Environmental Assessment
Section 4 - Environmental Consequences and Regulatory Compliance
Soils at CSSA tend to be thin (nonexistent to less than 1 foot deep) on hills and somewhat thicker in stream valleys (1 to 4 feet deep). Regardless of location or thickness, the soils can be affected by three primary means: chemical spills or other releases from the surface; erosion by wind, surface runoff, or human actions; and reduction of arable soils through chemical effects or erosion.
Areas of known chemical constituents on surface soils are found at the previous hazardous waste F-14 storage area where 1,1,1-trichloroethane was detected in aboveground berm soils, at the bluing process area (building 90-1) and isolated piles in the quarry and southeast of the engineer dump where solidified nickel penetrate was observed. These areas are limited in extent and can be addressed by removal and proper disposal of the affected soils. It is recommended that closure plans for the F-14 site and bluing process area be submitted for regulatory approval and that approved actions be implemented for site closure.
Erosion of soils can be found in stream valleys and on rock outcrops. This erosion is a function of the topography and lithology of the area. Areas that have been significantly impacted by natural erosion are along the Salado Creek channel that runs northwest-southeast through the inner cantonment. In particular, a flood in 1991 eroded soils at the north inner cantonment roadway and washed away inner cantonment fences located along the Salado Creek channel. Potential for soil erosion in flood-prone areas be reduced with divertment areas, soil furrowing, and establishment of native grasses whenever possible. Soil erosion along lesser tributaries is less significant but can also be reduced by cultivation of native vegetation. One other area of concern is the SWMU (B-28) west of and topographically below the oxidation pond in the northeast inner cantonment. This area is susceptible to soil and rock erosion, and should also be evaluated for possible installation of ditches that will drain away from the area to prevent undermining of the layers below B-28 and the oxidation pond.
There are few arable soil areas at CSSA, and these are not affected by natural or human action at this time. No mitigation measures are recommended with regard to environmental consequences to the arable soil areas.
The physiography of CSSA has been slightly altered only at a surface level by human actions. These actions include excavating for quarries and storage areas. There are no regulatory compliance actions for physiography, nor do there appear to be significant environmental consequences from such slight alteration of the area's topography.
Geology, like soils, can be affected by chemical spills or erosion. There have been no man-made changes in lithology, stratigraphy, or structure at CSSA, nor has erosion significantly altered the geology. There are, however, natural fractures and sinkholes known in the CSSA area. The geologic strata can be affected by releases to the surface and subsurface; e.g., the strata in areas of chemical releases have constituents in the rocks not found under natural conditions.
Subsurface strata at the previous hazardous waste F-14 storage area were found to contain total petroleum hydrocarbons (TPH) and nickel during an assessment of site conditions (ES, 1992g). It is unknown if the constituent levels are close to background levels that would be found in rock potentially unaffected by storage actions. If the F-14 site and background levels are similar, or if the F-14 site levels of TPH and nickel are less than background, the data can be submitted as requiring no further action. If the F-14 levels are substantially above background and above the target cleanup levels, then those rock strata should be excavated and disposed of or treated to below cleanup criteria levels.
Known areas of chemical releases to geologic strata including five leaking tank sites. TPH and the fuel product additives lead, methyl tertiary butyl ether (MTBE), and benzene, toluene, ethyl benzene, and xylenes (BTEX) have been detected in subsurface soils and rocks at one tank site (which includes tanks 3, 4, and 6). TPH and BTEX were also detected at each of the other four tank sites (tanks, 7, 13, 18, and 19). The extent of contamination is not known at these sites. After this has been determined, it is recommended that the subsurface soils and rocks be remediated to approved target cleanup levels so as to decrease risks to potential receptors and limit environmental consequences.
There are currently no identified industrial activities or operations at CSSA which would require a storm water discharge permit from the EPA. If, however, CSSA operations change or if future phases of storm water regulations have more stringent requirements, storm water discharge permits may be required.
All of the dams at CSSA are in excess of 6 feet in height, but contain less than 200 acre-feet of water. The height of the dams subjects these structures to design criteria of the TWC, but the volume of the reservoirs exempts the structures from specific approval requirements. These dams, in particular spillways, must be designed in accordance with the regulations of TWC, but specific approval from TWC is not required (Lowe, 1992) (appendix B). These structures should be reviewed to assure that the designs, particularly the spillways, are in accordance with current legislation and regulations: Vernon's Texas Code Annotated 12.052, Water Code, and 31 Texas Administrative Code (TAC) 299, dams and reservoirs.
There are no known significant impacts on surface water quality from the current CSSA operations other than those areas covered under the wastewater treatment discussion (section 4.9.2).
Effects to groundwater hydrology are predominantly inferred from evaluation of water well data for changes in static water levels, groundwater chemistry, and concentrations of chemical constituents. Changes in water level measurements can be related to recharge or effects of increased pumping. Changes in groundwater chemistry can indicate an influx of chemical constituents to the aquifer.
Water wells at CSSA were assessed in a preliminary evaluation of groundwater contamination (ES, 1993) (photo 36, appendix A). Water well locations are shown in Figure 5. In summary, the groundwater hydrology did not appear to be affected by regional pumping, recharge from the surface appears to take place over weeks and months instead of years, and the groundwater chemistry did not significantly vary over a period of 6 years (ES, 1993). However, groundwater contamination from halogenated volatile organics was detected in four separate sampling and analytical events.
During a site visit for routine pesticide screening of water wells on August 9, 1991, the Texas Department of Health (TDH) sampled water supply well 16, which is located along the northern inner cantonment boundary. Analytical results revealed the sample contained 127 micrograms per liter (ug/L) cis- and trans-1,2-dichloroethene (DCE), 151 ug/L trichloroethene (TCE), and 137 ug/L tetrachloroethene (PCE). These concentrations were above the MCL drinking water standards of 70 ug/L for DCE, 5 ug/L TCE, and 5 ug/L PCE. Subsequent sampling on August 23, 1991, confirmed the earlier results. TDH required that CSSA take the well out of service and notify previous well users.
TWC personnel collected samples on December 4, 1991, from well 16 and from two inactive wells (wells D and 4). Well 16 continued to show concentrations of DCE, TCE, and PCE above corresponding MCLs. Inactive well D, located approximately 400 feet west of well 16, contained a DCE concentration above the analytical detection limit but below the drinking water standard.
During November 1992, ES personnel collected water samples from accessible wells (ten of the nineteen CSSA wells). The water samples were analyzed in accordance with EPA method SW8010. Laboratory analysis disclosed TCE and PCE concentrations below corresponding MCLs in wells 2, 3, and 4. Wells D and 16 contained TCE and PCE concentrations up to 53 ug/L, which were above MCLs. Other inactive wells did not contain halogenated compounds. The extent of groundwater contamination is not known.
The preliminary evaluation was completed, and a hydrogeology report (ES, 1993) and three plans of action to assess the problem were submitted to CSSA and AL/OEB. At this time, CSSA is not under a regulatory order to assess the problem but has recognized the need for further evaluation and remediation of the problem as necessary and has been in communication with the EPA and the TWC.
The above assessments demonstrate that the drinking water aquifer at CSSA has been affected by concentrations of chemical constituents detected above MCLs. It is recommended that groundwater contamination be evaluated with respect to the contaminant plume extent and potential source areas. The contamination plume will require remediation to drinking water standards and monitoring to determine further contaminant migration and remedial effectiveness.
Groundwater at CSSA is known to have been affected by halogenated volatile organics in the drinking water aquifer near well 16. These chemical constituents should be removed to levels at or below drinking water standards. However, after well 16 was removed from service, the remaining drinking water wells (1, 9, 10, and 11) were found to supply water that meets drinking water standards.
In uncontaminated areas, the quality of groundwater pumped from drinking water wells appears to be consistent with a limestone aquifer source. The groundwater is slightly higher in calcium and carbonate-bicarbonate ions, as is expected, and TDS concentrations are within standard ranges for drinking water. Therefore, the quality of the pumped water meets state and federal regulations for drinking water except in areas of the aquifer affected by halogenated volatile organics (near well 16).
Measures recommended to protect groundwater quality at this time include remediation of the groundwater in contaminated areas as well as upgrading or closure of wells to meet current regulations. Current specifications for upgrading or plugging wells are outlined in the Texas Water Well Drillers Board (TWWDB) "Permanent Rule Changes," 31 TAC chapter 287 (appendix K) and the Texas rules and regulations for public water systems, 31 TAC 290.38-290.41 (appendix L). Potential upgrading and plugging for each of CSSA's nineteen water wells is discussed in the ES hydrogeology report for CSSA (ES, 1993).
Among several significant and interrelated documents which affect land use decisions at CSSA are the federal Endangered Species Act (ESA), the Department of Defense Legacy Program, the cooperative agreement between the DoD and The Nature Conservancy (TNC), and AR 420-74 (natural resources: land, forest, and wildlife management).
Section 7 (interagency cooperation) of the ESA, enacted in 1973 (amended 1982 and 1987), requires that "any action authorized, intended or carried out by" any federal agency which could affect endangered species (or their habitat) must be preceded by communication with the USFWS relative to the nature of the action and its potential impact (appendix C).
The Legacy Resource Management Program, established by Congress in 1991, is intended to direct and facilitate the "integration of the conservation of irreplaceable biological, cultural, and geophysical resources into the DoD's military mission" (appendix C).
The cooperative agreement between DoD and TNC, "establishes a policy of cooperation and coordination to identify, document and maintain biological diversity on DoD installations" (appendix C).
AR 420-74 (natural resources: land, forest, and wildlife management) includes among its objectives the protection of ecological relationships, wildlife, and wildlife habitat, especially endangered or threatened species and environmentally sensitive areas. It also calls for inventory and classification of resources present at the installations and an assessment of their status with an emphasis on endangered, threatened, and indigenous species.
This site's habitat condition relative to native biodiversity in this part of the Edwards Plateau is poor compared to its natural potential, but it is somewhat typical of much of this region at the present time and is likely to provide habitat for most common local vertebrates. Current management is appropriate for the livestock and game management objectives. However, this type of management is not favorable for sustaining the full array of biota native to this area, particularly those species requiring larger blocks of relatively undisturbed or mature woodland and those associated with undisturbed seeps, springs, and drainages.
Range site condition should be formally evaluated in conjunction with the Department of Agriculture and documented on a periodic basis (intervals not to exceed 10 years) following AR 420-74 guidance so that range management initiatives can be adequately evaluated and adjusted as appropriate.
Photodocumentation points or permanent vegetation and wildlife monitoring transects should be established to facilitate long-term site condition and trend analysis.
The overall range condition for domestic animals ranges from fair to poor across the property. Stocking rates are adjusted annually by USDA-ARC to prevent overgrazing and the current stocking rate is very low because of current reduced research needs (Shelley, 1992).
Land management at CSSA should be done in line with the Legacy Program. Such an undertaking should be compatible with the military mission of the site and with its livestock research and hunting recreation program objectives, while at the same time satisfying the various broader federal natural resources protection and management mandates.
All areas which have been identified as potential habitat for endangered or threatened species should be protected from any alteration in land use or further vegetation, stream, or soil manipulation until such time as actual use by the target species can be assessed. This endangered bird species inventory work is scheduled to begin March 1993.
All areas where sinkholes, wells, or other connections to subsurface water supplies and caves occur should be protected from disturbance, and remediation measures should be undertaken to address any possible contamination of groundwater on the site (photo 37, appendix A).
Since the 1940s, various portions of the north pasture at CSSA had been used for "demil" (demilitarization) activities (munitions burning) and testing. This activity was discontinued April 30, 1987 (Oliver, 1993), following complaints of "shaking" houses from Fair Oaks subdivision to the west. Because of increasing urbanization, especially to the west of CSSA, future demil of large munitions is not planned for the installation. CSSA currently transports unusable munitions to Red River Army Depot for destruction.
At the present time, there are no noise impacts associated with CSSA activities which would be incompatible with advancing urbanization near CSSA.
In cultural resources surveys at Camp Bullis and others performed in the vicinity of CSSA, numerous findings of prehistoric and historic sites indicate that there is high potential for similar archaeological sites to occur on the CSSA installation. The preliminary survey performed for this EA showed that such sites are present at CSSA. Because CSSA is a restricted-access installation , the potential for disturbance of these sites by relic collectors is low. However, a systemized cultural resources survey needs to be conducted prior to further land disturbance by CSSA (e.g., bulldozing) so that all site locations of prehistoric and historic significance can be determined.
Camp Bullis and surrounding areas also have been investigated for the presence of endangered species (birds). CSSA has some areas of potential habitat to endangered species and is currently conducting a detailed survey.
Once specific areas have been delineated for cultural resources and endangered species, a land use management plan can be developed to identify, preserve, and enhance these areas. In addition, when future environmental assessments and impact statements need to be developed to address installation modifications or construction, the plan can be used to summarize required information.
CSSA has a soil and water conservation plan which sets forth grazing criteria and methods for conservation of rangeland. CSSA should follow the guidelines of AR 420-74 in the area of a land, forest, and wildlife management plan to comply with environmental protection and enhancement policies and procedures as outlined in AR 200-1.
Because of land disturbance events which have occurred for the past 150 years on the land where CSSA is located, most disturbance-sensitive biological species no longer occur. However, the sensitive biotic elements which do occur on CSSA and surrounding land are subject to impact, positive or negative, by CSSA activities.
CSSA serves as a buffer zone between Camp Bullis and the expanding residential development to the west of the site. CSSA is also a sensitive transition zone between a rural landscape, to the north, and an urban landscape, to the south and advancing to the west and northwest of CSSA.
Activities which reduce woodland fragmentation, restore natural landscape cover types, and minimize impacts to drainage features would tend to improve habitats for terrestrial species. Such activities could also improve the effectiveness of the site as a protective buffer for Camp Bullis' species recovery and site improvement efforts and could indirectly augment species recovery and maintenance efforts at nearby Friedrich Wilderness Park (2.5 miles south of CSSA).
CSSA, Camp Bullis, and Government Canyon (20 miles to the west of CSSA) may soon be the only areas in Bexar County where biological aspects of the Texas Hill Country can remain relatively protected. Neither Eisenhower Park (4 miles southeast of CSSA) nor Friedrich Wilderness Park, although currently important, are of adequate size or quality to sustain functional canyonlands ecosystems in the face of urban expansion.
CSSA lies in the recharge zone of the Glen Rose aquifer and the drainage zone of the Edwards aquifer. Additionally, the site is cut by two minor divides and contributes surface drainage to Cibolo, Salado, and Leon Creeks which in turn feed into the Guadalupe and San Antonio River watersheds. Future developments may be slowed in this area by growth restrictions over the Edwards aquifer recharge zone (Army 1991).
There are currently no known Superfund sites at or within 1 mile of CSSA.
Numerous laws and regulations require federal agencies to consider the effects of projects on cultural resources. These laws and regulations stipulate a process for compliance, define the responsibilities of the federal agency proposing the action, and prescribe the relationship among other involved agencies. The following regulations are applicable to consideration of historic and archaeological resources at CSSA:
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National Historic Preservation Act of 1966, as amended (Public Law 89-665: 16 USC 470-470w-6). Establishes historic preservation as a national policy and defines it as the protection, rehabilitation, restoration, and reconstruction of districts, sites, buildings, structures, and objects significant in American history, architecture, archaeology, or engineering. It also expands the National Register of Historic Places to include resources of state and local significance, and establishes the Advisory Council on Historic Preservation (ACHP). Section 106 provides direction for federal agencies for undertakings that affect properties listed, or eligible for listing, on the NRHP and is implemented by regulations issued by the ACHP (36 CFR 800). According to NHPA section 106, all structures and sites greater than 50 years of age must be evaluated in an environmental assessment. |
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National Environmental Policy Act of 1969 (Public Law 91-190; 42 USC 4321-4347). States the policy of the federal government to preserve historic, cultural, and natural aspects of our national heritage and requires consideration of environmental concerns during project planning and execution. |
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Archaeological and Historic Preservation Act of 1974 (Public Law 93-291; 16 USC 469-469c). Directs federal agencies to notify the Secretary of the Interior when they find that any federal construction project or federally licensed activity or program may cause irreparable loss or destruction of significant scientific, prehistorical, historical, or archaeological data. Also provides for funding historical and archaeological protection in such projects. |
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American Indian Religious Freedom Act of 1978 (Public Law 95-341; 42 USC 1996). |
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Archaeological Resources Protection Act of 1979 (Public Law 96-95; 16 USC 470aa-11). Prohibits the removal, sale, receipt, and interstate transportation of archaeological resources obtained illegally (without permits) from public or Indian lands, and authorizes agency permit procedures for investigations of archaeological resources on public lands under the agency's control. |
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National Register of Historic Places, 36 CFR Part 60. |
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Determinations of Eligibility for Inclusion in the National Register of Historic Places, 36 CFR Part 63. |
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The Secretary of the Interior's Standards for Historic Preservation Projects, 36 CFR Part 68. |
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Archaeological Resources Protection Act of 1979; Uniform regulations, 32 CFR Part 229. |
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Protection of Historic and Cultural Properties, 36 CFR Part 800. |
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Department of Defense Directive 4710.1, Archaeological and Historic Resource Management, 21 June 1984. |
Potential impacts were assessed by identifying types and possible locations of activities that could directly or indirectly affect cultural resources. Historic properties, under 36 CFR 800, are defined as "any prehistoric or historic district, site, building, structure, or object included in, or eligible for inclusion in, the NRHP. This term includes, for the purposes of these regulations, artifacts, records, and remains that are related to and located within such properties. The term "eligible for inclusion in the National Register" includes properties formally determined as such by the Secretary of the Interior and all other properties that meet National Register listing criteria." Therefore, sites not yet evaluated are considered potentially eligible for the NRHP and, as such, are afforded the same regulatory consideration as nominated historic properties.
As a federal agency, the Department of the Army is responsible for identifying historic properties on CSSA. This identification process employs not only field surveys and recording of cultural resources, but also evaluations to develop determinations of significance in terms of NRHP criteria. Completion of this process results in a listing of historic properties subject to federal regulations regarding the treatment of cultural resources.
Cultural resources within CSSA, including prehistoric and historic archaeological sites and standing structures, have been impacted by modern activities and by ground disturbances.
Cedar clearing operations, through the grazing and cedar clearing agreement between CSSA and the USDA-ARC, have had an effect on archaeological sites. In the past, cedar tree clearing was accomplished by felling trees with hand-held equipment. In recent years, however, tree clearing has been done by mechanical bulldozing. The bulldozing operations have created severe ground disturbances. In at least two locations visited in the field, the bulldozing operations have disturbed cultural resources (at the World War I era campsite and a ranch site, both located in the north pasture).
As CSSA is a secure facility, looting of archaeological sites has been generally diminished. However, over the years surface artifacts have been collected, diminishing the potential of sites for interpretation of prehistoric and historic activities.
There have been architectural modifications to some buildings at CSSA as a result of normal operations and expansion and changes in installation activities. These architectural modifications have altered the character of some buildings greater than 50 years in age (such as the administration building, photo 38, appendix A), and thus may affect the potential for their listing as historic buildings. In addition, some buildings have not been maintained and have deteriorated.
Since there has not been a cultural resources study performed on CSSA, and the potential for prehistoric and historic resources is high, a comprehensive archaeological and architectural survey should be performed to be in compliance with section 106 of the NHPA. The survey should identify the locations and existence of prehistoric and historic sites and standing structures. A comprehensive cultural resources survey would provide the initial information needed to support development of regional historic contexts to aid in determining the significance of the historic resources at CSSA. Once potentially significant sites are identified, future impacts can be minimized, and the potential effect of current ground disturbances on cultural resources can be assessed.
AR 200-1, section 6-1, defines the Army policy and procedures for managing solid waste. This document describes current solid waste management standards, but does not detail procedures for investigating and remediating inactive SWMUs. Historical operations at CSSA have left numerous inactive SWMUs. Current federal and state regulations require immediate investigation of only those SWMUs that are causing a release to groundwater, and those that the Texas Water Commission requires through an agreed order, a RCRA permit, or a compliance plan. However, all known SWMU locations must be documented and recorded with the TWC. All SWMUs that are slated to remain in place must additionally be deed recorded with the county tax assessor or appraisal district.
Investigating SWMUs before required by regulators to do so has the benefit of CSSA control over the schedule and details of investigation and remediation.
Currently, remediation and closure requirements to remove a SWMU from the facility records involve removing all waste and waste residues to background levels. If background cleanup levels cannot be attained, the SWMU remains on record and must be deed recorded. Proposed regulations will allow for risk-based closure cleanup standards. Either these proposed rules will be adopted by June 1993, or the proposed rules will be resubmitted for additional consideration.
CSSA can divide the SWMU investigations into a number of categories. The first category and highest priority will be to investigate the SWMUs in close proximity to well 16. The second group is any areas which include subsurface disposals (landfills, trenches, etc.). Any releases to the environment should be determined. The third group is SWMUs used for munitions burning on the surface. After a complete investigation, the SWMUs should be ranked in order of greatest risk to the environment, and remediation efforts should begin where a release to the environment has occurred.
Drains from the motor pool and locomotive shop pits were plugged during May 1993. The area which receives waste from the pits should be investigated and remediated, as necessary. These areas have received flow for many years and therefore are likely to have increased levels of oils and solvents in the soils.
Sand used at both the indoor and outdoor firing range (east pasture) could be sifted to separate the lead projectiles from the sand. The sand could then be reused at both locations, reducing the amount of material which requires solid waste disposal. In addition, the lead may also be reclaimed and reused.
AR 200-1, section 6-1, defines Army policy and procedures for managing hazardous waste. This document describes current hazardous waste management standards, and mandates compliance with applicable federal hazardous waste management and remediation regulations. CSSA has no known inactive hazardous waste management units; however, the facility does operate a hazardous waste container storage area. RCRA regulations detail the requirements for container storage of hazardous waste. The hazardous waste container storage areas at CSSA were neither designed nor operated and maintained in compliance with federal or TWC regulations. CSSA has taken immediate action to consolidate, upgrade, and designate the areas as hazardous waste storage areas of less than 90 days. In so doing, CSSA has provided secondary containment, improve record-keeping, labeling, etc. The following discussion covers a few of the SWMUs in which more detailed information was found.
During a December 1992 field investigation, a partial drum was discovered at the B-29 site. Upon further investigation and chemical analysis by CSSA (appendix E), the drum was determined to contain nickel penetrate waste. In addition, another drum was discovered behind the fire station (building 2), however analysis disclosed the substance to be high in TPH and determined to be tar. CSSA has contracted to have the waste removed and properly disposed of. It was observed that nickel penetrate spills have also occurred around buildings 90-1 and 90-2 identified as HW-2 area. Therefore, this area should be investigated and areas remediated as necessary. In addition, CSSA has operated for many years and isolated drums have been discovered across the facility, when drums or waste are discovered, these areas should be investigated and remediated as necessary. Hazardous waste generated in association with cleanup activities must be managed on a case-by-case basis complying with all applicable regulations.
The oxidation pond (O-1) was put into service in approximately 1975 to hold solids and washwater from the bluing process. Waste liquids and sludges are collected in a tank adjacent to the bluing shop and hauled out to the oxidation pond. This pond was permitted under the predecessor of TWC, the Texas Department of Water Resources (TDWR). An inspection on September 16, 1980, reported that industrial wastes consisting of sodium hydroxide, hydrochloric acid, and perchloroethylene from the bluing and weapon reprocessing are stored in a lined pond on site (TDWR, 1980). The life expectancy of the vinyl liner was 10 years. The Texas Department of Health inspected the pond several times from 1982 to 1984.
At the request of the TDH, a sample of the top liquid and bottom sludge was taken to Brooks AFB laboratory on April 20, 1984, and tested for metals. In a letter dated June 15, 1984, the TDH, which had regulatory authority for solid waste at that time, determined that CSSA was in violation of state regulations. The TDH requested that CSSA make a waste determination of the pond's wastes, keep inspection logs and maintain proper records. In August 1985, RRAD prepared a closure plan for the evaporation pond. In the fall of 1985, the evaporation pond was filled in with dirt with the liner in place. It is not known if liquids or sludges were removed from the pond prior to being filled with dirt. Parts of the liner are visible on the surface, and it is highly probable the liner's integrity was compromised. Appendix E includes a history of the evaporation pond. All other identifiable SWMUs are listed on map 1 and described in Table 1.
A hazardous waste inspection of the CSSA was conducted on May 17, 1985, by TDH. The inspection concluded that management of hazardous waste activities was in general compliance with the requirements of subchapter L.
Hazardous materials and pesticide use and management are regulated under the Toxic Substance Control Act; Department of Transportation regulations; the Occupational Safety and Health Administration; the federal Insecticide, Fungicide, and Rodenticide Act; state-implemented regulations; and AR 200-1. These require proper labeling , handling, and inventory reporting of hazardous materials, including pesticides. AR 200-1, section 5-9(b), specifically requires that "Storage facilities for chemicals hazardous to health and welfare and detrimental to the environment will be constructed and operated per 29 CFR part 1910, other applicable regulations, and DoD manual 4145.19M2.
While these regulations do not specify materials management units with the exception of fire suppression systems, the scattered storage of these materials increases the potential for a spill or release to the environment. A spill or release will lead to a costly investigation and cleanup effort.
A spill prevention, control, and countermeasures (SPCC) plan and a contingency plan is required of certain facilities under Title 40 Code of Federal Regulations parts 112 and 264 (or 265). In addition, the plan should also meet applicable state guidelines for management of oil and hazardous substance spills.
Regulations under 40 CFR 112 require that an onshore nontransport-related facility that may reasonably be expected to discharge oil into the navigable waters of the United States prepare and implement an SPCC plan. Certain facilities are exempt from the SPCC plan requirement based on facility oil storage capacity. Such exempt facilities are those that have underground storage capacity of 42,000 gallons or less and aboveground storage capacity of 1,320 gallons or less, provided no single aboveground storage container capacity exceeds 660 gallons.
The facility SPCC plan should describe equipment, processes, and operations at the facility that may pose a threat of oil discharge. The plan should also describe structures, procedures, policies, and programs for safety standards, pollution and fire prevention. The plan must be certified by a registered professional engineer who has examined the facility and is familiar with the applicable regulations.
Furthermore, 40 CFR 264 (or 265), subparts C and D require that owners and operators of hazardous waste treatment storage disposal (TSD) facilities must prepare an emergency contingency plan describing equipment, procedures, and programs to minimize emergency situations such as fire, explosion or hazardous substance release, and to respond to any emergencies that may occur. The facilities that are exempt from the TSD permitting requirements because of the less-than-90-day storage exemption (40 CFR 262.34) are also required to prepare and implement the emergency contingency plan40 CFR 264.34(a)(4). The contingency plan may be incorporated into the facility SPCC plan as one single document. A stand-alone contingency plan does not require certification by a professional engineer. However, the plan must be distributed to the local emergency response agencies with whom the facility has agreements to respond to emergency situations at the facility.
The SPCC plan and contingency plan also establish specific notification and reporting procedures and training programs based on the requirements of 40 CFR 117 and 302, and 29 CFR 1910.120. The regulations in 40 CFR 117 and 302 establish chemical-specific reportable quantities in case of a spill or a release. Under SARA Title III, section 304, the facility must provide immediate notification to the local emergency planning committee and the state emergency response commission if there is a discharge or release of a harmful quantity of a hazardous substance 40 CFR 302.4 that exceeds the reportable quantity for that substance. Title 29 CFR 1910.120 establishes regulations regarding training and protection of personnel involved in routine hazardous waste operations or emergency response actions.
Currently, CSSA has an oil storage capacity of approximately 3,500 gallons in underground tanks. In addition, CSSA is a hazardous waste generator and stores hazardous wastes on site prior to disposal at offsite facilities. CSSA operates under the less-than-90-day exemption (40 CFR 262.34) and is exempted from the TSD permitting requirement. Considering the current oil storage and waste management status of the facility, CSSA is required to have an emergency contingency plan that complies with 40 CFR 265, subparts C and D.
CSSA is planning to replace approximately 3,000 gallons of the existing underground oil storage capacity with aboveground tanks. When the aboveground tanks are placed into service, the facility will be required to prepare and implement an SPCC plan within 6 months from the date of service.
There are no known pesticide rinsate sites on CSSA; however, if discovered these areas should be investigated for possible SWMU delineation. Otherwise, current practices do not present a regulatory compliance issue as CSSA contracts with an outside source.
TSCA regulations do not require immediate investigation of the PCB content of the transformers stored in the incinerator building, but to minimize the potential for a release of PCBs to the environment, unnecessary transformer storage that may include PCBs should be avoided. The transformer serial numbers were checked against identification plates, and/or existing PCB analytical data. There are no known transformers over 50 ppm on the installation.
Underground Storage Tanks. Five tank sites are known to have been affected by release of petroleum product to the subsurface as determined by subsurface assessment during the UST compliance project (ES, 1992a). The five LPST sties include the following tanks: tanks 3, 4, and 6 (LPST number 101264); tank 7 (LPST number 102487); tank 13 (LPST number 102486); tank 18 (LPST number 102485); and tank 19 (LPST number 102488). These sites were reported to the TWC District 8 office in March 1992.
The TWC required further assessment at the LPST sites in corrective action directives sent to CSSA in March 1992. Reports of the release and work plans for further assessment were submitted as phase 2 reports to TWC District 8 in May 1992. The TWC-approved phase 3 assessment actions were performed during the summer of 1992. Actions included drilling of soil borings and groundwater monitoring well installation, soil and water sampling, and chemical analyses.
The results for each LPST site were presented in phase 3 assessment reports (ES, 1992c; ES, 1992d; ES, 1992e; ES, 1992f; and ES, 1992g). In general, releases were confirmed in subsurface soils at each of the five sites. Groundwater was detected at 10 to 28 feet below ground level at each site with the exception of tank 18, where groundwater was not detected. The groundwater flow directions and gradients did not correspond from site to site, indicating that first water is most probably a perched, shallow water bearing zone at each site. The groundwater was affected by petroleum hydrocarbons above proposed action levels at tanks 3, 4, and 6; and below action levels at tank 19. In particular, a thin (less than 0.01 foot) lens of phase-separated hydrocarbons was detected in one groundwater monitoring well near tanks 3, 4, and 6. The extent of contamination in soil and/or groundwater above proposed target cleanup levels was not determined at tanks 3, 4, and 6, tank 13, and tank 19.
Target action levels for soil and groundwater based on site conditions and TWC policies for LPSTs have been proposed in the five reports referenced above. ES also proposed additional assessment to determine the extent of lateral and vertical migration at tanks 3, 4, and 6, tank 13, and tank 19. It was recommended that tank 7 be monitored for potential groundwater affects and that tank 18 be closed. Currently, the phase 3 reports have not been reviewed by the TWC.
The phase 3 assessment work was followed by quarterly groundwater monitoring at four of the sites. The general results of monitoring during three quarters are as follows: depths to groundwater can be significantly affected by the amount of recent precipitation; groundwater flow directions tend to change slightly, possibly in response to precipitation; and petroleum hydrocarbons have been detected below proposed action levels at tank 7 in addition to the other three tank sites. CSSA is currently monitoring the groundwater.
Aboveground Storage Tanks. There are no environmental consequences identified from use of three mobile ASTs previously kept at various locations. As CSSA elected to remove the ASTs, there are no regulatory compliance actions necessary.
CSSA has identified the locations of asbestos-containing materials in buildings at the facility. CSSA has currently contracted to have asbestos removed in many of the buildings. An operations and maintenance plan for workers should be developed for CSSA if one has not already been developed. No maintenance should be performed without first reviewing the plan and following its guidance. Work done on asbestos materials should be performed by certified asbestos workers who follow proper work practice techniques and disposal methods.
The Texas air pollution control program is managed by the TACB under authority of the Texas Health and Safety Code, subtitle C, air quality and under the Texas Clean Air Act (chapter 382 of the Texas Health and Safety Code) (TACB, 1992). The TACB is the state air pollution control agency, is the principal authority on matters relating to the quality of the state's air resources, and sets standards, criteria, levels, and emission limits for ambient air quality and pollution control. The policy inherent in the Texas Clean Air Act is to safeguard the state's air resources from pollution by controlling or abating air pollution and emissions of air contaminants, consistent with protection of public health, general welfare, and physical property, including aesthetic enjoyment of air resources by the public and maintenance of adequate visibility. To ensure protection of public health, safety, and welfare, TACB requires permits for construction of any facility that may emit air contaminants. The permit process ensures that the proposed facility will use at least the best available control technology and that emissions from the facility will not contravene the intent of the Texas Clean Air Act, including protection of the public's health and physical property.
Pollutants are emitted from three generators, four boilers, four USTs, the bluing shop, the weapons preservative area, solvent weapons cleaning (two degreasers, one vapor degreaser, and five hand-carried solvent trays), painting operations, a sand blaster, a steel shot blaster, a steel abrasive tumbler, and the weapons firing chamber. TACB has permitting authority for these facilities under the Texas Clean Air Act. This authority to grant permits for the construction of new facilities or modification to existing facilities applies to stationary sources.
Emissions from all of the sources described above are subject to permitting under TACB regulations unless they can be exempted under the TACB standard exemption procedures. There are only three methods available to authorize construction of a facility in Texas: construction permit, permit amendment, and standard exemption. Standard exemptions were created to exempt small facilities having insignificant emissions. Certain facilities may be exempted from permit requirements if it can be demonstrated that such facilities will not make a significant contribution of air contaminants to the atmosphere as determined by the TACB. The following is a brief discussion of TACB standard exemption and rule applicability for sources of air pollution at CSSA. A more detailed discussion is presented in appendix F.
It is anticipated that the painting operations, which are all performed by one painter, can be exempted under TACB standard exemption 75 since no metal spraying or metallizing is done, and because VOC emissions from the operation are below the exemption limits of 6 pounds per hour, averaged over a 4-hour period, and 500 pounds per week. No air quality permits are required for the proposed painting operation if the paint spray booth meets specifications listed in TACB standard exemption 75(a). Otherwise, TACB form PI-7 will need to be completed in accordance with TACB standard exemption 75(c). Again, registration of the paint spray booth by submittal of form PI-7 can be eliminated if the indoor work area (paint booth) meets conditions of TACB standard exemption 75(a).
In all cases, records of hours of operation and the usage of coating materials and any solvents used for thinning or cleanup must be maintained in sufficient detail to demonstrate compliance with the standard exemption. Records must be maintained on a rolling 2-year retention period. Also, the applicable requirements of regulation V, concerning general vent gas streams and surface coatings, must be satisfied.
Three of the boilers (a Kewanee in building 89, a York Shipley, not in use, also in building 89, and a Kewanee in building A-100) meet standard exemption 3, which exempts combustion units designed exclusively for comfort heating purposes employing natural gas from TACB permitting requirements. The other two boilers (a Kewanee in building 46 and another in building 201) do not meet this exemption since they are fired on #2 fuel oil. They also do not meet standard exemption 7. These units will require permits unless CSSA uses #2 fuel oil containing less than 0.3 percent by weight sulfur that is a petroleum distillate oil (not a blend containing waste oil or solvents), or converts the boilers to operate on natural gas.
A permit will not be required for the Wheelabrator steel shot blaster because the maximum filter velocity of its baghouse meets the requirement for fabric filters with air cleaning in standard exemption 102(a).
A permit will be required for the steel abrasive tumbler because the maximum filter velocity of its baghouse does not meet the requirement for fabric filters with air cleaning in standard exemption 102(a). Permitting of this tumbler may be able to be avoided if CSSA can assure TACB it will not operate the 3,310 cubic-feet-per-minute (cfpm) fan from the tumbler to the baghouse above 2,691 cfm. This will need to be discussed with the TACB. The agency may require removal of the 3,310 cfm fan and replacement with one that has a maximum flow rate of 2,691 cfm.
The Silverado sand blaster is vented through a baghouse in building 90-2 that is not vented outside. Since the unit does not vent to the atmosphere, it is not a source of air pollution and is not subject to permitting.
The glass bead tumbler is not in use and has not been for years. It is therefore not a source of emissions. Should CSSA wish to use this tumbler, it is exempt from permitting since it meets TACB standard exemption 22, which exempts all closed tumblers used for cleaning or deburring metal products without abrasive blasting, and all open tumblers with a batch capacity of 1,000 pounds or less.
The weapons firing chamber does not meet the emission limit of standard exemption 118(c). The chamber will require a permit since it does not meet all of the conditions of the standard exemption. CSSA shoots weapons into a room of sand that vents uncontrolled to the atmosphere. Installation of a 98-percent-efficient control device and limiting the hours of shooting to 2 hours a day, 5 days a week, and 48 weeks a year does not meet the requirements of standard exemption 118(c) for maximum hourly emission rate. Installation of a particulate control device, such as a cyclone or baghouse, will help in pollution prevention and may be a permit requirement. It does not, however, qualify the facility (weapons firing chamber) for a standard exemption.
Before applying for a permit for the weapons firing chamber, CSSA should either keep records of the dates and amounts of sand added to the chamber so that a more accurate mass emissions rate can be calculated, or conduct source testing on the chamber to get the exact particulate emission rate. In either case, they should compare pounds per hour and annual emissions to the standard exemption 118 limits of 0.072 pounds per hour and 5 tons per year, respectively. Should they meet these limits, the chamber will not require a permit but must be registered with TACB using form PI-7. A meeting with the TACB should be scheduled to discuss the permit application prior to its preparation.
The four operational USTs are exempt from permitting requirements since they meet TACB standard exemption 53, which exempts organic liquids loading or unloading equipment for railcars, tank trucks, or drums; and storage containers, tanks, or change of service of the material loaded, unloaded, or stored.
The vapor degreaser does not meet the surface area requirement of TACB standard exemption 107(a) and will therefore require a permit.
The four solvent dip tanks (including the two solvent tanks in the preservative line) and the fingerprint remover dip tank in building 90 satisfy the requirements of TACB standard exemption 107(b) and are therefore exempt from permit requirements.
The soap tank, rinse tanks, hydrochloric acid tank, and nickel penetrate tanks in the bluing shop are exempt from permit requirements since they meet TACB standard exemption 41, which exempts equipment using aqueous solutions for anodizing, electrodeposition, electroless plating, electrolytic polishing, and stripping of brass, bronze, cadmium, copper, iron, lead, nickel, tin, zinc, and precious metals; and for cleaning, stripping, etching, or other surface preparation , but not including chemical milling or electrolytic metal recovery and reclaiming systems. In addition, since the soap and nickel penetrate tanks are heated, they meet TACB standard exemption 57, which exempts electrically heated or sweet natural gas or liquid petroleum fueled equipment used exclusively for heat treating, soaking, case hardening, or surface conditioning of metal objects, such as carbonizing, cyaniding, nitriding, carbon-nitriding, siliconizing, or diffusion treating. The heated VCI tank in the preservative line in building 90 also meets TACB standard exemption 57 and is therefore exempt from permit requirements.
The light-oil dip tank in the preservative line in building 90 and the oil preservative dip tank in the bluding shop are exempt from permit requirements since they meet TACB standard exemption 50, which exempts containers, reservoirs, or tanks, used exclusively for dipping operations for coating objects with oils, waxes, or greases where no organic solvents, diluents, or thinners are used; or dipping operations for applying coatings of natural or synthetic resins which contain no organic solvents. According to the TACB (Shu, 1992), these tanks are not considered sources since the vapor pressure of the cold oil is very low (less than 0.01 mm Hg).
The VCI tank and one solvent tank in building 90 are to be replaced with tanks that vent to the atmosphere. The VCI tank will be heated to 130 degrees Fahrenheit. The solvent tank will meet TACB standard exemption 107(b). In accordance with the exemption, the tank will need to be registered with the TACB using form PI-7. The heated VCI tank will meet TACB standard exemption 57 and is, therefore, not subject to permit requirements.
The low emissions from CSSA operations are not expected to impact the NAAQS or Texas ambient air quality standards, which are equivalent to NAAQS. Emissions are also not expected to present a potential for offsite adverse health or welfare effects, or nuisance conditions with regards to air toxics.
It should be noted that a January 12, 1993, record search by TACB's Jack Lehman indicated that there are no files available for CSSA, the RRAD, or any other Army facility in Boerne, Texas, at TACB's headquarters in Austin, Texas. A records search at the TACB regional office in San Antonio will need to be conducted by CSSA to determine if CSSA has any exemptions on file. According to Lynn Weber (TACB Coatings Section, Austin, Texas), permits will be required for all sources not meeting all of the conditions of an applicable standard exemption unless the source was in operation prior to 1971 and there have been no changes to the source or its operation since that tine, in which case it is covered by the Grandfather Rules. Exact dates of equipment procurement, installation, initial operation, and changes in design or operation were not available to ES.
Significant air quality impacts to offsite receptors are not expected from operations at CSSA. Fugitive emissions from solvent weapons cleaning, the preservative process, painting operations, and the bluing shop are considered to be insignificant since it is anticipated that they can be exempted from the permitting process. Air emissions from exempted sources are considered insignificant by the TACB.
Since the possibility exists for impacts to indoor air quality in the weapons cleaning facility (building 90) at CSSA, measures should be considered for this area. Measures could include but are not limited to covering or closing solvent containers when not in use, and incorporating a dilution ventilation system that achieves a good distribution of air flow (ACGIH, 1988). ES did not perform OSHA audits as they are not within the scope of this EA.
Combustive emissions from the boilers or generators could be mitigated by efficient scheduling of equipment use performing regular maintenance and implementing a phased operation schedule to reduce the number of units operating simultaneously. The amount of emission reduction by these measures is not known with certainty because of the potential variables in scheduling. However, it is estimated that implementation of these measures would substantially reduce combustive emissions and associated air quality effects.
Measures directed towards reduction of automobile emissions would most likely focus on transportation planning and management measures. The purpose of the measures would be to reduce miles traveled, vehicle trips, peak hour travel, moving at a low rate of speed, and excessive idle time. These reductions would reduce localize vehicle-related emissions of CO, NOx, VOCs, and PM-10.
Federal and local governments have established noise guidelines and regulations for the purpose of protecting citizens from potential hearing damage and from various other adverse physiological, psychological, and social effects associated with noise. Some of the regulations that are applicable to CSSA are described below.
Federal regulations. The Noise Control Act of 1972 established that federal agencies, when engage in an activity resulting in the emission of noise, should comply with federal, state, interstate, and local requirements respecting control and abatement of environmental noise to the same extent as private entities. Even though the primary operational interest of this legislation, as well as the Aviation Safety and Noise Abatement Act, is directed toward aircraft and airports, the principles involved are applicable to other activities that produce sufficient noise to result in noncompatible land uses in the surrounding community.
In 1978 the Noise Control Act was amended by the Quiet Communities Act. This amendment provided for greater involvement by state and local authorities in controlling noise. Some of the highlights of this amendment are: development and implementation of a national noise environmental assessment program to identify trends in noise exposure, set ambient levels of noise, set compliance data, and assess the effectiveness of noise abatement.
The US Army has established an environmental noise abatement program which is mandated by chapter 7 of AR 200-1. The goal of the abatement program is to achieve compliance with applicable noise regulations which is consistent with mission accomplishment. The abatement program implements the Noise Control Act of 1972 and the Quiet Communities Act of 1978, DoD Instruction 4165.57 on air installation compatible use zones, DoD Instructions 5100.5, AR 95-1, and other Department of the Army memoranda, including ICUZ program implementation. This program requires each Army installation commander to complete an initial ICUZ study to identify and control noise impacts.
Local regulations. The City of San Antonio has a newly amended noise ordinance, the Noise Abatement Ordinance (City of San Antonio, 1992). The ordinance states that the acts of "the making of noise which exceeds 63 dBA (Leq) on residential zoned property as defined by City Code Chapter 35, when measured from property under separate ownership" are declared to be noise nuisances during daytime hours of 6:00 am to 11:00 pm. The daytime noise limits for business zone, industrial zone, and entertainment zone are 70, 72, and 85 dBA, respectively. The nighttime noise limits are 7 dBA lower than the daytime noise limits.
Since the City of San Antonio recently annexed land within 1,000 feet of Highway 3351, which forms the west boundary of CSSA, up to Dietz Elkhorn Road (the northwest corner of CSSA), the Noise Abatement Ordinance may be applicable to CSSA operations which generate noise over the established limits. These limits apply to noise noise activities which are continuous over a 2-hur period. High-energy impulsive sounds from activities at CSSA are not covered by this ordinance.
Other guidelines. In addition to the criteria above, another consideration in defining impact criteria is based on degradation of the existing noise environment. In a community noise assessment, changes in noise levels greater than 5 dBA are identified as significant impacts, while changes less than 3 dBA are generally not discernible to most people.
Generally, most areas on post exhibit noise levels less than 65 dBA. Since most training activities are intermittent and occur in short durations, the impact from noise activities at CSSA is considered to be minimal. Although sleep interference begins to occur around 45 dBA (Rau and Wooten, 1980), activities which produce noise levels greater than these are not expected to occur on post at night.
Construction of temporary and permanent structures in noise-sensitive land use areas is considered acceptable in most areas (residential) where noise levels are below 65 dBA.
There are no known significant impacts on water supply at CSSA aside from the elevated usage, which is substantially higher than would be anticipated for normal domestic activities. Given the age of the system, these high usage figures most likely reflect substantial leaks in the distribution system, which have recently been repaired.
From a capacity standpoint, the CSSA water supply and distribution system appears to be in general compliance with 31 TAC 290.38-290.49, rules and regulations for public water system (appendix L). However, the system may be in violation of some portions of these regulations as noted below (Hidalgo, 1993; appendix B).
Section 31 TAC 290.41(c)(3)(H) specifies that, "Below ground-level pump rooms and pump pits will not be allowed in connection with water supply installations." The wells at CSSA used for drinking water are in pits; however, the wells are contained, closed structures.
Section 31 TAC 290.46(i) says that, "Public water systems must adopt an adequate plumbing ordinance, regulations, or service agreement with provisions for proper enforcement to insure that neither cross-connections nor other undesirable plumbing practices are permitted. The use of pipes and fittings that contain more than 8.0 percent lead or solders and flux that contain more than 0.2 percent lead is prohibited for installation or repair of any public water supply and for installation or repair of any plumbing in a residential or nonresidential facility providing water for human consumption and connected to a public drinking water supply system." Repairs were made with solder that contains more lead than allowed under this regulation, however, CSSA issued a memo to dispose of all solder containing lead, in excess of the amount authorized by regulations, as of April 28, 1993. In addition, the water system is routinely tested in accordance with current regulations.
Section 31 TAC 290.46(t) mandates that' "All water storage facilities, distribution system lines, and related appurtenances shall be maintained in a watertight condition." The well pump records converted to per capita use indicate the probability of substantial leaks in the water distribution system, unless a large amount is used for other purposes than was obvious to ES.
Section 31 TAC 290.41(c)(3) stipulates various additional requirements for wells that will be used for public water supply. The existing wells used for public water supply should be reviewed for compliance with these requirements.
The wastewater treatment plant is operating in compliance with applicable regulations. No concerns or problems were noted with the plant.
Pursuant to Chapter 366 of the Texas Health and Safety Code, the Bexar County Commissioners Court has adopted regulations for private sewage facilities which apply to septic tanks. Section 9 of these regulations requires registration of all existing sewerage facilities. The septic tanks that are currently in use do not require registration under these regulations since they are on a federal facility. However, they will require upgrade or replacement if they are not in compliance with current standards or are not operating properly, according to personnel at the Bexar County Public Works Department (Hinojosa, 1993, appendix B). Although there are no specific requirements for unused existing septic tanks, the Public Works Department recommends that these be crushed and filled. CSSA should also look at the design of the septic tanks for compliance with Bexar County regulations.
According to general conversations with TWC permitting personnel, the existing wastewater permit may require modification to account for the boiler and building drain discharges which currently are not collected and flow onto the ground. These should be captured either by pans or routed to the sewer system. The TWC should be contacted to discuss particular drains and discharges.
Replacement of the existing vitrified clay pipe with PVC pipe would require TWC review and approval of plans, according to conversations with TWC personnel (Strauss, 1993, appendix B). Therefore, the TWC should be contacted before major replacement projects are conducted.
This survey did not identify any particular consequences or regulatory compliance issues. The transformers that contain PCBs are discussed in the hazardous waste section of this report.
This survey did not identify any particular environmental consequences or regulatory compliance issues concerning natural gas use.