Current Conditions Report

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Description of Current Conditions Report
July 1999

Background

Detailed CSSA background information can be found in the Background Information Report. A brief environmental background summary for CSSA is provided below.

On May 5, 1999, the EPA issued the Camp Stanley Administrative Order on Consent. This consent order, proceeding under Section 3008(h) of RCRA, was the result of several findings of fact. A brief overview of the Order findings is discussed here. CSSA was defined as a generator, storer, and transporter of corrosive hazardous waste in the Notification of Hazardous Waste Activities that was submitted to the EPA on September 18, 1980. On November 19, 1980, CSSA submitted Part A of its permit application and identified that, at that time, it treated, stored, or disposed of hazardous wastes by operation of a surface impoundment and tank storage for hazardous waste exhibiting characteristics of reactivity and from non-specific sources.

There are a total of twelve groundwater wells at CSSA. Groundwater well locations are shown in the Site Location Map. These wells are used as potable drinking water sources, for agricultural water supplies, as groundwater monitoring wells, or a combination of these uses. Laboratory analyses of groundwater samples collected during a routine Texas Department of Health (TDH) pesticide screening on August 9, 1991 identified 127 u g/L DCE, 151 u g/L TCE and 137 u g/L PCE in water supply well 16. On August 23, 1991, these results were confirmed, and well 16 was taken out of service. On December 4, 1991, the Texas Water Commission, now TNRCC, collected samples from wells 4, 16, and D. TCE and PCE were detected in well 16, and DCE was detected in well D.

Ten wells were sampled in November 1992. Results indicated wells 2, 3 and 4 were not contaminated with DCE and TCE. Wells 16 and D contained up to 53 u g/L of VOCs (above drinking water standards). The five other wells did not contain halogenated compounds. The potential sources of the hazardous waste constituents are believed to be the oxidation pond (SWMU O-1) and Burn Area 3 (Technical Memorandum on Soil Boring Investigation, Well 16 Source Characterization, Parsons ES, June 1995).

Pursuant to RCRA, and the release of hazardous waste or constituents into the environment at the Camp Stanley facility, CSSA was ordered to perform the actions included in the Order, and comply with all requests and dates of submittal listed in the Order.

This DCC Report is one of the submittals requested by the EPA in the Order. It has been prepared in accordance with the requirements set forth in the Corrective Action Plan (CAP), as specified in the Order. This DCC Report is to be submitted to the EPA within 90 days of the effective date of the order, and will be approved, or modified and approved, by the EPA. In the 3008(H) Order, the scope of work for the RCRA Facility Investigation (RFI) specifies the information that should be included in this DCC Report. These items are listed in the following table; each item is hyperlinked to the appropriate portion of the encyclopedia.

3008(H) Order Requirement	Environmental Encyclopedia Reference
Facility Background
Summary of regional location	Volume 1-1, Background Information Report, Installation Description and History
Pertinent boundary features	Volume 1-1, Background Information Report, Installation Description and History
Facility physiography	Volume 1-1, Background Information Report, Physiography
Hydrogeology	Volume 1-1, Background Information Report, Groundwater Resources
Historical use of Facility for treatment, storage, or disposal of solid and hazardous waste	Volume 1-1, Background Information Report, Installation Description and History
Maps depicting:
General geographic location	Volume 1-1, Background Information Report, Figure 1 and Figure 2
Property lines, with the owners of all adjacent property clearly delineated	Volume 1-1, Background Information Report, *Figure 12* In addition, property owner information will be updated as part of Community Relations activities planned for late 1999. Link to Community Relations Plan.
Topography, showing waterways, wetlands, floodplains, surface water features, and drainage patterns	Volume 1-1, Background Information Report, *Figure 4*
All tanks, past or present, buildings, utilities, paved areas, easements, rights-of-way, and other features	All underground storage tanks (USTs) have been removed in accordance with TNRCC requirements. Former locations are shown on figures in attachment 1. Buildings and roads are also shown in the Site Location Map. Locations of utilities will be field verified and added to CSSA’s GIS in late 1999. A list of the tanks, when they were installed, and when they were removed is also provided in attachment 1.
All solid or hazardous waste, treatment, storage or disposal areas active after November 19, 1980	The three following SWMUs may have been active after November 19, 1980: *F-14, O-1*, and B-20.
All known past solid or hazardous waste treatment, storage, or disposal areas regardless of whether they were active on November 19, 1980	All known areas are described in this DCC Report, and locations are shown on the Site Location Map.
All known past and present underground product and waste tanks and piping	All USTs and associated piping have been removed in accordance with TNRCC requirements. Former locations are shown on figures included in attachment 1 at the end of this DCC Report.
Surrounding land uses (residential, commercial, agricultural, recreational)	Volume 1-1, Background Information Report, Figure 12 In addition, land use information will be updated as part of the *risk assessment technical approach* in late 1999.
The location of all production and groundwater monitoring wells. These wells shall be clearly labeled with ground and top of casing elevations included.	Volume 5, Groundwater Monitoring. Ground and top of casing elevations are provided in Table 1 of the January 1997 Groundwater Monitoring Report.
The location of all wastewater and storm water outfalls used by the Facility.	Volume 1-1, Background Information Report, Figure 9
History and description of ownership and operation, solid and hazardous waste generation, treatment, storage, and disposal activities at the Facility.	Volume 1-2 and Volume 1-3
Approximate dates or periods of all known past product and waste spills, identification of the materials spilled, the amount spilled, the location where spilled, and a description of the response actions conducted (local, State, or Federal response units or private parties), including copies of all inspection reports and technical reports generated as a result of the response.	Aside from the SWMUs documented in this encyclopedia (Volume 3-1 and Volume 3-2), there have been no known releases to the environment.
A summary of past permits requested and/or received, any State or Federal environmental enforcement actions taken against the Facility, the resolution thereof, and a list of environmental studies performed for the Facility.	CSSA currently has a NPDES permit and an air permit. The only enforcement action taken against CSSA is the 3008(H) Order. A list of environmental studies performed for the facility is included in Volume 1-1, Bibliography.
Nature and Extent of Contamination
Summary of all possible sources areas of contamination	A summary of all known possible source areas of contamination, including SWMUs, AOCs, and RMUs, is provided in this DCC.
Location of unit/area (depicted on a Facility map)	Volume 1-1, Site Location Map
Quantities of solid and hazardous wastes in the area	Volume 1-2 and Volume 1-3
Hazardous waste or constituents, to the extent known, in the area	Volume 1-2 and Volume 1-3
Identification of areas where additional information is necessary	Volume 1-2 and Volume 1-3
Available monitoring data and qualitative information on locations and levels of contamination at the Facility.	Volume 1-2 and Volume 1-3
All potential migration pathways, including information on geology, pedology, hydrogeology, physiography, hydrology, water quality, meteorology, and air quality.	Volume 1-1, Background Information Report. In addition, an evaluation of potential pathways will be initiated in detail in late 1999 as part of the *Risk Assessment Technical Approac*h.

Potential impacts on human health and the environment, including demography, groundwater and surface water use, and land use.	Volume 1-1, Background Information Report, includes information on demography, groundwater and surface water use, and land use. In addition, a Risk Assessment Technical Approach will be initiated in late 1999 to further evaluate potential for impact to human health and the environment.
Pre-Investigation Evaluation of Corrective Measures Technologies
Identification of site criteria that may influence selection of corrective measure technologies	Volume 4, Electrokinetics Report
Field, laboratory, bench or pilot scale data that need to be collected in the facility investigation to facilitate the evaluation and selection of the final corrective measure or measures (e.g., compatibility of waste and construction materials, information to evaluate effectiveness, treatability of wastes, etc.)	Treatability studies are currently planned for soil piles at B-8, B-20, B-24, B-28, and DD. Information regarding these planned studies will be included in the Interim Measures Work Plan. It is currently anticipated that the results of the treatability studies will be applied to other sites at CSSA with similar types of contamination.