[Table of Contents]

Environmental Assessment

Section 3 - Affected Environment

3.1  Soils and Geology

3.1.1  Soils

Generally, soils at CSSA are thin, dark-colored, gravelly clays and loams.  The soil types are strongly influenced by topography and the underlying limestone.  All soil classifications used for this report are taken from the USDA Soil Conservation Service (SCS) soil survey series for Bexar County, Texas (1966).  Figure 4 shows the soil types occurring at CSSA.

The Brackett soils range over a large portion of CSSA.  These soils are on slopes of 12 to 30 percent, such as those found on Steele, McFarland, and Schasse Hills, as well as Taylor Ridge.  These loamy and clayey soils are very shallow (about 4 inches thick), grayish-brown, and strongly calcareous.  Laying within and on the surface layer are gravel and cobblestones.  The soils develop over soft limestone and are underlain by hard limestone, which gives the slopes a stairstep appearance.  The hills associated with Brackett soils are steep, cone-shaped hills with saddles between them.  The soils are nonarable and best suited to native grasses.

Brackett-Tarrant association soils are formed on hills with 8 to 30 percent slopes.  This soil type is found north of the inner cantonment.  The slopes of ridges are Tarrant soils located just above Brackett soils.  The Brackett soils of the Brackett-Tarrant association are grayish-brown, gravelly clay loam.

The Tarrant soils are shallow and form over hard, fractured limestone.  The surface layer is usually about 10 inches thick and is a dark grayish-brown, calcareous, clay loam with scattered gravel, cobblestones, and flagstones within the surface layer and on it.  Two types of Tarrant soils are at CSSA:  Tarrant association, gently undulating, and Tarrant association, rolling.  Tarrant association, gently undulating, occurs as nearly level and gently sloping areas of typical prairie and plateau topography.  It occurs primarily in areas not occupied by streams, such as the north-central area of the inner cantonment, as well as the west side of Steele and Wells Hills and the hills north of the inner cantonment.  The soils are dark colored, very shallow, calcareous, and clayey and are best suited for native grasses and range use.

Tarrant association, rolling, is found on the eastern sides of Anderson and Schasse Hills in areas not occupied by streambeds.  The slopes tend to have a gradient of 5 to 15 percent.  The soils are dark colored, very shallow, clayey, weakly calcareous, and typically more stoney than Tarrant association, gently undulating.

Except in stream beds and associated floodplains, the Crawford and Bexar stoney soils occupy the majority of the land not previously mentioned.  They occur as broad, nearly level to gently undulating areas with slopes of 0 to 5 percent.  The Crawford soils make up a majority of this type at CSSA.  The soils are stony, very dark gray to dark reddish brown, noncalcareous clay, about 8 inches thick.  Bexar soils range from cherty clay loam to gravelly loam.  The soils are nonarable and suited for native grass, such as Texas winter grass, little bluestem, sideoats grama, and buffalo grass.

Two soil units are found in the streambeds and floodplains of Salado Creek and other small tributaries.  They are the Krum Complex and the Trinity and Frio soils, frequently flooded.  The Trinity and Frio soils, frequently flooded, are the main channel soils for Salado Creek and a large tributary that joins the creek in southwestern CSSA.  The soils occur as narrow, long, and irregularly shaped areas.  They are flooded at least once a year after heavy rains.  Some areas are subject to thin sediment depositions, while other areas are scoured.  Channels are poorly defined and are of small capacity.  Trinity soils make up the majority of this soil type and are 3 to 5 feet deep, clayey to gravelly loam.  Frio soils are 3 to 4 feet deep, dark grayish-brown clay loam.  The soils are generally used as pasture, with occasional cultivation.  vegetation may consist of elm, hackberry, oak, mesquite, and other thorny shrubs, and of Texas wintergrass, Johnson grass, buffalo grass, Bermuda grass, and annual weeds.  Small grains, vegetables, and hay are the main crops that these soils can support.

The Krum Complex soils make up the remaining soils covering the streambeds and floodplains.  The surface soil is dark grayish-brown or very dark grayish-brown, calcareous, and approximately 30 inches thick.  The soils developed from slope alluvium of the limestone prairies.  The Krum Complex soils are on slopes between 2 and 5 percent and occupy "foot" slopes below Tarrant and Brackett soils.  The Krum soils receive sediments and runoff from higher elevation soils and are highly prone to water erosion if unprotected.

A minor soil type found at CSSA is the Lewisville silty clay on slopes of 1 to 3 percent.  It typically occupies long, narrow, sloping areas separating nearly level terraces from upland soils.  It can be found in small areas south of Dietz Elkhorn Road and north of the inner cantonment boundary around Moyer Road.  Surface soils are dark grayish-brown and about 20 inches thick.  This is a highly productive soil but is also susceptible to water erosion if unprotected.

3.1.2  Physiography

CSSA is characterized by a rolling terrain of hills and valleys in which nearly flat-lying limestone formations have been eroded and dissected by streams draining to the east and southeast.  Normal faulting has occurred near the southeastern boundary of the installation, and regionally two major trends of fractures extend across the region northwest-southeast and northeast-southwest.  Faulting in the limestone units has juxtaposed strata of different ages, but fault scarps and traces are almost absent because of similar calcareous lithologies.  The faults are northeast-southwest trending, but most are not as continuous as the fractures.  Soil cover is relatively thin, and bedrock is exposed in most areas other than stream valleys.

River and stream dissection of limestone id the major surface feature at CSSA.  Most major rivers and streams originating in the Edwards Plateau to the northwest of CSSA tend to follow the northwest-southeast regional fracture patterns.  Resistive limestone beds crop out as topographic highs, but none of these beds form buttes or mesas.  Rather, the predominant physiography is hills and "saddles" which lead to stream valleys.  Topographic relief across the area ranges from about 1,100 feet to 1,500 feet above mean sea level.

Sinkholes and caverns are present on the surface and in the subsurface, primarily in areas where porous and fractured limestone formations are exposed.  The sinkholes and carves results from solution of limestone and gypsum by infiltrating surface water.  Commonly, fractures are also enlarged by moving groundwater which permits the enhancement of secondary porosity and permeability.  Fractures, fault scarps, and karstic low-lying areas can be recognized on aerial photographs.

3.1.3  Geology

Information is summarized from the following:  TDWR, report 273, Ashworth, 1983; Hydrogeology of the Lower Glen Rose Aquifer, Hammond, 1984; and Hydrogeology of the Camp Bullis Area , Wattereus, 1992.

Stratigraphy.  The oldest and deepest known rocks in the study area are of Paleozoic age (225 to 570 million years ago).  They underlie the predominant carbonate lithology of the Edwards Plateau.  The Cretaceous-age sediments were deposited as onlapping sequences on a submerged marine plain, and, according to well logs and outcrops observations, these sediments thicken to the southeast.  They represent Trinity Group Travis Peak Formation shallow marine deposits.

The Travis Peak Formation attains a maximum thickness of about 940 feet and is divided into five members, in ascending order:  the Hosston Sand, the Sligo Limestone, the Hammett Shale, the Cow Creek Limestone, and the Hensell Sand.  The Hosston Sand is generally composed of conglomerate, sandstone, and claystone, becoming incresingly more dolomitic and shaley downdip to the southeast.  The Sligo Limestone exists downdip where the Hosston grades into a sandy limestone.  Overlying the Sligo is the Hammett Shale, which has an average thickness of 60 feet.  It is composed of dark blue to gray fossiliferous, calcareous, and dolomitic shale.  It pinches out north of the study area and attains a maximum thickness of 80 feet to the south.

Above the Hammett Shale is the Cow Creek Limestone.  It is a massive fossiliferous, white to gray, shaley to dolomitic limestone that attains a maximum thickness of 90 feet downdip in the area.  At CSSA, it averages about 80 feet in thickness.

The youngest member of the Travis Peak Formation is the Hensell Sand, locally known as the Bexar Shale.  The shale thickness averages from 80 to 150 feet.  It is composed of silty dolomite, marl, calcareous shale, and shaley limestone, and thins by interfingering into the Glen Rose Formation.

The Glen Rose Formation of the Trinity Group was deposited over the Travis Peak Bexar Shale and represents a thick sequence of shallow water marine shelf deposits.  This formation is divided into upper and lower members.  At CSSA, the Glen Rose is exposed at the surface and as alluvium in stream valleys.  Figure 5 shows the outcrop locations of the Glen Rose members at CSSA and the surrounding area.  In particular, the lower Glen Rose is exposed around Cibolo Creek and also southwest of the installation.

In Bexar County, the lower Glen Rose member is approximately 300 feet thick and consists primarily of massive bedded limestone with few layers of marl and marly limestone.  The upper member is approximately 500 feet thick and consists primarily of resistive and nonresistive beds of limestone and marly limestone.  At CSSA, the bed ranges from approximately 10 to 150 feet thick as it thins to the north.  A distinct stratigraphic marker bed known as teh "Corbula bed" (a bed of small clamshells 3 to 5 millimeters in diameter) is the dividing boundary between the upper and lower Glen Rose members.  In addition, evaporite beds are present in the upper member.  The depth of the second (deeper) evaporite beds is close to that of the Corbula bed, allowing the contact between upper and lower members to be found on subsurface geophysical logs.

Fredricksburg Group sediments, including the Edwards Formation, overlie the Glen Rose Formation in many areas as erosional remnants cropping out as topographic highs.  For this report, the Fredricksburg Group limestones will not be discussed because of the lack of outcrop in the immediate vicinity of CSSA.

Structure.  The predominant structural features are regional vertical fractures, the regional dip, and the Balcones fault zone (escarpment).  The regional fractures are the result of faulting in the Cretaceous sediments and in the deeper Paleozoic rocks.  The two sets of fracture patterns trend northwest-southeast and northeast-southwest across the region.  The regional dip of the formations is to the east and southeast at a rate of about 100 feet per mile near the fault zone in Bexar and Comal Counties, but decreases to 10 to 15 feet per mile northwest of CSSA.

The Balcones fault zone is a series of high-angle normal faults that generally trend northeast and southwest.  Total displacement in northwest Bexar County is approximately 1,200 feet.  The faulting is a result of structural weakness in the underlying Paleozoic rocks and subsidence in the Gulf of Mexico basin to the southeast.  The downdrop blocks outcrop as younger strata from northwest to southeast across the fault zone.  In addition to major faulting along the Balcones fault zone, numerous minor northwest-southeast-trending faults also occur.  These faults are laterally discontinuous and their displacement is small.

3.2  Water Resources

3.2.1  Surface Water Hydrology

Drainage from CSSA flows in a generally southerly direction into Salado Creek and Leon Creek, with a portion in the northeast draining into Cibolo Creek to the north (Figure 5).  Approximately 75 percent of CSSA is in the Salado Creek watershed, 15 percent in the Cibolo Creek watershed, and 10 percent in the Leon Creek watershed, including the wastewater treatment plant, which drains into a tributary of Leon Creek at the south boundary.  All of these streams are intermittent on CSSA.  The CSSA area can be characterized as hilly with stony soils and high runoff potential.  natural stream channels on CSSA generally have broad floodplains, and portions of CSSA are in the 100-year floodplain.

The Salado Creek watershed on CSSA extends in a broad swath from northwest to southeast with the Salado Creek headwaters located in adjacent Fair Oaks subdivision.  Impervious cover in Fair Oaks is currently estimated at 5 to 10 percent.  Drainage from Camp Bullis to the east also flows across CSSA to Salado Creek.  Impervious vover for CSSA within the Salado Creek watershed is substantially less than 5 percent, with much of the area undeveloped except for dirt and gravel roads.

As shown in Figure 6, there are four ponds within the Salado Creek drainage area of CSSA.  Reservoir D is in the inner cantonment near the western boundary; three additional stock ponds are located in the outer cantonment.  When it is full, reservoir D has a surface area of approximately 5 acres.  It is located on a tributary of Salado Creek.  The first stock pond is located on the main channel of Salado Creek in the northwest quarter of the outer cantonment and has a surface area of approximately one acre.  The second stock pond is located along the eastern boundary of the outer cantonment and also has a surface area of approximately one acre.  The third stock pond is located on the side of a hill just east of the northern boundary of the inner cantonment and has a surface area of approximately 1/5 acre.  All of the dams exceed 6 feet in height.

Three tributaries of Cibolo Creek originating on CSSA drain the northeastern part of the outer cantonment.  One stock pond with a surface area of less than one acre is located on the easternmost tributary.  The dam exceeds 6 feet in height.  The area of the Cibolo Creek watershed within CSSA is undeveloped except for dirt and gravel roads.  Impervious cover in the Cibolo Creek watershed is minimal.

A tributary of Leon Creek originating on CSSA drains the southwest quarter of the inner cantonment.  Reservoir W, in the southwest corner of the inner cantonment, is situated on a tributary of this tributary and has a surface area of approximately one acre and a dam exceeding 6 feet in height.  Overall, impervious cover within the Leon Creek portion of CSSA is estimated at approximately 5 percent or less, much of which is located along Tompkins Road and McElroy Drive.

In the developed areas of CSSA, rainfall runoff is conveyed to natural stream flow channels by ditches and sheet flow.  CSSA has sufficient relief to allow the rapid conveyance of runoff from developed areas.  In the undeveloped areas, runoff flows overland to natural channels.

3.2.2.  Surface Water Quality

Salado Creek, from its confluence with the San Antonio River in Bexar County to Rocking Horse Land west of Camp Bullis, is designated water quality segment 1910 of the San Antonio River basin by the Texas Water Commission (TWC).  According to The State of Texas Water Quality Inventory (TWC, 1992), segment 1910 does not meet its contact recreation use because elevate fecal coliform bacteria levels caused by urban runoff from the city of San Antonio for approximately 25 miles of its length.  This document did not indicate what portion of the 44-mile segment did not meet criteria for contact recreation use, but it appears to refer to that portion of the segment which receives runoff from San Antonio downstream of CSSA.  Designated uses for segment 1910 are contact recreation, high-quality aquatic habitat, public water supply, and aquifer protection.  There are nine wastewater outfalls permitted to discharge a total of 0.44 million gallons per day (mgd) to this segment (TWC, 1992).

A portion of CSSA in the northeast part of the outer cantonment drains into upper Cibolo Creek, which has been designated water quality segment 1908 of the San Antonio River basin.  Segment 1908 extends from the Missouri-Pacific Railroad bridge west of the city of Braken in Comal County to a point 1.5 kilometers upstream of the confluence with Champee Springs in Kendall County.  Monitoring data from TWC have shown the following:  elevated nutrient levels exist downstream from the city of Boerne; supersaturated dissolved oxygen levels occur from algal metabolism; and chloride, sulfate, and total dissolved solid levels outside criteria have occurred.  The city of Boerne is upstream from the locations at which runoff from CSSA enters Cibolo Creek.  Designated uses for segment 1908 are contact recreation, high-quality aquatic habitat, public water supply, and aquifer protection.  Four outfalls are permitted to discharge a total of 1.25 mgd to this segment (TWC, 1992).

The southwest quarter of the inner cantonment drains into a tributary of Leon Creek, and effluent from the wastewater treatment plant drains into this tributary.  The upper portion of Leon Creek into which CSSA drains is designated water quality segment 1907.  Segment 1907 extends from a point 100 meters upstream of State Highway 16 northwest of San Antonio in Bexar County to a point 9.0 kilometers upstream of Scenic Loop Road north of the city of Helotes in Bexar County.  There are no water quality problems noted in this segment.  Designated uses for segment 1907 are contact recreation, high-quality aquatic habitat, public water supply, and aquifer protection (TWC, 1992).

There are no uses of surface water on CSSA aside from the maintenance of water in the stock ponds.

3.2.3  Groundwater Hydrology

Groundwater occurrence and movement at CSSA were investigated as part of a separate ES project for the US Air Force Armstrong Laboratory (AL/OEB) and CSSA.  The results of a preliminary evaluation of groundwater contamination were submitted to AL/OEB and CSSA as a report entitled "Hydrogeologic Report for Evaluation of Groundwater Contamination at Camp Stanley Storage Activity, Texas" (ES, 1993).  This section summarizes information generated during that project and discussed in the report.

There are three aquifers in the area of CSSA: the upper, the middle, and the lower Trinity aquifers.  Beneath these are metamorphosed Paleozoic rocks, which act as a lower hydrologic barrier because they lack adequate permeability.  These water-bearing formations consist of the Travis Peak Formation and the Glen Rose Formation.  The formations are grouped based on different hydraulic continuities.

Lower Trinity aquifer.  The lower Trinity aquifer is made up of the Hosston Sand and the Sligo Limestone of the Travis Peak Formation.  These strata do not outcrop in the study area.  The Hosston and the Sligo thicken in a downdip diection (south and southeast) to as much as 500 combined feet near the Balcones fault zone.  At CSSA, they have an average combined thickness of 370 feet.  The lower boundary of the lower Trinity aquifer are Paleozoic basement rocks.

The lower Trinity aquifer derives its recharge from the overlying Hensell Sand (Bexar Shale) in the updip direction, where the overlying Hammett Shale and Cow reek Limestone is thin or absent.  Some recharge may come from leakage of overlying strata in areas where the Hammett Shale is disrupted by faulting.  Groundwater in the lower Trinity aquifer is under artesian conditions because the Hammett Shale acts as a confining bed overlying the water-producing formations.  The average coefficient of transmissivity in the lower Trinity aquifer is about 10,000 gallons per day per foot (gpd/ft) (Ashworth, 1983).  Groundwater movement is generally to the south and southeast except in areas of continuous pumpage, where flow is toward these discharge points.  Discharge from the lower Trinity aquifer occurs primarily by pumpage from wells.

At CSSA, the lower Trinity aquifer is not used because of its low production and the high cost of well completion.

Middle Trinity aquifer.  The middle Trinity aquifer consists of the Cow Creek Limestone, the Bexar Shale (Hensell Sand), and the lower Glen Rose Limestone.  The combined average thickness of the aquifer members is approximately 460 feet.  The only member found in outcrop is the lower Glen Rose, which is north of CSSA along Cibolo Creek and southwest of CSSA (Figure 5).

The lower Glen Rose portion of the middle Trinity aquifer derives its recharge from direct precipitation on the outcrop and stream flow losses crossing the outcrop.  A prime example of stream flow losses has been observed in the channel of Cibolo Creek between the towns of Boerne and Bulverde, where the entire stream flow is diverted underground through sinkholes except during flood stages.  This is the only area of lower Glen Rose that is considered to be part of the recharge zone for the Edwards aquifer (Edwards, 1987).

In the area of CSSA, Bexar Shale acts as a hydrologic barrier to vertical leakage except where faulted; therefore, most recharge to the Cow Creek Limestone comes from overlying formations in the updip areas.  No wells in the area are known to have been completed only in the Cow Creek, and thus the Cow Creek is presumed to be in natural hydraulic communication with the lower Glen Rose.  A number of wells are reported as completed in both the Cow Creek and the lower Glen Rose, allowing artificial hydraulic communication between these aquifer members.  The middle Trinity aquifer appears to be under water table conditions (unconfined) in the CSSA area.

The average coefficient of transmissivity in the middle Trinity aquifer (the Cow Creek and lower Glen Rose limestones) is 1,700 gpd/ft.  Movement of groundwater is towards the south and southeast.  In areas of heavy pumpage, groundwater flows towards discharge points.  Flow velocities calculated by carbon 14 analysis indicate a regional flow that ranges from 13.6 to 15.9 feet per year (Hammond, 1984).  Middle Trinity discharge occurs both artificially by pumpage from wells and naturally by springs and seeps.  Groundwater geochemistry is primarily of the calcium magnesium bicarbonate type, with total dissolved solids (TDS) content usually less than 500 milligrams per liter (mg/l) (Ashworth, 1983).

the primary source of water in the wells at CSSA is the middle Trinity aquifer, the most prolific producer with the best quality of water of the three Trinity aquifers.  These wells are completed as open holes without well screens.  To maximize yield, wells completed in the middle Trinity are also open to the upper Trinity aquifer.

There are nineteen water wells known at CSSA (Figure 5).  These wells have produced water for drinking, livestock, agricultural, and industrial uses, with the majority of the wells now inactive.  Identifications for the wells are alphabetic or numeric designations.  Five wells are located in the north pastures (wells E, F, G, H, and I); eight wells are located along the northern boundary of the inner cantonment lands (wells A, B, C, D, 2, 3, 4, and 16); three wells are in the housing area (wells 9, 10 , and 11); two wells are in the southern area (wells 5 and 6); and one well used by CSSA is located southeast of CSSA on Camp Bullis (well 1).

Groundwater movement at CSSA in the middle Trinity aquifer was defined using October 1992 water well data (ES, 1993).  groundwater elevations were calculated from measured depths to static water levels in the nineteen water wells.  Figure 7 is the resulting groundwater potentiometric map.  The groundwater elevation contours were estimated, as it was unknown how much input to each well came from the middle or upper Trinity aquifers.  Groundwater flowed to the south-southeast at an estimated gradient of 0.003 foot per foot.

Upper Trinity aquifer.  The upper Trinity aquifer consists of the upper Glen Rose Limestone, which is exposed over much of the CSSA area.  Recharge to the upper Trinity aquifer is from direct precipitation on the outcrop of the upper Glen Rose Limestone and from stream flow losses.  Additional recharge in the Camp Bullis area occurs from reservoirs built by the SCS on Salado and Lewis Creeks, approximately one mile south of CSSA (USGS 7.5 minute topographic map, Camp Bullis quadrangle photorevised, 1973).

No transmissivity values have been determined for the upper Trinity aquifer, but such values can be expected to be less for the upper Trinity than for the middle and lower Trinity aquifers.  Movement of groundwater in the upper Trinity is restricted to lateral flow along bedding planes between marl and limestone, where solution has enhanced the permeability of the limestone.  Static water levels in adjacent wells completed in different beds within the upper Glen Rose are not concordant, demonstrating the possibility that beds are not hydraulically connected by avenues of vertical permeability.  The only place where extreme development of solution channels has been reported is in evaporite layers in or near the outcrop of the upper Glen Rose Limestone.  Discharge from the upper Trinity aquifer is predominantly from natural rejection through seeps and springs and from pumping.

The upper Trinity aquifer appears to be under water table conditions where the aquifer is unbound by any confining strata.  Fluctuations in water levels in the upper Trinity are predominantly a result of seasonal rainfalls and pumpage from domestic and pumping wells.

3.2.4  Groundwater Quality

The following information is summarized from TDWR, report 273, Ashworth, 1983; Hydrogeology of the Lower Glen Rose Aquifer, Hammond, 1984; and Hydrogeology of the Camp Bullis Area, Waterreus, 1992.

Lower Trinity aquifer.  In the CSSA area, the lower Trinity aquifer yields fresh to slightly saline water with a TDS content ranging from 900 to 1,500 mg/l.  Approximately 40 miles updip of the area, the aquifer yields water with a TDS content of 500 mg/l or less.  The lower Trinity aquifer is not used as a primary source of water.  The overlying Hammett Shale is reported to be a heaving shale and must be cased off in order to complete a well in the lower Trinity aquifer.  The high cost of constructing a well in the lower Trinity makes it economically unfeasible to pump for most purposes.

Middle Trinity aquifer.  The middle Trinity aquifer yields fresh to slightly saline water throughout the area.  Water in the lower member of the Glen Rose Limestone is normally very good quality, although hard.  This water increases in dissolved solids content near the Balcones fault zone owing to an increase of sulfate ions.  No wells are known to have been completed only in the Cow Creek Limestone; therefore, the water quality of that limestone member is unknown.  The middle Trinity aquifer is the most widely used source of water in the area.  Most water wells in the area obtain middle Trinity water for public supply, irrigation, domestic, and livestock purposes.

Upper Trinity aquifer. Upper Trinity water is generally of poor quality, and most wells achieve only low production.  The existence of evaporite beds in the upper Trinity causes excessive sulfate in the water.  Few wells obtain water solely from the upper Trinity aquifer.

Edwards aquifer recharge and transition zones.  The Edwards aquifer is not found in the CSSA area.  However, the Edwards Underground Water District has defined recharge and transition zones of concern near the Edwards aquifer.  Two such zones are located north and south of CSSA.  One recharge area is along Cibolo Creek where the lower Glen Rose outcrops.  This is the only area of the lower Glen Rose that is defined as a recharge zone to the Edwards aquifer.  The closest area of this recharge zone is 0.5 mile from the northeast corner of CSSA.  A second recharge zone located on Edwards limestone is about 4 miles to the south-southeast.  A transition zone is 5 miles southeast of CSSA.  It is unknown how much surface or groundwater from the CSSA area recharges to these zones, if any.

3.3  Biological Resources

A habitat evaluation for this EA was prepared by Stewardship Services (appendix C).  The objective of this biological evaluation was to assess the general site condition for native terrestrial biota and to determine if there might be potential habitat on the installation for any rare, threatened, or endangered species.

An initial visit to CSSA was made on December 1, 1992, when a general evaluation of the vegetative condition of the property was made, primarily from the vantage point of various roads and trails which cross the site.  Particular attention was given to identifying areas which might contain suitable habitat for rare, threatened, or endangered species.

On December 2, 1992, a more focused site evaluation was made, primarily on foot, of several areas which might contain sensitive species' habitat.  Additionally, brief interviews were conducted with resource management personnel and persons with knowledge of the land use history of the site.

Appropriate aerial photographs and topographic maps were analyzed to confirm the findings from the site visits and to identify any additional areas which may have been missed, but which appear similar to sensitive areas which were noted during the visits.  Soils and geological maps were referenced to evaluate the current condition of the vegetation at the site relative to its potential vegetation condition.

3.3.1  Native Vegetation

The site is typical of the Balcones Canyonlands portion of the Edwards Plateau, encompassing a complex of limestone hills, drainages, and valleys with several springs and intermittent streams dispersed throughout (Riskind and Diamond, 1988).  The upper drainages of Salado Creek occupy much of the central portion of the site.  Elevation ranges from about 1,100 to 1,500 feet.  The general upland vegetation community type is classified as mainly an evergreen woodland of the Ashe juniper-oak (Juniperus ashei-Quercus sp.) series, and there is a minor riparian component of the sugarberry-elm (Celtis laevigata-Ulmus sp.) series (Diamond, et at., 1987).

Approximately one-third of the property has been modified for military purposes, primarily to accommodate munitions storage and troop training activities in earlier times.  Paved roads, rail lines, and a variety of buildings which support these functions are concentrated in the inner cantonment area.  Remains of other buildings and infrastructure are also dispersed throughout the site.

The current condition of the soils and vegetative cover in the "undeveloped" two-thirds of the site suggests previous overgrazing, land clearing for agricultural purposes, and suppression of natural fires.  Management directed toward cattle grazing and game production has resulted in most of the property being maintained in an open grassland or disturbance of savanna condition.  Selective brush removal, particularly of Ashe juniper, and mowing of some areas occur periodically.  Supplemental food and water for stock and wildlife are provided throughout the site.  Prescribed burning in some areas had been conducted in past years; however, none is done at this time.

The majority of the wooded uplands are characterized, generally, by a broken canopy of older live oaks (Quercus fusiformis) with somewhat younger Ashe junipers occupying the midstory and invading open areas in the woodlands.  Where active juniper removal is occurring, the vegetative cover type has more of an oak/oak motte savanna appearance.  Spanish oak (Quercus buckleyi) is present in some areas, but is not abundant, and very little mixed shrub development was noted.

The broader, floodplain areas have generally been maintained as open fields.  The smaller drainage areas over most of the site contain very little cedar elm (Ulmus crassifolia) or other mixed hardwood species normally associated with such areas, and instead are generally dominated by stands of live oak and Ashe juniper.

3.3.2  Wildlife and Livestock

CSSA is managed to meet three objectives:  to accommodate military activities; to satisfy a cooperative grazing lease with the USDA-ARC in Kerrville; and to provide hunting opportunities for military personnel.  Land management decisions are made ultimately by the installation's commander based on military needs, recreational interests, informal cooperative agreements with other agency resource specialists, and recommendations made by the installation's Wildlife Management Committee.

The Wildlife Management Committee on the site consults with the Texas Parks and Wildlife Department (TPWD) in annually counting the deer, planning the hunting program, and recommending land management activities focused on game species, primarily white-tailed deer and turkey (appendix C).  A free-ranging herd of axis deer is present at the site and is also hunted.  At one time, feral hogs were introduced for hunting purposes, but it is believed that they have all been removed.  As the need arises, the Command has consulted with the Alamo District Conservation Office of the SCS relative to farm pond construction.

Habitat condition for the high-profile native game species (deer and turkey) is good.  Although a detailed systematic study was not conducted as part of this ES, the general structure of the upland vegetation is known to be favorable to white-tailed deer, and the active and successful hunting program is helping to keep the deer population within the carrying capacity of the site.  Attention has also been given to improving the site's turkey habitat.  The nature of the population dynamics of the native white-tailed deer and the exotic axis deer and whether there is any direct competition between these two species at the site is unclear at this time.

The grazing lease is administered through a cooperative agreement between the Alamo District Conservation Office of the SCS and the USDA-ARC in Kerrville.  Stocking rates and range management recommendations are made by the USDA-ARC personnel based on research needs and in accordance with general guidelines developed in 1983 (appendix C).

3.3.3  Endangered, Threatened, and Rare Species

A description of endangered, threatened and rare species is presented below for the area northwest of San Antonio.

Two federally listed endangered bird species, the black-capped vireo (Vireo atricapillus) and the golden-cheeked warbler (Dendroica chrysoparia) are known to nest in the general upland habitat type which occurs to the northwest of San Antonio.  One federally listed endangered plant species, the Tobusch fishhook cactus (Ancistrocactus tobuschii) is known from similar habitat in counties to the northwest of CSSA.  The Texas blind salamander (Typhlomolge rathbuni) is federally listed as endangered and the San Marcos salamander (Eurycea nana) is federally listed as threatened.  Both of these species are known to occur in the southeastern Balcones Canyonlands portion of the Edwards Plateau in the Edwards aquifer.

Several federal category 2 and state-listed threatened or endangered animal species, the widemouthed blindcat (Satan eurstomus), the toothless clindcat (Trogloglanis pattersoni), the Comal blind salamander (Eurycea tridentifera), the Texas salamander (Eurycea neotenes), the Blanco blind salamander (Typhlomolge robusta), and the Texas horned lizard (Phrynosoma cornutum), and two plant species, Correll's false dragon-head (Physostegia correllii) and big red sage (Salvia penstemonoides), also occur to the northwest or adjacent to San Antonio.

Additionally, nine species of cave invertebrates, known to occur in caves in the geographic region, have recently been petitioned for federal listing as endangered (Reddell, 1988; Price, 1992).  the subterranean biota of the area is poorly known at this time.  During a downhole video camera survey of wells at CSSA, an unidentified invertebrate and a vertebrate (a salamander) were found in one well (well 2).  The invertebrate was present at 100 feet below static water level and appeared to be an isopod.  The salamander was observed at the bottom of the well (346.5 feet).  Species collection or identification has not been conducted for these two aquatic subterranean organisms and is not planned.

Black-capped vireo.  Historically, the black-capped vireo nested from the mountains of northern Mexico to Kansas and Oklahoma (Graber, 1961).  It is now believed to be extirpated from Kansas, only a small population is known from Oklahoma, and its numbers and range in Texas appear to be declining (USFWS, 1991).  The population declines are attributed primarily to habitat loss and to parasitism by the brown-headed cowbird (Molothrus ater).  Both threats have intensified in recent years due to rural land use practices and urban expansion.  The black-capped vireo was listed by the US Fish and Wildlife Service (USFWS) in October 1987 as endangered.

In general, this bird requires a patchy arrangement of well-developed shrubs and mid-successional overstory irregularly interspersed with bare or grassy openings.  The brush component should be complete to the ground to provide suitable nest sites (Graber, 1961).  The species composition of the vegetation tends to be less important than its structure, but broad-leaved species are more favorable than others, and juniper may be underrepresented in occupied habitat.  Suitable habitat development for this species is strongly associated with the rocky soils of the Lower Cretaceous limestones of the Fredricksburg Group (Sexton, 1990).

There are several areas at CSSA on the east side of the main drainage of Salado Creek which may have the vegetation structure and composition suitable for nesting habitat for this species (Figure 8).  One pair of vireos was observed in the northeast portion of CSSA during spring field studies.

Golden-cheeked warbler.  The nesting range of the golden-cheeked warbler corresponds to the range of Ashe juniper in central Texas (Pulich, 1976).  Prime habitat for this warbler consists of mature Ashe juniper in association with mature stands of mixed hardwoods to meet both its nesting and foraging requirements (USFWS, 1992).  From field investigations conducted in the area during the last 4 years, it also appears that canopy closure should exceed 40 percent for the stand, in general.

Recent projections of accelerating population declines (Wahl, et al., 1990), primarily the result of habitat loss throughout its nesting range through increasing urbanization and various range management practices (Oberholser, 1974), led the USFWS to list the species as endangered in December 1990.

Although much of the woody vegetation at CSSA has been fragmented and juniper removal has been extensive, there are several areas which could provide some amount of adequate nesting habitat for this species (Figure 8).  One male warbler was observed during spring field studies in the northeast portion of CSSA.

Other species of concern.  The overall habitat condition and current land use practices at CSSA do not appear to be suitable for any of the other rare, threatened, or endangered species, with the possible exception of the Texas horned lizard.  This species very likely did occur at the site in times past.  However, its population numbers have declined to such a degree that it has only rarely been documented from the general area in recent years.  Reasons for this decline are unknown at this time.

Some rare, threatened, or endangered subterranean species could occur at the site, including the Texas salamander, the Comal blind salamander, and a number of rare cave invertebrates or other unique species.  As discussed above, preliminary evidence from the well inspection work has documented the presence of vertebrate and invertebrate organisms in one well.  Since distribution of the two endangered catfish is generally restricted to pools of the Edwards aquifer which occur in the southwestern part of San Antonio, and since the Texas blind salamander, San Marcos salamander, and Blanco blind salamander are also presumed to have very narrowly defined ranges, none of these species would be expected to occur at CSSA.

3.4  Land Use

An important part of this EA is to review and evaluate land uses at and surrounding CSSA.  Past and current land use activities and actual or potential sources of pollution associated with these activities were identified to evaluate the ecological habitats, historic sites, surface and groundwater resources, and agricultural, residential, commercial, and industrial areas was also evaluated for potential effects of installation activities on these resources.  The general land uses of CSSA and adjacent areas are described below and shown on Figure 9.

3.4.1  On Site

CSSA is a restricted-access installation that requires authorized clearance to fo on site.  Currently, about 120 people work at CSSA, most of whom are present only during normal working hours.  A record search at CSSA indicated that in 1974 approximately 150 people were employed at CSSA.  In 1971 there were 165 nonresidents and 10 resident personnel, and in 1968, approximately 75 people were employed.

The inner cantonment of CSSA, comprising 1,760.18 acres, is used for storage of ammunition in igloos, light industrial activities, such as maintenance and cleaning of weapons, warehouse storage, and offices.  There are approximately 200 buildings, with approximately 120 igloo magazines housing conventional weapons and ammunition.  Seven houses where personnel and their families live are also located on CSSA, within the inner cantonment along the western edge of the property.  Four houses are permanent structures and three are modular homes.

The 2,244 acres of the outer cantonment is used for test ranges, wildlife hunting, and cattle grazing.  Much of the east and north pastures is unimproved to provide a protection area around the firing range.  Wildlife is hunted by military and civil service personnel, retired employees, and immediate families or other persons authorized to go on site.  CSSA has a cooperative agreement for cattle grazing with the USDA-ARC (USDA, 1991).

Archaeological surveys in the area surrounding CSSA and the neighboring Camp Bullis surveys have identified numerous prehistoric and historic sites.  Camp Bullis and CSSA are very much related in historic and cultural aspects, and thus similar prehistoric and historic sites can be expected to occur at CSSA.  The preliminary survey which was conducted at CSSA for this EA indicate that such sites occur.

3.4.2  Off Site

Bexar County is dominated by agriculture, covering approximately 60 percent of the total acreage.  Developed land accounts for approximately 27.6 percent of total county land use (15.5 percent residential, 1.5 percent commercial, 3.0 percent industrial, and 7.6 percent military, institutional or cultural/recreational).  The remainder of the land is either open space (e.g., parks, water), vacant, or used for transportation (City of San Antonio, 1991).

San Antonio has seen most of its recent development occur to the north and northwest of the city.  Although the area surrounding CSSA is primarily rural, the density of residential development on the west and south of the installation is increasing.  Adjacent communities include Fair Oaks, a large-lot single-family subdivision to the west and northwest, Leon Springs to the south.  Adding to the communities of Fair Oaks and Leon Springs, the subdivisions of Cross Mountain Ranch, Summit Oaks, Hidden Springs, Grey Oaks, and several others have had approvals for over one thousand additional lots to be developed from 1980 to 1992 (City of San Antonio, 1993).

On the eastern and part of the northern and southern boundaries of CSSA is the Camp Bullis Army Installation, which comprises 27,880 acres.  Camp Bullis serves as the field training installation in support of all military activities in the south Texas area.  Eleven major training areas are located on Camp Bullis.  Activities are conducted for weapons training, field training, and maneuvers.  The installation features map and compass courses, a drop zone for parachute operations, and a combat assault landing strip (ES, 1992b).

Camp Bullis is also one of the most significant undeveloped public lands in south central Texas.  In addition to military operations, Camp Bullis is used for recreation by civilians and military personnel.  Recreational activities consist of hunting, fishing, shooting, and youth adventure sports such as mountaineering, land navigation training, and camping (ES, 1992h).

Historically, the native vegetation condition of the region in which CSSA is located is believed to have been a fire-maintained matrix of woodlands, grasslands, and savannas, with riparian corridors along the floodplains.  However, following Anglo settlement, beginning in the 1800s, the landscape underwent a dramatic and somewhat irreversible transition to extensive contiguous woodlands.  The primary agents contributing to the initial alteration were fire suppression, fencing, cultivation, overgrazing, and soil erosion.  More recently, the major agent of land conversion in the area has been advancing urbanization.

3.5  Cultural Resources

Cultural resources are prehistoric and historic sites, structure, districts, artifacts, or any other physical evidence of human activity considered important to a culture, subculture, or community for scientific, traditional, or religious purposes.

All structures and sites greater than 50 years of age should be evaluated for compliance with the National Historic Preservation Act (NHPA).  This EA presents the first cultural resources work for the installation.  Potential cultural resources in the vicinity of CSSA are identified so that a prediction about the historic potential of the installation can be made.

Cultural resources have been divided for ease of discussion into two main categories in this report:  prehistoric resources, and historic structures and resources.  Record and literature searches were performed at Camp Stanley, the Texas Historical Commission in Austin, and the Library of Congress in Washington, D.C.  This research was conducted in December 1992.

3.5.1  Prehistoric Background

The following prehistoric background uses four basic developmental stages common to both the central and south Texas regions:  Paleoindian, Archaic, Late Prehistoric and Historic (Hester, 1980).  The Archaic is further divided into three substages, Early, Middle, and Late, and the Late Prehistoric is subdivided into two phases, the Toyah and Austin.

The Paleoindian period in Texas is generally dated from 12,000 to 8,000 years ago.  These Paleoindian groups crafted distinctive and geographically widespread stone tool assemblages.  In Texas, the earlier diagnostic artifacts are known as Clovis and Folsom types, and the later as Plainview, Angostura, ad Golodrina (Prewitt, 1981; Black and McGraw, 1985). The Clovis and Folsom forms have been associated in various parts of the country with extinct large mammals, including mammoth, mastodon, camel, horse, and bison.  In most areas of the country, big game hunting was likely supplemented by exploitation of smaller game and plants.

The transition between the Paleoindian period and the Early Archaic was gradual, coinciding with a warming trend and the extinction of may species of large mammals.  The Early Archaic lasted from about 8,000 to 5,500 years ago.  This period is marked by profound social and economic changes (Weir, 1976; Story, 1980; Prewitt, 1981).  The proliferation of numerous diagnostic projectile points over a wide geographic area has been interpreted to signal the distinction between social groups.

The Middle Archaic in central Texas has been virtually defined by the presence of a single specialized site type, the burned rock midden and its associated artifact styles.  The Middle Archaic lasted from approximately 5,500 to 3,000 years ago.  The burned rock features appear to represent intensified and specialized activities, perhaps associated with acorn processing.  There are marked changes in population, settlement patterns, technology and territorial boundaries (Weir, 1976; Story, 1980; Prewitt, 1981; Black and McGraw, 1985).  The regionalization of cultures, based on projectile point styles, increases dramatically during the Middle Archaic.  The proliferation in the number of sites may signal population increase.

The Late Archaic marks the peak of distinctions in material culture, implying regionalization of social groups, corresponding with a population increase.  The Late Archaic in central Texas is generally dated from about 3,000 to 1,200 years ago (Story, 1980; Prewitt, 1981; Black and  McGraw, 1985).

The Late Prehistoric period is generally divided into earlier and later phases, the Austin Phase and the Toyah Phase.  The Late Prehistoric generally dates from about 1,200 to 300 years ago.  In central Texas, the Austin Phase is marked by the introduction of bow-and-arrow technology.  The trend of increasing regionalism seems to decrease during the Austin Phase and is marked by similar and widespread material traits.  The Toyah Phase in central Texas is marked by the systematic use of ceramics and by a markedly different subsistence and settlement pattern.  Bison remains are frequently found in Toyah Phase sites.

3.5.2  Historic Structures and Resources

Regional history and settlement.  Spanish exploration reached the coastal area of Texas in 1519 with the Alvarez de Pineda expedition, and others soon followed.  It was not until the 1700s that the Spanish established missions in Bexar County to Christianize the native Indian populations.  In 1718, Martin de Alarcon founded the mission of San Antonio de Valero (the Alamo) and the San Antonio de Bexar Presidio.  Other early missions included Nuestra Senora de la Purisma, Concepcion de Acuna, San Francisco de la Espada, and San Juan Capistrano.  A civil settlement for Canary Islanders was founded in 1731 in the villa of San Fernando de Bexar (San Antonio).  This became the first municipality in the Spanish province of Texas.  In 1772, the seat of government of Spanish Texas was moved to Bexar from Los Adaes.  By 1770, Bexar county was sparsely settled, with most settlements centered around San Antonio.  Native Indian populations in Bexar County at this time included the Lipan Apache and the Comanche, who had come to the Plains region in search of food (EHA, 1991).

In 1824, Texas belonged to the newly independent Mexico.  The Mexican government established three political regions in Texas:  Bexar, Nacogdoches, and Brazoria.  Bexar extended from the Rio Grande to the Texas Panhandle and to El Paso in the west.  During the early nineteenth century, most settlement in the Bexar region continued to be centered around San Antonio.

In an attempt to increase settlement in the region between San Antonio and Nacogdoches to the east, thee Mexican government granted a series of empresario contracts to men who promised to bring settlers to populate a given area or province.  Most of the settlers came from the United States and Europe (Gerstle et al., 1978).

Many Anglo-American settlers were planters and frontiersmen from the southern states of Louisiana, Alabama, Arkansas, Tennessee, and Missouri.  They acquired farmland along major river valleys in the eastern part of Texas and established cotton plantations using slave labor (Gerstle et al., 1978).

European settlers emigrated from Germany, France, Czechoslovakia, Poland, and Norway.  The German immigrants had the greatest influence on the rural culture of central and southwestern Texas.  They established independent farms, and planted with diverse crops which did not require slave labor (Gerstle, et al., 1978).  Cattle ranches were also an important industry in Bexar County and had been inexistence from the time of Spanish settlement (EHA, 1991).

Texas became a free republic in 1836 following General Sam Houston's victory over the Mexican dictator General Santa Anna at San Jacinto.  Another wave of Anglo-American and European immigrants arrived in Texas at this time primarily because of the vast amount of open land available.

In December 1837, the Republic of Texas enacted a General Land Act in order to parcel out the land.  First-Class grants were given to any man who had arrived in Texas before the signing of the Texas Declaration of Independence in March 1836.  Married men were entitled to one league 1,791.5 hectare (ha), or 4,423.4 acres (ac) and one labor 71.7 ha (177.1 ac); single men received one-third of a league 597.8 ha (1,476.1 ac).  Second-class certificates for 1,280 acres were granted to those who had arrived before October 1, 1837.  Later arrivals received smaller portions of land (Boyd et al., 1990; EHA, 1991).

The land which became Camp Stanley was part of several acquisitions made by Nathaniel Lewis between 1838 and 1847 (Boyd et al., 1990).  Lewis was born in Falmouth, Massachusetts, in 1806 and arrived penniless in Texas around 1830.  He became a successful merchant and owned large tracts of land throughout the state.  Lewis began ranching the land in the area soon after his purchase.  The main ranch on his property was located east of CSSA, between the floodplains of Salado and Panther Springs creeks.  It is unlikely, however, that he ever lived there because his home was located in San Antonio.  The 1848 tax rolls indicate that he owned 647,008 acres, 84 slaves, 252 horses, and 4,077 cattle, with a total value of $306,266 (Boyd et al., 1990).

In 1847, Lewis sold 2,577 acres of his land located on the floodplain of Slado Creek to John Meusebach for $2,600.  Meusebach did not ranch the land but was engaged primarily in agriculture (Boyd et al., 1990).  The 1856 tax rolls indicate that he owned 3 horses, 35 cattle, and 500 hogs.  Meusebach married Agnes von Coreth in September 1852, and probably constructed the two-story stone house at Comanche Spring (site 41BX420) at this time.  This site is located just outside the southeast boundary of CSSA, as shown in Figure 10.

Meusebach was a German immigrant who served as the commissioner-general of the Society for the Protection of German Emigrants to Texas.  In 1847, Meusebach resigned his post and settled on the land which he had purchased from Lewis.  He sold this land to Henry Habermann in October 1853, but remained there with his family until about 1860.  At this time, he moved his family to Fredricksburg and began a mercantile business (Boyd et l., 1990).

Habermann bought more property located adjacent to his Meusebach purchase from Nathaniel Lewis in 1862.  He owned a total of 9,224 acres, and the 1862 tax rolls indicate that he had 300 cattle.  In 1881, Habermann sold this land to his friend, Conrad Schasse.  Schasse was a druggist who resided in San Antonio but continued to operate a cattle ranch on Comanche Spring property.  In 1906, he sold 4,877 acres of this land to the United States government.  This constitutes most of the southern portion of CSSA.  The northern portion of the camp was acquired by the US government through purchase or condemnation in 1941.

History of Camp Stanley.  During the late nineteenth century, the small military outposts throughout Texas were slowly consolidated into larger, more permanent garrisons.  The Post at San Antonio, later renamed Fort Sam Houston, was selected as a central garrison for the cavalry, infantry, and artillery in 1882 (Army, 1990a).

By 1890, additional land was required for field training, artillery ranges and maneuver grounds.  In 1906 and 1907, six tracts of land were purchased near Leon Springs.  The Schasse tract, which includes most of the southern portion of Camp Stanley, was one of these tracts (see Figure 10).  This new property called Leon Springs Reservation was made use of at once.  The Southwestern Rifle and Pistol Competition was held from July to August 1907 on a rifle range which was built just north of the Schasse Ranch (within Camp Stanley).

Over the next years, the Leon Springs Reservation was used for maneuvers by Regular Army and National Guard units.  Campgrounds were set up, one of which was located at the Schasse Ranch.  Other businesses were established to accommodate the soldiers training in the area.  For example, by 1908, a saloon was located outside one of the gates to the reservation.  As shown in Figure 10, the site of this saloon is within present day CSSA (Army, 1990a; Boyd et al., 1990).

In 1911, the Third Brigade of the Maneuver Division used the Meusebach house on the Schasse land as its headquarters.  In the spring of 1917, Remount Station #3 was established at the western edge of the Leon Springs Reservation (southwest corner of CSSA).  This station had animal shelters, hay racks, a grain house, dip tanks, a vegetable garden, veterinary stables, wells and tanks, officers quarters, mess halls, and corrals.  It served to process and maintain horses purchased for use by the mounted arms of the service (Army, 1990a).

In February 1917, the reservation was named Camp Funston in honor of the deceased commanding general of the Southern Department, Major General Frederick Funston.  However, because a fort in his native Kansas was also given his name, the Leon Springs Reservation was redesignated as Camp Stanley, in October 1917.  It was named for Brigadier General David Sloan Stanley who was a former commander of the Department of Texas.

The US involvement in World War I spurred a new series of preparations at the reservation.  The FOTC was established at Camp Funston on May 15, 1917.  The purpose of the FOTC was to provide junior officers with field training and extended order (tactical) drills.  Their training covered practice marches, trench warfare, and marksmanship at the rifle range north of the Schasse Ranch.  A branch of the Signal Corps school was established in May 1917 and named Camp Samuel F.B. Morse.  The actual location of this facility is not disclosed in available documents; however, at the time it was likely located in the northwest corner of Camp Stanley.  Divisional signal battalions and telegraph battalions were trained there (Army, 1990a).

From 1917 to 1919, field artillery brigades, trench mortar batteries, quartermaster battalions, cavalry regiments, and US guard battalions were housed on Camp Stanley and trained on the adjacent Camp Bullis.  Extensive construction took place on Camp Staley in order to provide housing for these men.  A map produced in 1925 shows regimental-size temporary cantonments and installation support facilities (see Figure 10).  Three cantonments were intended for mounted units, that is, field artillery and cavalry regiments, and included a large number of stables.  Another cantonment may have housed the US guards.  In addition, a brigade headquarters, a post headquarters, and a series of quartermaster facilities were constructed.  A railroad also serviced the camp.  The rails entered at remount station No. 3, extended north to the center of the camp and south to exit through the Schasse Ranch.  By 1925, the remount station and parts of the cantonments were being dismantled (Army, 1990a).

In 1920, part of the cantonment at the north end of Camp Stanley was turned over to the Ordnance Section of the San Antonio General Intermediate Depot.  This area was used for storage of large stocks of ammunition surpluses after World War I and for the stock of ammunition required by ground and aviation units during training.  The facilities at Camp Stanley were temporary and flammable structures which had not been designed for this purpose; however, they were the best available in the area.  The existing San Antonio Arsenal had been built in 1859 and had been expanded as much as possible during World War I.  However, by 1919, the city of San Antonio had grown around it, which not only limited its expansion but made it a dangerous location for ammunition storage.  In 1925, the Ordnance Department made plans to construct a proper storage area for a 2-year supply of ammunition and components for all combatant troops in the Eighth Corps area.  Camp Stanley was chosen for the new storage depot in 1931.  A 1,270-acre tract of the camp was transferred to the chief of ordnance for the San Antonio Arsenal in September 1933.  In January 1938, construction of the standard magazines and igloo magazines began (Army, 1990a).

In 1932, President Franklin D. Roosevelt created the Civilian Conservation Corps (CCC) for conservation, relief, and public works.  From May to July 1933, 4,000 CCC enrollees were assembled and in-processed at Camp Bullis.  They were then organized into companies and sent to camps throughout Texas.  Many of those from Camp Bullis worked at Camp Stanley building structures and other facilities.

In 1940, the US made preparations to enter World War II.  The facilities at Camp Bullis were expanded to support mobilization and training of Army ground forces.  Additional tracts of land for Camp Bullis were acquired through condemnation or purchase in 1941.  Several of these tracts were located just north of Camp Stanley and were eventually transferred to it.  The owners of these tracts were A. Blank, W. Wilke, O. Scharmann, and J.F. Ashley.  There were ranch houses located on these tracts.

Among the training courses designed and constructed on Camp Bullis land, later transferred to Camp Stanley, was a "fortified area" (Figure 10).  It was built in 1943 by the 320th Engineer Battalion near the old rifle range at Schasse Ranch, which until that time had been used as a moving-target antitank range (currently, the large range on CSSA).  This fortified area was intended to familiarize soldiers with the the fortified combat areas they were likely to encounter overseas.  The engineers constructed simulated bunkers, antitank ditches, and wire entanglements.  The bunkers were constructed of wood framing and metal mesh, then coated with concrete realism.  They did not, however, have roofs or back walls.  Most of the simulated bunkers remain on CSSA and are often mistaken as remnants of sets made for the movie Wings, which was filmed in that area in 1926 (Army, 1990a).

Camp Stanley became part of the Red River Arsenal in 1949.  In addition to ammunition storage, the camp was used to test-fire and overhaul ammunition components.  In August 1953, about 2,040 acres, including the original target ranges north of the Schasse Ranch, were transferred from Camp Bullis to Camp Stanley.  An additional 204 acres were assigned to Camp Stanley in December 1970; this is now the northern most portion of CSSA (Boyd et al., 1990).

3.5.3  Cultural Resource Surveys

Information about archaeological sites in the vicinity can provide information about the potential of the area to contain prehistoric and historic sites.  Within the last 20 years, Bexar County has been the subject of considerable archaeological attention generating excellent summaries of archaeological investigations to date (e.g., Gerstle et al., 1978; Black and McGraw, 1985; Katz, 1987; McGraw and Hindes, 1987; Boyd et al., 1990).

Archaeological surveys have been conducted on Camp Bullis, which shares common borders with CSSA.  Prior to 1975, only one prehistoric site was identified on Camp Bullis.  This site was a large multicomponent camp consisting of a burned rock midden (Townsend, 1975).  The first intensive archaeological work on Camp Bullis consisted ona 100-percent survey of 20 percent of the camp (Gerstle et al., 1978).  The survey located ninety-one prehistoric isolated finds, recorded nine historic and sixty-two prehistoric sites, and conducted limited testing at twelve sites.  The prehistoric sites represented all temporal periods and were of different types, including base camps and satellite sites.  The historic sites consisted of ranches.  A total of forty-one of these sites were considered as eligible or potentially eligible for listing on the National Register of Historic Places (NRHP).  It was recommended that further impacts to these sites be avoided or that testing be done prior to any disturbance.  In 1988, another archaeological survey was carried out on Camp Bullis, identifying the presence of eight prehistoric sites and reinvestigating two others (Quigg, 1988).  Two sites were considered to warrant further archaeological consideration.  In 1989, a third survey was performed on three high-use areas on Camp Bullis (Boyd et al., 1990).  The survey identified eighteen prehistoric and nine historic sites, and two previously recorded prehistoric sites were reinvestigated.  The prehistoric sites were of all temporal periods and consisted of lithic scatters, campsites containing features such as hearths and burned rock middens, and rock shelters.  The historic sites consisted of World War I and World War II era military structures, and one ranch.  Of the twenty-nine sites investigated, one prehistoric and one historic site were considered eligible for listing on the NRHP.

Besides the cultural resources surveys performed on Camp Bullis, a number of other cultural resource surveys have been performed in the vicinity of CSSA.  A systematic survey was performed at Eisenhower Park, south of Camp Bullis, resulting in the identification of four prehistoric sites and the re-identification of two sites (McGraw, 1986).  All six sites were deflated lithic scatters, and none were deemed potentially eligible for nomination to the NRHP.  East of Camp Bullis, excavations were performed at the Panther Springs Creek site (41BX228), a multicomponent prehistoric occupation located within the Walker Ranch National Register Historic District (Black and McGraw, 1985).  The site was excavated due to repeated and persistent artifact looting be relic collectors.  Despite these problems, the excavations recovered large quantities of well-preserved cultural materials, including lithic, ceramic, and bone artifacts, representing multicomponent activities.

Just south of CSSA, an archaeological survey was performed on portions of the Salado Creek watershed, leading to the documentation of twenty-eight prehistoric sites and one historic site (Hester, 1974).  Most of the sites were prehistoric sites, including major occupations, temporary campsties, chert quarries and workshops, and rockshelters.  the historic site is a ruin on the Walker Ranch National Register Historic district, perhaps an early Spanish structure or a mid-nineteenth century site (Scurlock and Hudson, 1973; Hudson et al., 1974).  As a follow-up investigation to the survey by Hester, archaeological surveys were carried out along Salado Creek and in other watershed areas to the south and east (Dribble, 1979).  The survey resulted in the definition of nineteen prehistoric sites and two potential cave sites.  Along the Salado Creek drainage, two sites were identified, one consisting of a light scatter of artifacts and fire-fractured limestone, and the other consisting of lithic debris dominated by two mounded accumulations of fire-fractured limestone.

3.5.4  Field Assessment

The prehistoric and historic background research and the cultural resource surveys suggest that many types of cultural resources may be present on CSSA, including both prehistoric and historic sites and military-era standing structures and facilities.  Figure 10 depicts the high potential areas for identifying prehistoric and historic sites.  All structures and sites shown on the map are greater than 50 years old.  Standing structures and facilities are listed in appendix D.  Since no cultural resources survey has been conducted on CSSA, a field assessment was performed for 2 days in December 1992.

CSSA contains evidence of prehistoric sites, as indicated by materials collected by installation workers.  According to notes taken by the collectors, artifacts have been found in the east pasture and near Salado Creek.

During site reconnaissance, foundations and ruins of several structures were noted in the F section near Moyer Road and Barnard Road.  Among the identifiable architectural features were the foundations of a latrine and a flagpole.  These may represent the structures associated with the First Officers Training Camp, established at Camp Funston on May 15, 1917.  The structures certainly predate the igloo storage structures which were constructed from 1938 to 1940.

In the southeastern corner of CSSA, a rifle range was identified (Figure 10).  According to historical research and maps, this area was first used by the Southwestern Rifle and Pistol Competition from July to August 1907.  This area was later used by members of the FOTC for target practice in 1917, and was used for target practice in the ensuing decades.  This area is still used today.

In the north pasture, a potential World War I era camp was identified (Figure 10).  A large number of artifacts were scattered over the area, including bottle glass, ceramics, and metal objects.  No ruins of permanent structures were identified, suggesting that the camp may have supported only temporary structures or tents.

In the southern part of CSSA, there are sections of railroad tracks and beds (Figure 10 and photo 1 in appendix A).  From 1917 to 1919, a railroad serviced Camp Stanley, but sections of the railroad may predate the camp.  In some areas, the tracks date to 1932, as indicated by manufacturing stamps.

CSSA preserves extensive evidence of Works Progress Administration (WPA) projects of the CCC, established by President Franklin D. Roosevelt.  Structures and culverts constructed in the 1930s on Camp Stanley are said to be the product of CCC projects (photo 2).  A plaque at CSSA recognizes work performed by the WPA in 1938 and 1939.

In the southwestern corner of CSSA, the 1943 fortified area was relocated.  At least seventeen simulated bunkers are still standing, and were confirmed to consist of wood framing and metal mesh coated with concrete, with simulated bullet holes (photo 3).  In this area remnants of the barbed wire entanglements also remain.  Prior to the 1940s, this area was used for tank maneuvers.  Stone alignments identified in this area may record nonmilitary land use activities prior to 1908 (see Boyd et al., 1990: Figure 11).

Just north of the rifle range, a series of curled railroad tracks dating to the 1940s were identified.  These served as a training area for targets which moved around on the narrow-gauge railroad (Figure 10).

A number of standing structures remain at CSSA that were constructed prior to 1945.  These structures and facilities are listed in appendix D.  It is possible that some of these structures and facilities were rebuilt, therefore predating their year of said construction.

In the northern portion of CSSA, the ruins of several ranches were identified, as shown on Figure 10.  These tracts, owned by A. Blank, W. Wilke, O. Scharmann, and J.F. Ashley, were acquired by the government through condemnation or purchase in 1941.  During the survey on the Blank ranch, the foundations of the main house and at least ten other associated structures were re-identified (photo 4).  The date 1928 was carved into a cement water trough.  Although not identified with specific family tracts during this stage of research, numerous other foundations of structures were identified in the field.  A 1921 date was carved into a part-cement dam on a tributary of Salado Creek in the north pasture.

3.6  Material and Waste Management

Activities conducted at CSSA have required the use of both hazardous and nonhazardous materials, and have generated both solid and hazardous wastes.  Hazardous materials on site currently and in the past, PCBs, and solid and hazardous waste management activities at CSSA were investigated in this EA.  Past waste generation and disposal methods were reviewed to assess waste management practices.  Information was obtained from files and records, interviews with present installation employees, and field observations.  File data and interviews did not allow a complete determination of past waste handling practices.  It was difficult to determine practices, amounts, characteristics, quantities, disposal methods, or locations of waste generated prior to present-day activities.

3.6.1  Solid Waste Management

Under the Resource Conservation and Recovery Act (RCRA), a solid waste is broadly defined as:

... any garbage, refuse, sludge from a waste treatment plant, water supply treatment plant, or air pollution control facility and other discarded material, including solid, liquid, semisolid, or contained gaseous material resulting from industrial, commercial, mining, and agricultural operations, and from community activities ... [42 USC section 6903(27)].

A solid waste management unit (SWMU) is defined as any area or structure used to treat, store, or dispose of solid waste.

In 1992 and 1993, ES performed a review of CSSA waste management records followed by a detailed field survey.  The SWMUs were field located after being identified through historical waste management records (including a list of known waste management areas), site maps, aerial photographs, and interviews with CSSA personnel.  Once they were identified, ES attempted to field verify them.

Numerous areas historically used to burn and dispose of ammunitions, classified documents, and miscellaneous solid waste were identified and located.  The identified SWMUs include numerous trenches, firing ranges, ponds, landfills, pits or buildings, and waste piles.  Table 1 contains information pertinent to the SWMUs identified and located during 1992-93 assessment activities.  Map 1 shows approximate locations of these SWMUs on a 1973 aerial photo.  This map and additional (1966, 1989, and 1991) aerial photos (maps 2, 3, and 4) were obtained from the Texas Natural Resource Information Service (TNRIS) and United Aerial Mapping.  These aerial photos, in appendix M, were reviewed and compared for historical locations of potential source areas of contamination.  ground photos, taken during 1992-93 field investigations, of many of the SWMUs are in appendix A.

There are active and inactive firing ranges on CSSA.  The east range is used to fire small arms ammunition, grenades, small rockets, mines, pyrotechnics, and demolition items during testing and training activities as part of the CSSA mission (CSSA, 1993a).  In addition, there are two areas adjacent to the embankment where spent targets and ammunition have been buried.  The waste from these ranges, including spent targets, should be handled in accordance with appropriate guidelines and regulations.  A small four-position range is located in the cantonment area.  It is used in the past by the security branch and was formerly used by the wildlife committee to quality personnel for firearms use.

An indoor firing area located in building 90 is used to test weapons after maintenance.  This area uses sand to stop the bullets.  This sand, mixed with lead, has been disposed of in various SWMUs.

Two incinerators operated at CSSA.  The incinerator in building 294 (I-1) was built in 1943 and taken out of service around 1961.  It was a two-chamber, coal-burning incinerator reportedly used to burn paper and packing materials.  Inscribed on the chamber doors are the words, "Gilt Edge Cover Incinerator."  There are no ashes left inside the unit.  Currently, this building is used for storing transformers that contain less than 50 ppm PCBs.  The other incinerator, built in 1913, was converted to a boiler and is in building 46.

Most solid waste at CSSA is currently collected in dumpsters and picked up by Garbage Gobbler of San Antonio, Texas.  Approximately 310 cubic yards of solid waste is generated each month by CSSA, assuming that all containers emptied by the contractor are full.  Fifteen 90-gallon containers are emptied twice a week, two 40-cubic yard containers are emptied twice a month, and four 6-cubic yard containers are emptied weekly (CSSA, 1993b).

3.6.2  Hazardous Waste Management

A solid waste is defined as a hazardous waste if it exhibits any of the characteristics identified in title 40 of the Code of Federal Regulations (CFR), part 261, subpart C (i.e., characteristic wastes), or if it listed in 40 CFR 261 subpart D (40 CFR 261.3) (i.e., listed wastes).  These require proper labeling, storage, handling, and inventory reporting for hazardous materials and pesticides.  CSSA is classified as a small-quantity generator and operates under TWC registration 69026 and EPA identification number TX2210020739.  Relevant regulatory information is in appendix E.

Historically, these materials and wastes have been stored throughout the active portions of the facility.  As a result, not all historical satellite storage locations can be accurately defined.  Known hazardous materials areas are listed below.

CSSA operations at building 90 currently include munitions maintenance, which generates hazardous waste.  This waste is currently placed in containers (drums) and stored in and around a corrugated metal building 90-2 (HW-2).  Another building is currently being upgraded to store hazardous waste from building 90 and 90-1.  Around building 90, 90-1, and 90-2 there are visual indications of past spills and releases to the environment in the form of stains on the ground.  In addition, a memo (from October 1971) states that material was released to natural drainage.  The storage facility behind the motor pool (HW-1) has recently been upgraded to comply with applicable federal and state hazardous waste management regulations for container storage, including a concrete berm added for spill containment.  Table 3 details existing hazardous waste storage areas.  The waste petroleum products and solvents from the motor pool, locomotive area, and paint shop are stored in this location.

CSSA has used hazardous materials for ordnance maintenance operations since 1966 (Oliver, 1993).  A fingerprint removal operation is performed in building 90 to prepare small arms for storage.  Wastes from this process are a mixture of various petroleum distillates.  A halogenated solvent (tetrachloroethene) is used for a degreasing operation in building 90.  Spent degreasing solvent is drummed and transported to the hazardous material storage area.  A bluing operation is performed in building 90-1; this is a successive dipping process for small arms metal components (TDH, 1982a).  A solution called nickel penetrate is used in this operation.  From approximately 1975 to 1985, the washwater and sludges from the evaporation pond (discussed in the next section).  Currently, these wastes either are drummed or drain into a concrete sump where they are pumped into a 1,080 gallon nonhazardous waste storage tank.  Presently, spent solvents are drummed and transported to the hazardous material storage area (HW-2) while awaiting removal.  Since 1991, CSSA has contracted with Safety Kleen, a waste disposal, management, and recycling firm to provide necessary collection services for waste oils, solvents, etc.  Currently, drummed wastes from the bluing operation are disposed of by a licensed hazardous waste disposal firm.

Vehicle maintenance operations take place at the motor pool in building 4 and in the locomotive maintenance area in building 28.  Wastes generated are waste lubricating oils, antifreeze, hydraulic fluids, other petroleum lubricating fluids, and some solvents used in the operations.  In the past, these wastes were drummed and transported to DRMO at Kelly AFB.  Currently, Safety Kleen is used to dispose of these wastes.

Both the motor pool and locomotive areas have a service pit which drains directly to the ground or to a nearby unlined drainage ditch, respectively.  Both drains were plugged in May 1993.

Small amounts of solvent wastes are generated by the paint shop, which is located adjacent to the motor pool area.

Hazardous materials were stored in the F-14 area at CSSA.  this area is described in the soils section in this report and in the detailed F-14 accumulation point site assessment report (ES, 1992g).  It is known that PCB transformers, pesticides, solvents, and nickel penetrate drums were stored at this location.

These are the only locations at CSSA which have been identified to use hazardous materials.  No other hazardous waste (except any associated with cleanup or investigation activities) has been identified to be generated at CSSA.

3.6.3  Hazardous Materials Management

Current hazardous materials management practices at CSSA call for storing the hazardous materials required by building 90 operations in building 90-1, in building 90-2, in an "igloo" (B-116), and in a building near the paint shop and motor pool area.  Paints and small amounts of solvents are stored in two portable buildings, one northwest of building 90 and the other behind the motor pool shop.

3.6.4  Pesticide Management

Historically, CSSA pesticide applications have been conducted by facility personnel authorized to apply pesticides.  In the past, CSSA has stored chlordane, malathion, diazinon, and weed killers.  The only known application area is along the railroad tracks for weed control.  Some application equipment is stored adjacent to the locomotive building.  Additional application equipment and locations of equipment cleaning and disposal are unknown.  Current practice, during the last 4 to 5 years, is to employ contract pesticide applicators to perform large-scale applications.  CSSA personnel store only small quantities of nonrestricted-use pesticides in building 66 near the headquarters building.  During a site visit in November 1992, only Kocide 101 (copper hydroxide), copper sulfate, and rat traps and bait were observed.  this pesticide storage building is shown in photo 5 in appendix A.

3.6.5  PCB Management

Polychlorinated biphenyl (PCB) compounds are regulated through the Toxic Substances Control Act (TSCA).  PCBs are commonly found in older transformers.

An inventory and inspection of all oil-insulted transformers was performed by CSSA personnel in April 1981, according to available documentation.  Transformers containing PCBs were labeled based on information on the name plates.

In September 1982, CSSA disposed of nineteen transformers containing PCBs through Fort Sam Houston DRMO (TDH, 1982b).  CSSA disposed of twelve drums of PCB-containing transformer oil with AmerEco Environmental Services in March 1988 (TWC, 1988).

The VCI oil that was used as a rust-retardant on weapons was tested for PCBs in December 1986.  Twenty of the samples were below the detection limit of 5 ppm.  One of the samples was just above the detection limit, 6 ppm.

In October 1988, CSSA contracted with Fort Sam Houston (DRMO) to perform an analysis and data collection of transformers suspected to contain PCBs.  It was recommended that the suspect transformers and containers by turned in for salvage at Kelly AFB.  According to hazardous waste manifests, in November 1989, eleven drums of PCB-containing oil was transported and disposed of by Aptus, a facility in Loffeyville, Kansas.  A history of transformer storage indicated that transformers were stored at the F-14 storage area while awaiting disposal for an unknown amount of time.  Appendix E includes a history of PCB storage and disposal activity and sampling results.

Field activities conducted in 1992 at CSSA revealed that transformers of various size and age are currently being stored in an abandoned incinerator facility (building 294) located close to the wastewater treatment plant (photo 6, appendix A).  CSSA has records on the concentration of PCBs in each transformer and all are less than 50 ppm.

3.6.6  Storage Tanks

Underground Storage Tanks.  The status of USTs at CSSA have been evaluated in two projects.  The US Army Corps of Engineers evaluated twenty-two UST sites in 1989 based on a tank inventory and observations of surface conditions.  In September 1991, Armstrong Laboratory/OEB and CSSA contracted ES to perform an UST compliance evaluation in which the status of each UST was determined, preliminary subsurface assessments were performed around active and inactive USTs, and the project results were summarized in an "UST Compliance Report" (ES, 1992b).  Information from that report is summarized below.

CSSA has owned at least twenty-five USTs over the years, and since the mid-1980s, twenty-two tanks have remained in place.  The tanks stored various petroleum products which were routinely used for fuels and building heating.  As of August 27, 1991, the TWC had eight USTs registered to the US Department of the Army, CSSA, owner ID number 15480 and facility number 0032776.  The registered tanks contain or have contained diesel, gasoline, or Stoddard solvent (PD-680), a petroleum distillate product.  The remaining seventeen tanks contain or have contained heating oil and thus are exempt from registration.  The tanks were installed from 1939 to 1981 and ranged in capacities from 280 to 24,000 gallons.  An inventory of tank information is shown in Table 4, and the tank locations are shown in Figure 11.

CSSA records indicated that the USTs were tested for tank tightness in 1990, 1991, and 1992.  Ten of the twenty-two USTs passed tank tightness in 1990.  Four of these USTs (tanks 5, 16, 21, and 24) were upgraded for corrosion, spill, and overfill protection in 1991, and one (tank 5) was upgraded with a piping leak detection system.  Only these tanks were tested for tightness in 1991 and 1992.  They passed the tests and remain the only four active USTs at CSSA.

ES performed subsurface assessment at active and inactive USTs by drilling and sampling soil borings around accessible tank sites.  Analytical results indicated that release of product had occurred at five UST sites.  The TWC District 8 office designated these sites as leaking petroleum storage tank (LPST) sites.  Tanks 3, 4, and 6 are LPST number 101264; tank 7 is LPST number 102487; tank 13 is LPST number 102486; tank 18 is LPST number 102485; and tank 19 is LPST number 2488.

The UST compliance report recommended that the four active tanks be fully upgraded with installation of tank leak detection systems, the inactive tanks be upgraded or removed from service, and the five LPST sites be further assessed to determine the extent of released petroleum product.  Actions regarding these recommendations are currently in progress.  Eleven inactive tanks were permanently removed from service and disposed of in January and February 1993, three previously removed tanks were also disposed of at this time, and installation of leak detection systems or replacement with above ground storage tanks at the four active tanks will be accomplished in spring 1993.

Aboveground Storage Tanks.  CSSA has owned three mobile aboveground storage tanks (ASTs) of 1,000-gallon capacities and one mobile tank of 500-gallon capacity.  One of these tanks was never used, and the other two stored diesel fuel #1 or #2.  These tanks were never registered, and CSSA elected to have then disposed o.  The ASTs were emptied by CSSA personnel in February 1993, followed by triple-rinsing performed by Alamo Petroleum of San Antonio.  The ASTs will be sent to Kelly AFB for disposal.

3.6.7  Asbestos

Asbestos is a naturally occurring mineral.  It is distinguished from other minerals by the fact that its crystals form long, thin fibers.  Asbestos deposits are found throughout the world: Canada, the Soviet Union, South Africa, and the United States.

Asbestos minerals are divided into two groups - serpentine and amphibole.  The distinction is based on crystalline structure.  Serpentine minerals have a layered or sheet structure; amphiboles have a chain-like crystal structure.

Chrysotile, commonly known as white asbestos, is the only mineral in the serpentine group.  It is the most commonly used asbestos and accounts for approximately 95 percent of the asbestos found in buildings in the United States.  Five types of asbestos are found in the amphibole group: amosite, crocidolite, anthophyllite, tremolite, and actinolite.  The last three types are extrememly rare and of little commercial value.  Amosite, or brown asbestos, is the type second most likely to be found in buildings.  Crocidolite, or blue asbestos, was used in high-temperature insulation applications.

Asbestos has been used in literally hundreds of products.  Collectively they are referred to as asbestos-containing material (ACM).  The EPA and others distinguish between friable and nonfriable forms of ACM.  Friable ACM contains more than 1 percent asbestos and can be "crumbled or reduced to powder by hand pressure."  Other things being equal, friable ACM is thought to release fibers to the air more readily than nonfriable forms; however, many types of nonfriable ACM can release fibers if disturbed.  EPA identifies three categories of ACM used in buildings:

Surfacing materials - ACM sprayed or troweled on surfaces (walls, ceilings, structural members) for acoustical, decorative, or fireproofing purposes.  This includes plaster and fireproofing insulation.

Thermal system insulation - insulation used to inhibit heat transfer or prevent condensation on pipes, boilers, tanks, ducts, and various other components of hot and cold water systems and heating, ventilation, and air conditioning (HVAC) systems.  This includes pipe lagging and wrap; block, batt, and blanket insulation; cements and "muds"; and a variety of other products such as gaskets and ropes.

Miscellaneous materials - other, largely nonfriable products and materials such as floor tile, ceiling tile, roofing felt, concrete pipe, outdoor siding, and fabrics.

AR 200-1 requires that an asbestos survey be conducted for any preliminary assessment screening.  While it is possible to suspect that a material contains asbestos by visual determination, actual determinations can only be made by instrumental analysis.  EPA requires that the asbestos content of suspect materials be determined be collecting bulk samples and analyzing via polarized light microscopy (PLM).  PLM determines both the type and percent of asbestos in the bulk sample.

To reduce the health risk associated with ambient exposures to asbestos, the EPA (1992b) listed and regulated asbestos under section 112 of the Clean Air Act, 40 CFR 61 subpart M, national emission standard for asbestos (National Emission Standard for Hazardous Air Pollutants, NESHAP), and under title 3 of the Clean Air Act Amendments (CAAA) of 1990.

Asbestos is a recognized human and animal carcinogen.  Malignant diseases caused by asbestos exposure include bronchial carcinoma, lung adenocarcinoma, pleural and peritoneal mesothelioma, alimentary tract carcinoma, and tumors of other sites.  Asbestosis, a fibrotic lung disease caused by asbestos fibers, is also associated with long-term exposures.  These diseases are linked to ambient environmental exposures as well as to occupational exposures.

EPA (1985a) published a guidance document for controlling asbestos in buildings.  So long as nonfriable asbestos is intact and will remain undisturbed, it is not necessary to remove the ACM until demolition or renovation of the building.  Friable forms should be removed or encapsulated to prevent entrainment of the fibers in the air.  Facilities should conduct surveys to identify areas containing ACM.  They should develop operations and maintenance plans describing where the ACM is located, its condition, plans for removal or encapsulation, and work practices for maintenance workers when working in or on areas containing ACM.  All removal and maintenance work practice techniques must follow the EPA requirements listed in the NESHAP regulations and Occupational Safety and Health Administration (OSHA) worker protection rules.

CSSA had a survey of ACM performed by Fort Sam Houston (DEH) on January 31, 1992.  Table 5 lists the results of that survey.

3.7  Air Quality

3.7.1  Existing Air Quality

The existing air quality of the affected environment is defined by air quality data which are obtained by examining records from air quality monitoring stations maintained by the Texas Air Control Board (TACB).  Information on pollutant concentrations measured for short-term (24 hours or less) and long-term (quarterly, annual) averaging periods is extracted from the monitoring station data in order to characterize the existing background air quality of the area.  Air quality in a region is determined by comparing ambient concentration of specific pollutants with the appropriate federal, state, and local ambient air quality standards.  Ambient air quality standards are maximum limits or concentrations of pollutants in air.  Federal standards are based on estimates of maximum concentrations that, with an allowance for safety, present no hazard to human health or the environment.

the Clean Air Act (CAA) provides the basis for regulating air pollution to the atmosphere.  The CAA required the EPA to establish ambient ceilings for certain criteria pollutants.  The ceilings were based on the latest scientific information regarding the effects a pollutant may have on public health or welfare.  Subsequently, EPA promulgated regulations that set national ambient air quality standards (NAAQS).  NAAQS have been established for sulfur dioxide (SO2), nitrogen oxides (NOx), carbon monoxide (CO), ozone (O3), particulate matter equal to or less than 10 micrometers in diameter (PM-10), and lead (Pb).  The State of Texas has adopted the NAAQS.

According to EPA guidelines, an area with air quality better than the NAAQS for a specific pollutant is designated as being in attainment for that pollutant.  Any area not meeting ambient air quality standards is classified as nonattainment for the pollutant on which the standard has been exceeded.  When there is a lack of data for the EPA to define an area, the area is designated as unclassified and is treated as attainment until proven otherwise.  CSSA is located within the Metropolitan San Antonio Interstate Air Quality Control Region (AQCR) 217.  This AQCR is classified by EPA an attainment or unclassified for all criteria pollutants.

Ambient air quality monitoring conducted by TACB in San Antonio is limited to four of the criteria pollutants: PM-10, CO, O3, and Pb.  Ambient monitoring data for 1991 indicated that six air monitoring stations were in operation.  Three of these monitoring locations were continuous air monitoring stations (CAMS) sited in populated and/or industrialized areas (north, northwest, and downtown San Antonio) to determine concentrations of O3, CO, and PM-10.  The three remaining stations were noncontinuous air monitoring stations (NCAMS) located at downtown San Antonio, the San Antonio airport, and Kelly Air Force Base (AFB).  The NCAMS were operated periodically to monitor PM-10 and lead.  During 1991, no ambient air quality standards were exceeded (TACB, 1991a; TACB, 1991b; EPA, 1992).  The NAAQS and ambient monitoring results are presented in Table 6.

3.7.2  Air Pollution Emission Sources

No pollution emission inventory had been performed for the CSSA complex so an emission inventory was prepared in the process of this EA.  Potential sources of pollutant emissions identified are:  combustion emissions from four backup generators and five boilers; volatile organic compounds (VOC) emissions from four underground storage tanks (USTs), the bluing shop, the weapons preservative area, solvent weapons cleaning (two degreasers, one vapor degreaser, and five hand-carried solvent trays) and painting operations; and particulate emissions from a sand blaster, a steel shot blaster, a steel abrasive tumbler, a glass bead tumbler, and the weapons firing chamber.  Calculations for emissions are in appendix F.

There are four underground fuel storage tanks at CSSA:  tank 16 (1,000 gallons), tank 24 (2,000 gallons), tank 21 (500 gallons), and tank 5 (24,000 gallons).  Tanks 16, 24, and 21 are used for storing diesel fuel (#2 fuel oil) for the boilers and generators.  Tank 5 is used for storing gasoline for motor vehicles.  VOC losses from USTs (excluding any losses from leaks in the tank system) result from filling and withdrawal operations.  Since there are no AP-42 equations (EPA, 1985b) for calculating such losses from USTs, the fixed-roof working loss equation is used (AP-42 section 4.3, equation 2 on page 4.3-8).

For the USTs, fuels are assumed to be at 60 degrees F and working losses are:

Lw from all tanks = 241.292 lb/yr

Lw from all tanks = 0.121 ton/yr

Any breathing loss associated with a UST can be determined using the AP-42 section 4.3 fixed-roof tank equation (equation 1 on page 4.3-5) (EPA, 1985b) provided the UST has a normal pressure relief valve.

Breathing losses for the USTs are:

LB from all tanks = 301.536 lb/yr

LB from all tanks = 0.151 ton/yr

Total VOC emissions from the fuel storage tanks include working loss emissions and breathing loss emissions (Lt from all tanks = LW from all tanks + LB from all tanks) and are 542.828 lb/yr or 0.271 ton/year.

CSSA uses three backup generators with capacities of 500, 15, and 5 kilowatts per hour (kW/hr).  An additional generator with 30 kW/hr is not in use and has not been in working condition in years.  Combustion emissions were calculated using emission factors for diesel-powered industrial equipment (EPA, 1985b).  The emission factors for pound of pollutant per hour of operation were multiplied by the annual hours of operation for all three generators (65 hour per year estimated by CSSA) to calculate the following annual emissions:

Hydrocarbon (HC) = 0.005 ton/year (tpy)

Carbon monoxide (CO) = 0.014 tpy

Nitrogen oxides (NOx) = 0.065 tpy

Sulfur oxides (SO2) = 0.004 tpy

Aldehydes = 0.001 tpy

Particulate = 0.005 tpy

There are five boilers at CSSA, two of which are not in use.  They are located in buildings 46, 89, A-100, and 201.  Two are fired on diesel fuel (#2 fuel oil), and three are fired with natural gas.  Combustion emissions from the boilers are presented in Table 7.

Vehicle operations associated with CSSA consist of operation of passenger vehicles on the facility by base personnel.  Emissions from these activities are considered minor and cause only minimal and temporary impacts to air quality.

Painting operations are performed at CSSA as part of routine maintenance (e.g., lawnmowers, buildings, igloo doors, and road stripes).  The painting of equipment such as lawnmowers is done in a spray paint booth.  The booth acts to capture particulates (the solids part of the coating) from overspray.  To calculate VOC emissions, usage information was provided by CSSA, and VOC content and densities were provided by a Sherman Williams sales representative and AP-42 (table 4.2.1-1 VOC emission factors for uncontrolled surface coatings, and table 4.2.1-2 typical densities and solids contents of coatings) (EPA, 1985b).  Annual VOC emissions from painting operations were calculated to be 0.261 tpy.  It should be noted that particulate emissions generated by overspray in the paint booth were not calculated because CSSA was able to specify only the total volume of paint used in 1992.  Ed Renk of CSSA indicated that the painter does mostly hand painting and very little spraying.

There are volatile organic fugitive emissions from solvent weapons cleaning and preservation in building 90.  Sources are two solvent degreasers, one vapor degreaser, five hand-carried solvent trays, and tanks in the preservative line.  These tasks consist of two solvent tanks, one fingerprint remover tank, one light-weight lube oil tank, and one heated volatile corrosion inhibitor (VCI) tank (photo 28 and photo 29, appendix A).  All of the tanks have covers that are in place when the tanks are not in use.  The tanks are in use 6 hours per day, 2 days per week, 52 weeks per year.  In addition, the five hand-carried solvent trays are stored in two small tanks when not in use.  The had carried solvent trays are used 4 hours per day, 5 days per week, 52 weeks per year.  Emissions from all tanks and trays were calculated using exposed surface area, hours of operation (hours the surface is exposed), percent volatile by volume, and emission factors from AP-42 (table 4.6-2 solvent loss emission factors for degreasing operations) (EPA, 1985b).  Emissions from these tanks have been calculated to be:

Four solvent tanks = 1.498 tpy

Vapor degreaser = 1.01 tpy

VCI tank = 0.056 tpy

Fingerprint remover tank = 0.244 tpy

Light-weight lube oil tank = 0.0 tpy

Five hand-carried solvent trays = 0.212 tpy

It should be noted that the lube oil is zero percent volatile by volume and has a vapor pressure of <0.01 millimeters of mercury (mm Hg).  Also, the four solvent tanks include the two solvent tanks in the preservation line.

In addition, 0.011 tpy VOC is emitted from the use of one gallon per month of cleaner lubricant protectant (CLP), assuming all solvent in the CLP is emitted.

The bluing shop contains ten tanks.  All of the tanks are covered when not in use.  Three of the tanks that contained nickel penetrate are now empty.  Three tanks are rinse tanks and contain water.  One tank contains an oil preservative that is zero percent by volume and has a vapor pressure of <0.01 mm Hg.  One heated tank contains a soap cleaner (Unikleen 3D at 180 degrees F to 212 degrees F) that is zero percent volatile.  Another heated tank contains nickel penetrate (285 to 310 degrees F) which is also zero percent by volume.  There are no emissions from any of these tanks.  Emissions from the acid rinse tank are calculated via mass balance to be 0.285 tpy hydrochloric acid.

Particulate emissions from a Silverado sand blaster, a Wheelabrator steel shot blaster, a steel abrasive tumbler, and a glass bead tumbler (not in use) could not be estimated since CSSA has no sand or steel shot usage records and because emission factors for these units have not yet been developed by EPA.  EPA's Control Technology Centers expects to have emission factors and a descriptive writeup for grit-blasting sources available in May 1993.  The CSSA grit-blasting units are described further in Table 8.

From sand usage information provided by CSSA particulate emissions from the weapons firing chamber are determined to be 11.138 tpy.

3.8  Noise

3.8.1  Terminology

Physically, sound pressure (Lp) magnitude is measured and quantified using a logarithmic ratio of pressures whose scale gives the level of sound in decibels (dB).  Because the human hearing system is not equally sensitive to sound at all frequencies, a frequency-dependent adjustment called A-weighting has been devised to measure sound in a manner similar to the way the human hearing system responds.  The A-weighted sound level is expressed in "dBA" or "dB(A)."  Figure 12 provides typical A-weighted noise levels measures for various sources and responses of people to these levels.

When sound levels are measured at distinct intervals over a period of time, they indicate the statistical distribution of the overall sound level in a community during that period.  The most common parameter associated with such measurements is the energy equivalent sound level (Leq).  Leq is a single-number noise descriptor representing the average sound level in a real environment, where the actual noise level varies with time.  Leq is the same as Lp if sound levels do not vary during a measurement period.

Several methods have been devised to relate noise exposure over time to community response.  EPA has developed the day-night average sound level (DNL) as the rating method to describe long-term annoyance from environmental noise.  DNL is similar to a 24-hour Leq A-weighted level.  The DNL has a 10-dB penalty for nighttime (10 p.m. to 7 a.m.) sound levels to account for the increased annoyance that is generally felt during normal sleep hours.

The US Army uses a C-frequency weighting (C-weighted day-night sound level) for evaluating high-energy impulsive sounds from large weapons fire (artillery, armor, demolition, etc.).  All other noise not meeting the criteria for high-energy impulsive sounds are to be assessed using the A-weighted level and DNL (Army, 1990b).

Installations may be required by AR 200-1 to have an installation compatible use zone (ICUZ) program as part of the long-range land use planning.  An ICUZ study consists of preparing noise zone maps of the installation's existing and future noise environment.  This includes identification of existing and potential incompatible land uses, as well as identification of desirable land uses within zones II and III.

According to AR 200-1, ICUZ zone I is acceptable (A-weighted level of <65 dB; C-weighted (<62dB), zone II is normally unacceptable (A-weighted level of 65-75 dB; C-weighted level of 62-70dB), and zone III is unacceptable (A-weighted level of >75 dB: C-weighted level of >70 dB).

3.8.2  Setting

As described in the previous sections, activities at CSSA have varied since the early 1900s.  Prior to April 1987, a main noise source at CSSA was detonation and demolition operations, and the test firing of various ammunition components at the two firing areas.  These operations occurred at the north and east end of CSSA (north and east pastures).

Rifle ranges at CSSA typically generate noise levels in excess of 140 dB(Lp).  It is estimated these areas would be classified as zone III of the ICUZ noise zone.

The main noise source currently generated at CSSA is firing operations on the East Range.  These firing operations use small arms ammunition, grenades, small rockets (less than 66 millimeters), mines, pyrotechnics, and demolition items used during testing and training activities (Oliver, 1993).  Other sources of noise are civilian and military vehicle traffic in the cantonment and training areas of the post, and aircraft flyovers from San Antonio International Airport (SAIA) and the C-130s which operate at the combat assault landing airstrip at Camp Bullis (ES, 1992h).

The noise-generating activities such as the firing ranges and explosion of grenades are routinely performed at CSSA and can be particularly noisy.  Some training areas at Camp Stanley have firing activities similar to those at Camp Bullis.  The training areas at Camp Bullis exhibit noise levels ranging from 55 dBA to 75 dBA (ES, 1992h).  However, these activities on CSSA are performed on an intermittent basis and are isolated from sensitive areas at both posts.

Noise complaints from local citizens living near CSSA have not been filed with the post since the detonation and demolition operations ceased in April 1987.  Since noise-generating activities are intermittent, it is expected that most areas at CSSA exhibit noise levels less than 55 dBA where ranges are not in use, which is normally accepted by the public without complaints.  Existing noise levels near the cantonment area should be typical of a light commercial or industrial area, which is about 65 dBA.

The closest residential location off post is south of the installation and approximately one and a half miles away.  Typical residential areas have an existing DNL of approximately 60 dBA.  The seven houses on CSSA where personnel and their families live are located on the west side of the cantonment area.

CSSA also has an indoor firing range located in building 90 to test-fire weapons after maintenance.  This area is equipped with sound-proofing.

3.9  Utilities

3.9.1  Potable Water

Five groundwater wells can be used to supply potable water for CSSA.  These are wells 9, 10, and 11 on the west-central side of CSSA, well 1 just southeast of CSSA in Camp Bullis, and well 16 in the northeast corner of the inner cantonment.  Wells 9 and 10 are currently used on a regular basis.  Well 11 has not been used for the last 4 years because it cannot be pumped for more than 30 minutes before going dry.  Well 1 is essentially a backup.  Well 16 previously supplied water but has been withdrawn from service pending an investigation of a contamination source which has led to maximum contaminant level (MCL) exceedances of several organic chemicals.

Pressure and storage for the system is maintained by a 56,00-gallon reservoir located on a high hill on the west side of CSSA amid wells 9, 10, and 11.  According to the CSSA water operator, each well pumps at an initial rate of approximately 100 gallons per minute (gpm), with a drop to 70 gpm after prolonged pumping.  When operating, the wells typically are pumped for 24 hours to fill the reservoir.  Water from wells 9, 10, and 11 is chlorinated in building 54, which houses a 3-horsepower booster pump and two 150-pound chlorine tanks.

The reservoir is concrete and is buried in the top of the hill with the top cover exposed.  According to the operator, static pressure is 50 pounds per square inch (psi).  A small booster pump and hydrotank in building 20 supply water at adequate pressure and quantity to the headquarters, which is at an elevation just below the reservoir.  Two 5-horsepower booster pumps and a hydrotank with an estimated capacity of 3,000 gallons in building 74 provide adequate pressure and supply to the housing area.

According to the most recent comprehensive water distribution system plans, dated January 1972, the water distribution system is composed of the following approximate quantities of cast iron pipe:

Pipe size (inches)

Quantity (linear feet)

















Fire hydrants are located in the building areas and in areas away from buildings.  Fire truck fill spouts are connected directly to mains at strategic locations away from the developed areas to permit control of grass and brush fires.

Copper pipes are used in all CSSA buildings, and repairs have been made with a 50/50 solder composed of lead and copper.

Well pump records for the years 1987 through 1990 were reviewed for usage.  For the most recent year records were available, 1990, average monthly usage was 1,276,652 gallons.  Per capita domestic water use is generally approximately 100 gallons per day for residents and 50 gpd for transient population.  For the CSSA staff of 120, most of which is present only during work hours, per capita use was approximately 350 gpd.  This value is therefore elevated, indicating losses in the distribution system which recently have been repaired.  Occasionally water is used to fill stock ponds.

Two water quality reports from 1987 and 1990 by the Texas Department of Health (TDH) were reviewed (appendix G).  Given MCL drinking water standards available at the time of the reports, these tests showed no excessive or harmful concentrations for the constituents tested.  In addition, CSSA routinely tests the system in compliance with current regulations.

3.9.2  Wastewater Treatment

Domestic wastewater from CSSA is treated at a facility operating pursuant to the conditions of TWC permit 12111-01 effective June 22, 1991 (appendix H), and National Pollutant Discharge Elimination System (NPDES) permit TX0064505, effective October 25, 1990 (appendix I).  The TWC permit authorizes a discharge of 0.03 mgd containing no more, on a daily average basis, than 20 mg/l of 5-day biochemical oxygen demand (BOD5) and 20 mg/l of total suspended solids (TSS).  Dissolved oxygen (DO) must be a minimum of 2.0 mg/l on a daily average basis.  The conditions of the NPDES permit are similar.

The TWC permit includes other provisions which require the following:  lined evaporation pond(s) for industrial waste from the metal parts treatment process; facilitieis to transport all industrial wastewater from the metal parts treatment facility to the evaporation pond(s); no discharge of industrial wastewater to waters of the state; no treatment of industrial wastewater from the metal parts treatment facility in the domestic wastewater treatment plant; and specific authorization from the TWC executive director for treatment of any wastes in the domestic wastewater treatment plant different from normal domestic wastewater.

The wastewater treatment plant is located in the southwest portion of CSSA with a discharge through a 400-foot pipe to a tributary of Leon Creek at the southern boundary of CSSA (Figure 6).  A trailer park is located directly south of CSSA along this tributary.  The treatment plant consists of a manually cleaned bar screen, two Imhoff tanks operating in parallel, a trickling filter, a chlorine contact chamber, and a sludge drying bed (photo 30 and photo 31, appendix A).  The design capacity of the plant is 0.15 mgd.

The most recent TWC inspection on February 20, 1991, found no major operation and maintenance deficiencies aside from the existence of a pipe from the sludge drying bed to the effluent manhole (appendix J).  The CSSA plant operator indicated that this pipe has been plugged.  The Plant was renovated during the fall of 1990.

The inspection report also indicated that a small quantity of wastewater from the metal parts treatment facility discharged into the treatment plant in June 1990, but that no permit violations occurred as a result of this discharge.  Additional documents indicated that CSSA personnel were disposing of the wastewater in accordance with past accepted practices and were unaware that the discharge was not authorized by the current permit.

Approximately 600 gallons of sludge is drained into the drying bed each month.  The drying bed is approximately 1,500 square feet surrounded by a 2-foot wall, and dried sludge has never been removed because only small quantities were generated.  When the sludge is eventually disposed, it will be placed in landscaping areas at CSSA.  Given the small quantities of sludge compared to the volume of drying bed, dried sludge will probably not require removal for several years.

Discharge for the 1991 calendar year averaged 0.012 mgd, ranging from a low of 0.0017 mgd in March to a high of 0.041 mgd in December.  High discharges continued for the first 4 months of 1992.  During the period from December 1991 through April 1992, rainfall in the area was almost 37 inches.  The occurrence of high discharges in association with high rainfall indicates the probability of substantial infiltration into the wastewater collection lines.

A review of self-reporting data indicates that the wastewater treatment plant consistently produces high-quality effluent exceeding permit requirements.

Two septic tanks are shown on the 1972 sanitary sewer detail amps within Leon Creek watershed and six are shown within the Salado Creek watershed.  According to the CSSA plumber, only three of these are operational, all within the Salado Creek watershed.  The developed portions of CSSA that generate domestic wastewater within the Salado Creek watershed discharge wastewater to these three septic tanks with associated leach fields (Figure 6).

The first septic tank and leach field is located near building 201.  An oil-burning boiler is located in this building and water containing sediment and rust from the boiler is discharged to the leach field.  The boiler provides steam for hearing building 200.  According to the CSSA plumber, only boiler water from building 201 drains into this septic tank.  This leach field appears to be operating normally and is appropriately sited.

The second leach field is located east of buildings 45 and 46 and takes domestic waste from building 45 and periodic (approximately quarterly) small amounts of water through a sump from an oil-burning boiler located in building 46.Building 45 contains several commodes and lavatories, a sink, and a kitchen area, and is heated by the building 46 boiler.  Daily discharges of small amounts of water containing sediment and rust from the boiler flow through a second sump in building 46 to the roadside ditch along Moyer Road.  The ditch is stained by this discharge.  There are trees growing in this leach field and the pipe from the solids tank to the leach field is broken (photo 32, appendix A).  Therefore, no wastewater is flowing to the leach field at this time.  In addition, this leach field appears to be sited in the floodplain of Salado Creek.

The third leach field is located in the streambed of a tributary of Salado Creek east of Central Road downstream of the motor pool.  Sewage from buildings 4, 5, 27, 38, and 44 drains into this leach field along with washwater from the washrack at the motor pool.  A surface investigation of the solids tank and leach field area showed no apparent problems.  However, an old sewer line is laid in the bed of the tributary of Salado Creek extending downstream as far as Moyer Road.  This line was exposed approximately 1,000 feet downstream of the leach field and contained water in a broken section of pipe (photo 33, appendix A).  Dye tests by CSSA personnel have demonstrated that this line is carrying wastewater that should be flowing into the septic tank and dispersed within its associated leach field.  Therefore, it appears that the leach field is not operating properly and may be inappropriately sited.  The means by which sewage flows into this old line is unknown, since it should not be connected to the septic tank or the inlet line to the septic tank.

Two vehicle maintenance pits with drains are located at CSSA.  The first is in building 4, the motor pool, and drains directly into the ground underneath the building (photo 34, appendix A).  Apparently, these drains and the sump are not connected to the wastewater treatment plant but drain into a tributary to Leon Creek.

There are other building drains that route water from the interior of the buildings to the outside, either to the wastewater collection system or to the ground outside the buildings.

Based on the most recent comprehensive wastewater collection system plans dated January 1972, the wastewater collection system is composed of approximately 8,760 linear feet of 6-inch vitrified clay pipe (VCP) and 6,140 linear feet of 8-inch VCP.  As of the writing of this report, CSSA personnel were in the process of replacing approximately 2,490 feet of 6-inch vitrified clay pipe with polyvinyl chloride pipe.

3.9.3  Electric Power

Electricity is supplied by City Public Service of San Antonio.  For the most recent calendar year, 1991, monthly electricity usage averaged 185,100 kilowatt-hours (kWh).  Usage for the first 9 months of 1992 is comparable to 1991 usage during the same time period.

CSSA has four backup generators.  The first generator has a capacity of 30 kWh.  A 50-gallon diesel fiel tank is sited underneath the generator, and the generator is started once a week to check its working condition.  This generator provides backup for the security area. 

The second generator has a capacity of 500 kWh and provides backup for the entire base.  Its operation is checked once every week.  A 500-gallon diesel fuel tank for the generator is located in the fill above the building in which the generator is located.

The third generator provides backup for the housing area.  Its capacity is 30 kWh and a 50-gallon diesel fuel tank is located beneath the generator.  This generator is not operated on a regular basis.

The fourth generator provides backup power for the radios and communication equipment.  It has a 5 kWh capacity and is operated weekly.  A 9-gallon diesel fuel tank is located beneath the generator.

3.9.4  Natural Gas

Natural gas is supplied by Grey Forest Utilities.  For the most recent complete calendar year, 1991, monthly gas usage averaged 5,782 ccf (centicubic feet, or 100 cubic feet).  For the first 10 months of 1992, monthly usage averaged 3,686 ccf.  For the same period of 1991, monthly usage averaged 4,900 ccf.  CSSA personnel indicated that a number of leaks have been repaired over the last year and that a dehumidifier which was a substantial gas consumer has been taken out of service.