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The meeting was held at the Parsons ES Austin office conference room, beginning at 0900 hours on July 16, 1996. This meeting was attended by representatives of CSSA, AFCEE, Booz-Allen & Hamilton (BAH), and Parsons ES. Representatives of Texas Natural Resource Conservation Commission (TNRCC), Corrective Action (CA) Section, and Environmental Protection Agency (EPA) Region VI joined the meeting at 1000 to 1200 hours. An afternoon meeting was attended by CSSA, AFCEE, BAH, EPA, and Parsons ES for discussion of remedial options at SWMUs O-1 and B-20. 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. EPA personnel flew in from Dallas, TX to join the meeting. Attached is the sign-in sheet used at the meeting.

Meeting Purpose

The purpose of the meeting was to discuss and resolve issues pertinent to the next field effort that were first discussed during the April 29 meeting.

Meeting Agenda

The morning meeting agenda was a project summary, request for variance from SW846 8260A practical quantitation limits (PQLs) listed in the AFCEE QAPP vs those achievable using 25 vs. 5 mL purge by the laboratory, status of background metals statistical evaluation, proposed actions for field effort 2, and investigative derived wastes (IDW) handling.

The afternoon meeting agenda was a discussion of remedial options for CSSA SWMUs O-1 and B-20.

Morning Meeting

Introduction of Participants

 

Greg Lyssy	EPA Region VI RCRA Technical Enforcement Environmental Engineer
Richard Clarke	TNRCC, CA, Program Manager
Kirk Coulter	TNRCC, CA, Caseworker assigned to CSSA SWMU closure certification reviews
Brian Murphy	CSSA Environmental Officer
Elizabeth Berman	AFCEE/ERC Chemical Engineer
Rene Hefner	AFCEE/ERC Hydrogeologist
Farrukh Ahmad	BAH Engineer supporting AFCEE
Susan Roberts	Parsons ES Project Manager
Julie Burdey	Parsons ES Program Manager
Ken Rice	Parsons ES Task Manager

Discussions, 0900 to 1000 hours

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

Items of Concern: Jo Mullen noted a concern with recent draft TNRCC guidelines regarding SWMU closures. Parsons ES observed that the guidelines are draft and not binding, they do not supersede existing regulations, and it appears that the TNRCC has received so many negative comments about the draft that they plan to revise a good portion or all of it. All agreed that this item will be brought up for discussion with TNRCC and EPA.

Jo also requested a schedule of work for Field Effort 2. This effort will involve drilling and sampling at those SMWUs with geophysical anomalies likely attributable to subsurface waste management activities, or SMWUs with surface soil samples that contain chemical constituents above comparison criteria. These drilling sites are anticipated to be at SWMUs:

Field Effort 2 also includes soil gas surveys at six SMWUs:

Susan Roberts said that a schedule of day-to-day activities will be sent to AFCEE and CSSA within a week of receiving regulatory approval for all issues pertaining to Field Effort 2.

The meeting handouts were reviewed. Ken Rice pointed out that the afternoon session was intended to be a working meeting and that input from all participants was necessary to achieve the goal of establishing viable technologies for the sites under review, based on work and data to date.

Discussions, 1000 to 1200 hours

Project Summary: Susan Roberts provided a brief summary of the project to date. In particular, project plans were completed in Feb 96; and field effort 1 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 validated laboratory reports of volatiles, semivolatiles, explosives, and metals for surface soil samples collected during Mar 96.

Field Effort 1 (mapping, geophysical surveys using electromagnetic induction, and surface soil sampling for analysis) sites are:

Geophysically surveyed sites: B-5, B-6, B-9, B-10, B-13, B-25, B-26, B-27, B-29, B-30, B-31, B-32, B-33, B-34, Bldg. 43, I-1

Surface soil sampling at sites: B-5, B-6, B-7, B-9, B-22, B-25, B-26, B-27, B-29, B-30, B-31, B-32, B-33, B-34

Richard Clarke, TNRCC, asked Greg Lyssy, EPA, about EPA’s stance towards primacy over CSSA’s SWMU closures. Greg indicated that the 30008H order will be signed soon, and that EPA is primarily interested in high priority sites such as B-20 and O-1 (the oxidation pond).

Susan Roberts requested TNRCC’s input on the recent draft guidance for use of the risk reduction rules under 30 TAC §335 Subchapter S. Richard Clarke said that new regulations will not be passed for 6 months to 2 years, and they anticipate placing a grandfather clause so that work under the current regulations will not be invalidated. It was agreed that CSSA could follow their existing approach documented in the project plans.

Issue to be Resolved - IDW Handling: The one-page April 29 handout on this subject was presented. Greg Lyssy asked for clarification of field screening; Ken Rice stated that typical instruments such as PIDs and explosimeters would be used. Greg observed that the April 29 memo was not specific enough to satisfy his concern that the IDW would be appropriately handled. In particular, EPA and TNRCC were concerned about dust from cuttings and the potential for runoff (i.e., creating a potential contaminant pathway that did not exist before the investigative activities began). Kirk Coulter, TNRCC, provided a draft TNRCC guidance on IDW handling, which was copied for all participants. It was agreed that:

Note: It was agreed at this time that all information and letters sent to TNRCC on this project will also be sent under a cc: to Greg Lyssy.

Issue to be Resolved - PQL Variance Request: The letter of 12 April 96 and table requesting a variance from the AFCEE QAPP PQLs for SW846 8260A analyses was presented to attendees. Kirk Coulter requested that a risk value for bromochlorobenzene, a compound that was not provided for in the 30 TAC §335 Subchapter S appendix II table. Should that calculated value be higher than the laboratory PQL as is the case with the other compounds, TNRCC does not see a problem with approving the request. It was agreed that:

Issue to be Resolved - Approval of Background Metals Statistical Evaluation: Julie Burdey provided a table of final statistical results from the June 1996 report and briefed the attendees on the field and analytical efforts performed under AL/OEB Order 126. The following questions were raised:

Action Items

IDW Handling

1. Parsons ES: soil and rock cuttings will be contained in double plastic bags, rather than drums. However, at high priority SWMUs or any place that hazardous wastes were suspected, drums will be used to contain soils.

2. Parsons ES: will revise their IDW handling procedures and submit to CSSA and AFCEE next week.

3. AFCEE and CSSA: Review and provide comments to Parsons ES on the revised procedures.

4. TNRCC and EPA: Review the revised procedures. If the revised procedures are approved, TNRCC will prepare a letter of approval, and EPA will prepare a letter of concurrence. Parsons ES respectfully requests that the letters of approval or comments be sent within one week of receipt, so that the drilling and sampling field effort may begin in early August 1996.

PQL Variance Request

1. Parsons ES: will calculate value for bromochlorobenzene as requested by TNRCC, and submit to TNRCC and EPA with a letter of request based on results.

2. TNRCC and EPA: Review the calculation and letter of request. If approved, TNRCC will prepare a letter of approval, and EPA will prepare a letter of concurrence. Parsons ES respectfully requests that the letters of approval or comments be sent within one week of receipt, so that the drilling and sampling field effort may begin in early August 1996.

Approval for Use of Statistically Evaluated Background Metals Levels

1. TNRCC and EPA: Based on the meeting discussion, TNRCC indicated that they could approve use of the statistically evaluated background metals levels for use in CSSA closure investigations. TNRCC will prepare a letter of approval, and EPA will prepare a letter of concurrence. Parsons ES respectfully requests that the letters of approval or comments be sent along with the other letters of approval or comments, so that the drilling and sampling field effort may begin in early August 1996.

Afternoon Meeting

Participants

Discussions

Agenda: A list of the afternoon meeting agenda was handed out. The handout presented a review of viable remedial technologies for both sites.

Because Greg Lyssy had to catch a plane flight at 0230 hours, brief overviews of background and probable remedial options for SWMUs O-1 and B-20 were provided by Ken Rice and Julie Burdey, respectively. At SWMU O-1, Ken noted that it would be ideal to address both volatiles and metals, that electrokinetics or phytoremediation may not achieve background levels, and that it would be a good test site for other similar CSSA sites due to its small size. At the B-20 site, Julie discussed data to date showing that the problems are metals and some explosives in relatively small areas, there is little to no soil, lead piles are suggested to be removed, and that some buried wastes are in the northern portion of the site.

Greg noted before he left that it appeared for both sites that a combination of remedial technologies will be necessary to remediate the sites.

Ken discussed the remedial technologies listed in the handout. The following presents a summary of the next actions per SWMU.

SWMU B-20

Rifle Management Units

Action item: BAH will prepare draft scope of work for the above items for AFCEE’s review.

SWMU O-1 (oxidation pond)

Action item: Parsons ES will contact potential electrokinetics subcontractors to establish a cost estimate for a benchscale treatability study under task 05, RL17.