Environmental Assessment
Section 5 - Conclusions
This environmental assessment consisted of reviewing available historical records, identifying environmental studies and permits, and conducting field surveys to document baseline site conditions. The study addressed such issues as cultural resources, geology and hydrogeology, air quality, noise, utilities, potential hazardous and solid waste sites and practices, surface water, natural resources, and land use practices, as well as others.
A detailed records search was conducted to obtain information about past practices, regulatory inspections, environmental studies, etc. Since CSSA is a restricted-access facility and without large demands for outside consulting assistance, few environmental documents were discovered. Virtually all the documentation existed as memos or letter-type correspondence. Only two documents provided any history of a specific topic, one on oxidation pond operations and one on PCBs. Therefore, it was difficult to determine exact practices for the different branches and activities over the 60-year history of CSSA. Current military practices for that time period had to be assumed for virtually all issues and are expected to change over the history of CSSA. All relevant memos and correspondence are in appendices to this report.
Current environmental practices were evaluated for regulatory compliance. Where deficienceis were noted, recommendations were developed; these are presented in tabular form in section 6.
As a result of this assessment, several substantial conclusions can be drawn. Overall, documentation stating operating practices, and records are incomplete, especially relating to potential hazardous and solid waste issues. Very little information was available to describe locations, amounts, and materials which were placed into landfills and trenches or burned on the surface.
CSSA currently has a known problem where groundwater contains levels of organic contaminants above the MCLs. A source has not been identified; however, several SWMUs are in close proximity. It is not known if any other SWMUs may contain hazardous materials or if other releases to the environment have occurred. All other SWMUs should be randed and investigated to determine exact boundaries, contents, and amounts of materials in each location. In addition, since many areas contained burned munitions, it is possible that some unexploded munitions may be encountered. The "dud munitions area" should be clearly marked on all sides.
Secondly, no environmental assessments or environmental impact statements could be identified for CSSA. One possible explanation is that CSSA's mission and activities have not substantially changed in the last 20 to 30 years. As a result, new construction and substantial modifications have been rare in recent years. CSSA should consult AR 200-1 to determine specific cases when an EA or environmental impact statement may be required for upcoming projects.
Thirdly, several required studies, surveys, or plans have not been completed or are outdated. These include studies for endangered species and cultural resources, natural resource and land use plans, ICUZ plan, and SPCC and contingency plans. These should be completed as soon as possible; some are required by Army regulations, while others are state or federal requirements.
Therefore, CSSA should use this document as a planning tool to decide priorities for recommendations both within each specific area (air, water, solid waste, etc.) and overall in order to determine future funding requirements. In addition, some recommendations can be completed by internal or external sources and require various levels of effort. Regulatory requirements such as permitting, RCRA compliance, and investigations, should be considered with the highest priority.