The meeting was held at CSSA Building 1 conference room, beginning at 1300 hours on October 28, 1997.  This meeting was attended by representatives of Environmental Protection Agency (EPA) Region VI, Texas Natural Resource Conservation Commission (TNRCC), Corrective Action (CA) Section, CSSA, Air Force Center for Environmental Excellence (AFCEE), and Parsons Engineering Science (Parsons ES).  The following were in attendance (see attached sign-in sheet):

Meeting Purpose

The purpose of the meeting was to discuss issues pertinent to future field efforts regarding solid waste management unit (SWMU) closures under 30 TAC 335 Subchapter S requirements.  The intent of the meeting was to include regulatory personnel clarifications on the requirements for remediation associated with closure activities.

Discussions

The meeting discussions included background information concerning ongoing efforts conducted at CSSA and a current status report.  In addition, discussions of proposed remediation/treatment requirements for SWMU closure efforts under 30 TAC 335 Subchapter S was also included.  Greg Lyssy provided insights to EPA’s expected involvement through a RCRA 3008(h) order.

Susan Roberts provided a brief summary of actions to date for AMC Delivery Order RL17, and indicated the basis for these actions was discussed in the project workplan and sampling analysis plan sent to the TNRCC and EPA in February 96 along with notification of closure as required by 30 TAC 335.8(c).  The field work is completed, however reporting is not compete.  Included in the efforts to date are two treatability studies for suspected source areas of groundwater contamination found in well 16 at CSSA.  The two sites are SWMU O-1 and B-3, at which treatabilty studies for electrokinetic remediation and soil vapor extraction (SVE), respectively, are being conducted.  The O-1 treatabilty study is currently in the field investigation stage.  The SVE study field effort has been completed and the final report is expected to be submitted soon.  Jo Mullen indicated that AFCEE expects to conduct modeling efforts for B-3 using “Fracman” which will also identify any data gaps.  Richard Clarke questioned if the actions were initiated voluntary and Brian Murphy replied that they were.

Julie Burdey provided a brief summary of action to date for AMC Delivery Order RL33; the field work is currently ongoing and includes three treatability studies:  stabilization with off-site disposal, phytoremediation, and soil washing.  The concern noted by Malcom Ferris of TNRCC is associated with planned stabilization efforts for hazardous soils, which was discussed at length later in the meeting.  Greg Lyssy asked if phytoremediation works; Parsons ES believes it has possibilities for certain types of soils identified at B-20.  Richard Clarke asked if phytoremediation would work for lead shot contaminated soils.  Parsons ES replied that those soils are expected to be treated through stabilization/off-site disposal or soil washing.

Ken Rice provided a brief summary of the planned efforts for AMC Delivery Order RL53 and indicated that a workplan and notification will be forwarded to the TNRCC before work commences.  Richard Clarke asked if PCBs are expected to be tested at the incinerator.  Ken Rice replied that they would be tested for along with other appropriate contaminants at all SWMUs being investigated.

Susan Roberts provided a brief summary of groundwater investigations to date.  The summary included work efforts to identify groundwater contamination source areas (i.e., SWMU O-1 and B-3), and groundwater monitoring efforts.  Greg Lyssy questioned about typical groundwater levels  and whether all other potential source areas (e.g., SWMU B-2, B-8, etc.) were ruled out.  Susan indicated that groundwater is encountered between 100 feet below grade surface (bgs) to +300 feet bgs and flows in the south-southeast direction.  Groundwater is recharged through fracture flow through the limestone and all other potential source areas showed nothing in relation to contaminants found in groundwater near well 16.  Richard Clarke questioned whether rain events affect concentrations detected in groundwater and if a risk assessment has been done.  Susan Roberts responded that rainfall events do increase the concentrations detected in groundwater; however, not enough data are available to correlate the relationship of rainfall events to spikes seen from the groundwater monitoring events.  A risk assessment has not been conducted; however, water supply wells both on-site and off-site have been tested.  No chlorinated solvents were identified in the water supply wells.

Malcom Ferris, TNRCC Region 13 Field Investigator, reiterated his concerns regarding planned remediation efforts at CSSA.  The concerns of the TNRCC are that since the material stockpiled (on plastic or otherwise) is intended for disposal, then they are solid waste and, therefore, CSSA needs to perform a hazardous waste determination on those materials.  If the waste is determined to exhibit a characteristic of a hazardous waste, then CSSA needs to manage those materials in compliance with accumulation time requirements.

With regard to the expressed intention of CSSA to dispose of the scrap metal and soils stockpiled at B-20 as a non-hazardous waste following on-site stabilization of metals, the TNRCC notes that the treatment of a hazardous waste for purposes of meeting land disposal restriction requirements would require the facility operators to submit a waste analysis plan at least 30 days prior to the commencement of the treatment activity as required under 40 Code of Federal Regulations (CFR) §268.7(a)(4) (relating to Land Disposal Restrictions - Waste analysis and recordkeeping).

CSSA is currently proceeding with investigation/closure efforts for a number of SWMUs under 30 TAC §335 Subchapter S (§ 335.554) which allows decontamination of contaminated media within a SWMU.  CSSA maintained that the soils undergoing investigations and decontamination within the SWMU are not generated wastes and therefore not subject to the notification and accumulation time requirements for wastes.

Richard Clarke indicated that treatment can not be done voluntary and that Subchapter S can not be less stringent than the federal regulations which requires the facility to manage hazardous waste within an accumulation time frame or obtain a permit.  Therefore, materials excavated from waste disposal units which predated RCRA (i.e., a SWMU) and are characterized as hazardous would create a hazardous waste which would then be subject to RCRA and its requirements including obtaining a permit for treatment or providing a waste analysis plan as required under 40 CFR §268.7(a)(4).

Jo Mullen noted that the material within the units contained unexploded ordinance (UXO) which required mitigation before additional investigations could begin.  The mitigation efforts included excavation and sifting to remove metal fragments and UXO material.  Brian Murphy noted that the UXO found was detonated on-site with TNRCC’s approval.

Richard Clarke noted that RCRA units require a permit and an approved closure plan.  In order to facilitate excavation and off-site disposal, which CSSA could do without permit,  notification to the TNRCC of the intended actions, hazardous waste characterization with prompt disposal is required.  If the facility is not prompt or moves the material, it would be considered a hazardous waste management unit which would fall under the requirements of the RCRA regulations.  The only other method for which a permit is not required for treatment is through an agreed order (i.e., 3008h order) which would contain requirements for planning and schedule for remediating waste units.  Greg Lyssy indicated that the 3008h order is the easiest way to accomplish any remediation of the units.  The order does not have to address individual SWMUs, but can be structured to address the entire facility.

In a recap of the discussions, TNRCC asked whether the B-20 site had an approved plan and if any changes to the plan have been submitted.  Susan indicated that the original plan was submitted in 1994 and acknowledgment from the TNRCC was received for B-20.  The amendment to the original plans have been forwarded to the TNRCC as they become final.  However, no acknowledgment from the TNRCC has been made on the other SWMUs undergoing closure efforts.

Brian noted that the workplan addenda for B-20 and other SWMUs will be provided to the TNRCC.  In addition, CSSA will wait for 3008h order before proceeding with remediation of B-20.  Brian asked Greg the status of the 3008h order.  Greg Lyssy indicated the EPA will be sending it to the TNRCC within the next 2 weeks for comments and that the EPA could provide CSSA with an advanced draft.  Greg added that it will take at least 6 months for the 3008h order to be finalized.

Action Items

Parsons ES

1.      Parsons ES will provide closure/investigation work plans or reports to the TNRCC regarding units which are undergoing closure as they become final.  Submittal of the plans and reports are expected to be in an encyclopedia format.

AFCEE

1.      No Action items identified for AFCEE.

CSSA

1.      CSSA to forward copy of the Groundwater Evaluation & Source Characterization report to Malcom Ferris.

TNRCC

1.      TNRCC will review the draft 3008h order expected from EPA sometime in November 1997.

EPA

1.         Provide draft 3008h order to the TNRCC.