The meeting was held at the Parsons ES Austin office conference room, beginning at 0900 hours on April 29, 1996. This meeting was attended by representatives of CSSA, AFCEE, and Parsons ES. An afternoon meeting beginning at 1330 hours was attended by representatives of Texas Natural Resource Conservation Commission (TNRCC), Corrective Action (CA) Section, CSSA, AFCEE, and Parsons ES. The following were in attendance (see attached sign-in sheet):

The meeting was held at Parsons ES for the convenience of attending TNRCC personnel, as the office is a 10-minute drive from the regulators’ office in Austin. Parsons ES personnel David Highland, Karuna Mirchandani, and Julie Burdey were only in attendance for portions of the meeting for which they had specific input.

Meeting Purpose

The purpose of the meeting was to discuss issues pertinent to the next field effort. The intent of the meeting was also to include regulatory personnel in an active teaming arrangement that will continue throughout the project timeframe and allow for expedited decisions during the closure activities.

Meeting Agenda

The morning meeting agenda was a project summary, discussion of a proposed report example for all closure reports, summary of lab variances and data validation, status of background metals statistical evaluation, field effort 1 data, proposed actions for field effort 2, investigative derived wastes (IDW) handling, and review of oxidation pond data to date.

The afternoon meeting agenda was a discussion of proposed teaming arrangements between CSSA, AFCEE, Parsons ES, and TNRCC, discussion of proposed closure report format, request for TNRCC approval of variance for 25 vs. 5 mL purge for SW-846 8260A analyses, discussion of background metals statistical evaluation, proposed actions for field effort 2, and IDW handling.

Morning Meeting

Introduction of Participants

Brian Murphy -- CSSA Environmental Officer

Jo Jean Mullen -- AFCEE/ERD, Team Chief

Beth Garland -- AFCEE/ERC Chemist

Rene Hefner -- AFCEE/ERC Hydrogeologist

David Highland, P.E. -- Parsons ES Technical Director

Susan Roberts -- Parsons ES Project Manager

Ken Rice -- Parsons ES Task Manager

Teresa Anderson -- Parsons ES Task Manager

Karuna Mirchandani -- Parsons ES Environmental Engineer/Chemist (working on requested lab variances and summary of data validation)

Julie Burdey -- Parsons ES Geologist (background metals statistical evaluation)

Discussions

Meeting objectives: A list of the morning meeting agenda was handed out. Objectives (meeting agenda) were agreed upon before further discussion.

Items of Concern: Parsons ES requested input on any items of concern that CSSA or AFCEE might have. Brian Murphy and Jo Mullen both stated that they had no items of concern to date. Jo Mullen noted that she needs additional information about sites B-20 under Armstrong Laboratory/OEB (AL/OEB) order 126 and O-1 under AL/OEB order 067 before she can propose a plan of mitigation to CSSA. AFCEE needs a summary of work to date on these sites. Jo plans to move forward on the treatability studies for SWMU B-20 and O-1 in June 96. Susan Roberts noted that information about these two sites, as well as the soil vapor extraction pilot test at B-3, is currently being written in reports to be submitted to CSSA and AL/OEB in June 96, and the reports will be made available to AFCEE. Jo noted that the critical item to watch with regard to the treatability studies is the time schedule.

Project Summary: Susan Roberts provided a brief summary of the project to date. In particular, task 01 (preparation of plans) was completed in Feb 96; task 10 (site visit and utilities) was completed on 23 Feb 96; and field effort 1 of task 03 (site characterization) was conducted on 4-15 Mar 96 and 25-28 Mar 96. Data to date includes electromagnetic induction (EM) data contoured on site maps, and receipt of laboratory reports for the majority of analyses (semivolatiles, explosives, and metals) for surface soil samples collected during Mar 96.

Report Template: Parsons ES received AFCEE comments on 25 Apr 96, and concurs with the majority of the comments. Revision of the report template into one volume for background inclusive to all CSSA solid waste management units (SWMUs), with separate site-specific volumes for each SWMU, was further discussed. Jo Mullen said that AFCEE recommends an “encyclopedia” approach to reduce paperwork. Each of the three project plans would be a “volume”, followed by a background information report, to be followed by site-specific reports of closure certification or investigation for closure. David Highland noted that it was important that TNRCC agree to this approach, and that they do not perceive it as too difficult for individual caseworkers to find the necessary information to review each SWMU closure report. It was agreed that in preparation for the afternoon meeting with TNRCC, Teresa Anderson would revise the report template table of contents during lunch to reflect separate volumes for background and site-specific report format examples. The revised tables will be presented to TNRCC, and a request made for TNRCC approval of a background information volume along with site-specific closure reports.

Summary of Lab-Requested Variances: Two pages summarizing lab variances and major issues to date were handed out. Karuna Mirchandani reviewed the handout, and noted that one of the two variances was pending approval from TNRCC based on a letter of request sent to the agency on April 12, 1996. It was agreed that this variance request should be discussed at the afternoon meeting with TNRCC.

Beth Garland noted that with regard to major issue #1 (use of water matrix in SW6010 and SW7000 series for preparation of the laboratory control sample, rather than Ottawa sand required by the AFCEE QAPP), is under review, but she would have been willing to consider a variance for the project. She said she is available for discussions on any such problems the laboratory may have, and can be reached by facsimile if a phone call does not reach her. Susan Roberts said that Parsons ES and Inchcape will be happy to include her on all such discussions of whether or not work items required by the QAPP may be allowable under a variance. Beth Garland also indicated that the analyses run within holding times but through a water matrix instead of the Ottawa sand should be appropriate for use in the project data set.

For major issue #2 (presence of 4-chloroaniline in seven samples), Beth Garland said that because this compound is not part of any chemicals used at CSSA, the data should still be usable and Parsons ES should not need to resample nor reanalyze. Parsons ES and Inchcape should note this in a memo to AFCEE, and the data results thoroughly explained in reports that contain the affected data. [Note: 4-chloroaniline is used as a dye intermediate, and is used in pharmaceuticals and agricultural chemicals (Handbook of Environmental Fate and Exposure Data, Philip H. Howard, 1990).]

Upon receipt of the data validation report, Karuna Mirchandani and Beth Garland will discuss major issues #3 (failed spike recoveries in LCS of SW8330 analyses) and #4 (“R” flags due to low internal standard counts in SW8260 analyses) within the next few weeks. Beth Garland also asked for clarification on the draft data validation report, page 8, paragraphs 3 and 5, for use of the phrase “correlation coefficient outlier.” Parsons ES will call her with a verbal explanation, and ensure that the explanation is included in the final data validation report. Jo Mullen and Beth Garland noted that they anticipate an analytical data informal technical information report (ITIR) (item A002 of the project SOW) within 30 days of completion of the technical effort, which will be completion of data validation.

Summary of Background Metals Statistical Evaluation: Julie Burdey provided a table of preliminary statistical results and briefed the attendees on the field and analytical efforts to date, performed under AL/OEB Order 126. The sampling and analysis plan was approved by TNRCC letter dated 22 Feb 96. Collection of background samples in surface soils was performed 11-15 Mar 96. The laboratory Inchcape Testing Services was contracted to perform the metals analyses, as they were most familiar with AFCEE QAPP requirements and the unit rates were cost competitive. Results were received on Wednesday, April 24. A preliminary statistical evaluation was performed over the weekend in preparation for the meeting. It was agreed that the table should be provided to TNRCC at the afternoon meeting to discuss regulatory approval for use of these background levels for comparison to SWMU closure sample analyses, and to discuss possible TNRCC written approval of background levels within 30 days of submission of report. AFCEE also recommended asking TNRCC when the B-20 remedial investigation, including a background statistical evaluation, would be commented upon.

Susan Roberts noted that waiting for TNRCC approval on the background metals concentrations will delay field effort 2, making it impossible for Parsons ES to complete all scheduled work under the contract by the Sept 96 contract-end date. Due to the need for regulatory approval of background data (to be submitted in June 96) for use in the SWMU closures project, and the associated delay of Field Effort 2, Jo Mullen said that a contract-end date extension request to AMC would be appropriate.

Brian Murphy also noted that another potential SWMU was found in the CSSA F Section, where used batteries were stored.

Field Effort 1 Data: Handouts presented to attendees were analytical data (a summary table of data exceeding state risk reduction standards, site-specific data tables, and a sample summary table for field effort 1), base site maps, two sets of site maps with analytical results either greater than Risk Reduction Standard 1 or 2, and a set of site maps with geophysical EM contours. All information is considered draft at this time.

The results were discussed primarily using site maps with analytical results greater than Risk Reduction Standard 1, as CSSA intends to close the SWMUs under this standard. Each site map was reviewed and pertinent results discussed. The map of SWMU B-9 noted the presence of “pink powder” near some mortar and concrete piles - AFCEE requested that the nature of the powder be explained, e.g., whether it appears to be related to the mortar or some other material.

Because of the lack of time, the geophysical contour maps and site-specific data tables were not discussed in detail. Susan Roberts asked Rene Hefner to provide input within the next month if he has comments or concerns about the draft map format or geophysical data. Parsons ES and AFCEE agreed that in-phase and quadrature phase EM data maps should be put in an appendix in the closure reports. Beth Garland was also asked to provide input on the draft data tables if she has any comments or questions.

Recommendations for Field Effort 2: Handouts were (1) a summary table of Field Effort 1 results and proposed Field Effort 2 actions, and (2) a set of draft site maps with geophysical anomalies due to suspected waste management activities, analytical results greater than Risk Reduction Standard 1, and proposed boring locations. Each site was reviewed, and it was agreed that results with an “F” flag do not require further investigation, and that the number of borings will be revised upon receipt of validated data. Tentatively, 46 boring locations were agreed upon. It was agreed that the proposed boring locations would be discussed with TNRCC at the afternoon meeting.

The meeting broke for lunch during discussion of Field Effort 2 actions, and reconvened before the afternoon meeting with TNRCC at 1330 hours.

The number of borings is greater than originally proposed (33), but AFCEE and Parsons agree that the number of proposed monitoring wells (33) will most likely be much less. Therefore, it is anticipated that the task funds will be sufficient to complete the closure investigation field activities.

Ken Rice provided a brief discussion of data at the oxidation pond. This data will be included in the groundwater investigation report (AL/OEB Order 067) to be submitted to AL/OEB and CSSA in June 1996.

IDW Handling: A 1-page handout that listed the proposed IDW handling actions per media was provided. Ken Rice gave a summary, and it was agreed that the handout should be discussed with TNRCC in the afternoon meeting, and that a decision on IDW handling would be asked for.

Afternoon Meeting

Introduction of Participants

Richard Clarke TNRCC, CA, Program Manager

Kirk Coulter TNRCC, CA, caseworker assigned to CSSA SWMU closure certification reviews

Brian Murphy CSSA Environmental Officer

Jo Jean Mullen AFCEE/ERD, Team Chief

Beth Garland AFCEE/ERC Chemist

Rene Hefner AFCEE/ERC Hydrogeologist

David Highland, P.E. Parsons ES Technical Director

Susan Roberts Parsons ES Project Manager

Ken Rice Parsons ES Task Manager

Teresa Anderson Parsons ES Task Manager

Karuna Mirchandani Parsons ES Environmental Engineer/Chemist (working on requested lab variances and summary of data validation)

Julie Burdey Parsons ES Geologist (background metals statistical evaluation)

Discussions

Agenda: A list of the afternoon meeting agenda was handed out.

Teaming Arrangement: Jo Mullen discussed a teaming arrangement. The objective is to have the project run more smoothly with more communication between the working groups so that decisions can be made in a timely fashion. Richard Clarke noted that TNRCC’s participation in work at CSSA will depend on the approach EPA Region 6 takes with the corrective action order. He added that in some cases, EPA will issue an order that addresses an entire facility, and sometimes an order only addresses specific sites. Brian Murphy observed that the EPA corrective action order only affects B-20, and that negotiations have been such that EPA and TNRCC should have their own areas of oversight.

Report template: Susan Roberts introduced the report template, and AFCEE’s recommendation of an “encyclopedia’ approach that seems appropriate for TNRCC review of CSSA SWMU closure reports, and handed out tables of contents for a background volume and for site-specific closure reports. Jo Mullen discussed the approach agreed upon by CSSA, AFCEE, and Parsons ES, e.g., one volume for background information pertaining to all CSSA SWMUs, volumes that have already been submitted to TNRCC for methodologies and QA/QC of the project (the workplan, SAP, and health and safety plan), and subsequent volumes for site-specific data per SWMU. Richard Clarke expressed interest in reducing the volume of paper and thus review time. Jo Mullen noted that a reference could be placed at the front of each volume to identify other volumes and the information contained therein. David Highland asked Richard Clarke if the “encyclopedia” approach would work for a P.E. seal on separate reports, and the answer was yes, as long as the separate volumes were easily identifiable. David also asked if this approach would be cumbersome for caseworker review, and Kirk Coulter indicated that because all the pertinent information seemed accessible in the volume of background information, it should be fairly easy to deal with. He will be keeping most of the volumes in his office and did not see a problem with reviewing background information in a volume separate from site-specific closure reports. Richard Clarke said that three copies of each report should be sent to TNRCC (one each for central records, field office, and corrective action). TNRCC also noted that electronic copies can be sent instead of hard copies to the TNRCC field office and Corrective Action Section (TNRCC uses WordPerfect). Brian Murphy noted that any deviations from the project plans will be described in site-specific reports.

Summary of lab-requested variances: A copy of the Parsons ES letter to TNRCC dated April 12, 1996, was handed to TNRCC. Richard Clarke noted that PQLs are very important to the agency, and that he’ll need time for further review of the request. Susan Roberts asked if TNRCC might make a decision within the month. Richard Clarke said yes, and Parsons ES will contact Kirk at TNRCC (via teleconference with AFCEE and CSSA) within the month. AFCEE considers a decision on PQLs to be crucial to the next field effort.

Background Metals Statistical Evaluation: Julie Burdey briefed TNRCC on the evaluation to date, including site B-20 with 3 soil types and 1 rock type. A statistical evaluation of background was included in the remedial investigation report sent to TNRCC under AL/OEB Order 126 last summer; no comments have been received. The draft table of preliminary background data at CSSA was provided. Richard Clarke said that the statistical levels looked a little high for some of the metals; Julie said that we have not finished our final evaluation, but the statistical methods were the same as used for the B-20 RI report and work at Kelly AFB approved by TNRCC. Richard said that he’d have to refer the statistical work to TNRCC’s statistics expert Peter Lodey, and perhaps Mr. Lodey and Julie could talk over the methods during the next month. Brian Murphy asked Richard if comments could be made on the B-20 RI report; Richard indicated that this should happen in the near future.

Field Efforts 1 and 2: Susan Roberts provided a brief summary of actions to date, and indicated the basis for these actions was discussed in the project workplan and sampling analysis plan sent to the agency in Feb 96. Handouts were (1) a summary table of Field Effort 1 results and proposed Field Effort 2 actions, and (2) a set of draft site maps with geophysical anomalies due to suspected waste management activities, analytical results greater than Risk Reduction Standard 1, and proposed boring locations. During review of each site map, the following questions were brought up.

IDW Handling: A 1-page handout that listed the proposed IDW handling actions per media was provided. Ken Rice gave a summary, and requested input from TNRCC. Richard Clarke noted that hazardous waste had recommendations for definite handling, but expressed concern over non-hazardous wastes. David Highland said that at nonhazardous waste sites, cuttings will be left at the site to be dealt with if results indicate that they exceed the closure standard. Susan Roberts said that because CSSA intends to close sites under RRS1, the non-hazardous waste as well as the site media must be remediated if necessary to meet that standard. Richard Clarke said that the proposed actions need further review by TNRCC. Susan asked Richard if this subject might be addressed within the next month - Richard said that should be OK.

Other Items:

The meeting ended at 1500 hours.

Action Items

Parsons ES

1. Parsons ES will provide reports containing data on SWMUs O-1, B-3, and B-20 to AFCEE in June 1996. Work on these sites has been performed under AL/OEB Orders 126 and 067; final reports are due to CSSA and AL/OEB by 21 Jun 96.

2. Parsons ES and Inchcape will include Beth Garland on future decisions regarding laboratory data that may be acceptable under a variance to the project QAPP.

3. Parsons ES will send a memo to AFCEE in May 1996 requesting use of SW6010 and SW7000 series data which analyses were run within holding times and whose LCS was prepped through a water matrix instead of the Ottawa sand. The memo will indicate that Ottawa sand will be used for remainder of SW6010 and SW7000 series analyses during the project.

4. Parsons ES will send a memo to AFCEE requesting use of analytical data in which 4-chloroaniline was detected. Because this compound is not part of any chemicals used at CSSA, and based on discussion during the meeting, the data should still be usable, but will be thoroughly explained in reports that contain the affected data.

5. Upon receipt of the data validation report, Karuna Mirchandani and Beth Garland will discuss major issues #3 and #4 within the next few weeks.

6. Parsons ES will send to Beth Garland clarification on the draft data validation report, page 8, paragraphs 3 and 5, for use of the phrase “correlation coefficient outlier.”

7. An analytical data informal technical information report (ITIR) (item A002 of the project SOW) for Field Effort 1 data will be submitted within 30 days of completion of the technical effort (completion of data validation). Data validation is anticipated to be complete during the week of 13 May 96.

8. Parsons ES and CSSA will provide information to AFCEE during May 1996 on the presence of “pink powder” near some mortar and concrete piles at B-9.

9. Julie Burdey will call Peter Lodey of TNRCC in May 1996 to discuss the statistical methods used for evaluation of the B-20 site and background metals at CSSA, and set up meeting if necessary.

10. After submittal of the background metals statistical evaluation report to CSSA and AL/OEB in June 1996, and a complimentary copy provided to AFCEE, Parsons ES will call CSSA and AFCEE and arrange the next teaming meeting with TNRCC.

11. Based on meeting discussions, and the delay of Field Effort 2 actions, Parsons ES will send a written request for extension of the project due date to AMC Contracting.

AFCEE

1. Rene Hefner is requested to provide input within the next month if he has any comments or concerns about the draft map format or geophysical data.

2. Beth Garland is requested to provide input on the draft analytical data tables provided at the meeting if she has any comments or questions.

CSSA

1. Brian Murphy indicated he would talk to EPA about ensuring that federal facilities cleanup funds are not involved in the SWMU closures project.

2. Brian Murphy and Kirk Coulter will arrange a CSSA site visit for Mr. Coulter.

TNRCC

1. TNRCC will review the letter of April 12, 1996, that requests variance from the AFCEE QAPP PQLs due to a 25 vs. 5 mL purge on SW846-8260A analyses. Parsons ES will call Kirk Coulter, TNRCC CA, in May 1996 and ask for a written decision on the requested PQL variance.

2. TNRCC indicated they would provide comments to CSSA on the June 95 B-20 remedial investigation report in the near future.

3. TNRCC will review request for IDW handling. Parsons ES will call Richard Clarke or Kirk Coulter in the next month to see if TNRCC has finished their evaluation of the request, and to ask for a written decision on IDW handling.