TVH in soil gas, SVE flow rates, pressure response of VMPs, and soil temperature. As most of these data are for screening purposes only, the use of standardized techniques and properly calibrated and maintained equipment will ensure that the data are of sufficient quality to be used for the intended purpose of screening. Requirements for these field measurements are included in the TO 58 DQOs in Appendix A.

1.4 - Electronic Data Management

Field data collected during the course of the project will be stored and submitted to CSSA in electronic format. The purpose of the electronic data management program is to provide a method through which field information and data can be stored, reviewed, and managed in electronic format. The electronic files will be incorporated into a database specifically designed to manage anticipated field data collected on a daily basis. The electronic files will be generated by scanning field logbooks, inputting field measurements into an electronic field notebook, and recording data with dataloggers or geophysical equipment. All field personnel involved in data collection activities will be required to undergo training in the electronic field data management techniques that will be used under this delivery order.

1.4.1 Field Logbooks

Field logbooks will be used to record daily field activities and field observations. Daily entries into the logbook may include work hours, field personnel, weather information, sampling times, and observations. Logbook entries will be handwritten using permanent ink. A new page will be started each day of field activities and entries will continue onto successive pages as necessary. At the end of each day, the field team leader will sign the field logbook and unused portions of the last page will be marked through to prevent further entries.

At the end of each day in the field, the team leader will electronically scan that day’s entry into the field logbook. The pages will be scanned to create a graphics format electronic file (JPEG or similar) using the electronic scanner in the CSSA environmental office. The hard copy of the field notes will be stored in Parsons field and project files. The scanned electronic file will be stored in an MS Access database accessible through CSSA’s computer network and the Parsons computer network. This database application is referred to as the Customized Hybrid Environmental Restoration program (CHERP).

1.4.2 Electronic Data Field Storage Notebook

An electronic field notebook will be used by field team members to record field measurements that do not require validation. Field screening measurements may include items such as groundwater levels, field TVH readings, airflow measurements, etc. Field collected data requiring validation (e.g. results of soil and groundwater analytical data) will not be a part of the field-screening database. However, data regarding the collection of samples submitted for analyses (e.g., Chain-of-Custody) will be collected as part of the electronic data management efforts.

Specific data-entry forms will be created to facilitate entry of the screening field data into the notebook. An entry form will be developed for the notebook to facilitate entering various field measurements that might be collected during the project. At a minimum, notebook entry forms will be created for the following field measurements:

	Groundwater elevation;
	Groundwater sampling parameters (temperature, pH, and conductivity);
	Groundwater purge volumes;
	Field air monitoring readings (TVH, oxygen);
	SVE air-flow; and
	Microgravity and other geophysical measurements.

At the end of each day of field measurements, the field screening data will be downloaded to a database established in the computer network at the CSSA environmental office. Hard copies of the field measurements will be stored in Parsons field and project files.

1.4.3 Dataloggers/Geophysical Instrumentation

Management of data collected by specific instrumentation with datalogging capabilities, such as from the weather station datalogger and geophysical equipment, will be stored within the internal memory of the instrument until it can be downloaded to a computer. Electronic file formats for the downloaded data will be determined by the format generated with each instrument. Data will be downloaded into the database at the end of each day, at the end of a profile for geophysical surveys requiring multiple days, or at pre-established intervals for longer measurement events.

1.4.4 CHERP Database Application

The CHERP’s database application is currently designed to generate COCs and labels for collection of samples submitted for laboratory analyses. The database ensures that all required information for delivery of ERPIMS data is entered. The field screening data collected on a daily basis will be incorporated with the daily logs to provide efficient and expedient review of data. The electronic database application is set up to allow synchronization between networks at CSSA and Parsons. This will allow review and observations of daily field activities by CSSA and Parsons managers.

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