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April 5, 1999

The Technical Interchange Meeting (TIM) 6 was held at the Parsons ES office in Austin, Texas. The attendance sign-in sheet is attached. The following were in attendance:

The TIM 6 meeting addressed potential actions and several issues involved in investigating and characterizing groundwater contamination and SWMU closures at Camp Stanley Storage Activity (CSSA) under the upcoming EPA Consent Order.

Discussion

Each topic listed in the agenda was discussed. Comments from the discussion are described below.

Introductions were made around the table. Susan Roberts reminded everyone of the goal of the meeting. CSSA needs an action item list appropriate for the upcoming AMC delivery order scope of work (SOW) that will address EPA’s priority concerns within available funds.

One issue not on the agenda was brought up by Jo Jean Mullen - will EPA accept ITS metals data? Susan said that Parsons ES has not found problems with the metals data under the RL17 data validation nor through the ITS MDL studies evaluation. However, due to lab procedures for metals analyses, Parsons ES acknowledges that there is no way to ensure that ITS followed appropriate metals SOPs. Therefore, for the RL17 and RL33 rework, Parsons ES plans on proposing confirmation samples as appropriate, site by site. Greg Lyssy said that a letter from Parsons ES on the intended use of the ITS metals data and any planned resampling would be reviewed.

Karuna Mirchandani said another resampling issue is TNRCC’s 1 April 1999 initiation of extraction method 5035 for VOCs. The new method will ensure that reporting limits (RLs) are lower than those previously used, and therefore will not be comparable to old RLs. Greg Lyssy said that same method for extraction previously used for RL17 sampling and analysis (method 5030) should be OK from EPA’s viewpoint. Greg asked about the percentage of resampling points. Susan replied that no percentage is planned; Parsons ES will go through the ITS data and other available data, site by site, to provide a plan of action and rationale for resample points. Karuna noted that the low level detections near background are the hits on which Parsons ES will focus. Julie Burdey asked Greg if all ITS data must be shown in tables in the workplan for resampling. Greg said that would not be necessary; just provide the logic in writing and include that to the best of Parsons ES’ knowledge, nothing has been found wrong with the metals data. The data can be discussed in the text rather than providing pages of old data tables.

2a. Lab for AFCEE DO23 (GW Monitoring project). Jo Jean Mullen said that under the current CSSA data quality program, some variances requested by laboratories are a problem. Some variances are allowable; some are not. Also, other contractors have had labs submit variances after a subcontract is signed, an action which is not acceptable. Jo Jean would like a list of variances as soon as possible, because she needs to compare them to CLP procedures. CLP is not acceptable under the newly proposed TNRCC Risk Reduction Program (TRRP). Karuna said that for AFCEE DO23, O’Brien & Gere have recently completed and sent 17 of the 24 AFCEE forms to Parsons ES for review and seemed to work out many of the kinks. AFCEE has seen these variances in the meeting minutes for the 11 March 1999 teleconference with AMC.

Jo Jean said that she needs a final list of variances per lab. AFCEE will review for a "go no-go" decision. If the variances are approved, then they can be submitted to EPA and TNRCC for review. Greg said that he would most likely have Mike Daggett of the EPA Houston lab review the variance list, though normally EPA doesn’t review this type of information. Susan and Julie will ask Kirk Coulter how TNRCC might review this list. Karuna will send a final list of O’Brien & Gere variances to Jo.

2a. Lab for AMC RL33 & RL53 (B20 and SWMU Investigations projects). Parsons ES has recently sent out 4 more requests for proposals (RFPs) for these projects. The responses were discussed at the meeting as follows:

Jo Jean Mullen said Kemron’s variance for deletion of a second source calibration standard is not acceptable. Jo Jean has been told that the Kemron variances are minor, though the 2nd source calibration would be important to AFCEE. Jo Jean said that EarthTech had 3 audit visits to Kemron, and is not happy with the results. Shavonne noted the Parsons ES Ohio offices’ experiences with Kemron had not been very good. (Note: as of May 1999 Kemron has passed an audit and 2 follow-up actions, and can perform AFCEE QAPP work.)

Greg Lyssy asked Jo Jean what are options to resolve this issue for CSSA. Jo Jean said that many of the service centers have been accepting a mix-and-match of SW-846 and CLP procedures from labs. The results may produce data that are "R" flagged under SW-846, but are not flagged under CLP. Greg and Jo Jean agreed that most responsible parties are having difficulty finding good labs. Greg noted that the upcoming Consent Order says SW-846 or other approved methods. Jo Jean said that if EPA and TNRCC allow a mix-and-match of SW-846 and CLP methods, and approve of it in writing, then we’ll be able to get data, but the situation appears to be set for poor chemistry. AFCEE has found problems with some Bases using this approach and then being required to resample. If TNRCC will not allow CLP under the new Texas Risk Reduction Program (TRRP), then we may have to resample at CSSA. Greg said that TNRCC must be allowing a mix-and-match of SW-846 and CLP because it is the current state of the industry.

Karuna said that SW-846 allows laboratories to base their criteria on historical data. Jo Jean noted that the AFCEE QAPP has set limits. When you give the labs leniency to use any numbers they want, it sets the stage for low quality work. Greg said that other projects are moving ahead, and we need to come up with a solution. For the RL33 & RL53 projects, Karuna said that APPL is willing to work with us. Jo Jean said that the AFCEE forms do not have to be used if the laboratory can produce the same information on their forms with the data linked in the same manner. If the data are not linked in the same manner, then the lab must provide "decoder" information to allow Parsons ES and AFCEE to quickly find the required information. Brian further noted that the analytes must be linked to the QC data.

As a possible solution, Brian asked the group about use of SW-846 + CLP for the first phase, and if the group thought the regulators would accept this to get the RFI going. This approach might involve screening for the first phase, followed up by resampling for hits. Greg said that CSSA would have to check with TNRCC, who has the final say on closures. Jo Jean said that other projects in Texas are using an SW-846 + CLP approach, but the problem is that the data are being questioned. Greg stated that risk assessors always question data. Karuna brought up some Superfund sites that Parsons ES is using the SW-846 + CLP approach. Greg said that he can’t see that the team would be faulted if we set appropriate data quality objectives (DQOs) for the project. Brian said that the DQOs need to be put into the RFI Workplan.

Susan asked Karuna that if the SW-846 + CLP approach could be used, would any of the RL33/RL53 bidding labs be acceptable? Karuna said that she’ll have to talk in more detail with the labs, but it is more likely that we’ll have to send out another RFP as the requirements would be different than what was previously put in the RFP. Brian noted concerns about the schedule, as it looks like we would be delayed for 6 months. Susan pointed out that the tentative schedule for RL17 and RL33 resampling (handout at the meetings) shows that it will be October 1999 before procurement and auditing might be completed. O’Brien & Gere is close to procurement acceptability, but they have only bid on groundwater. Jo Jean asked if Parsons ES could check on O’Brien & Gere for soils, and continue looking for additional labs, possibly sole source. Susan asked how long it took for EarthTech to audit Kemron - Jo Jean said it was 4 months. Parsons ES has estimated at least 3 months for audits and corrective actions.

If the projects go forward with an SW-846 + CLP approach, the following actions were agreed upon:

1. Parsons ES to work on finalizing a subcontract with O’Brien & Gere for groundwater monitoring under AFCEE DO23.

2. Parsons ES will submit final O’Brien & Gere variances and provide justifications for AFCEE review.

3. Upon approval of variances, O’Brien & Gere will be audited; we anticipate corrective actions and follow-on (funds for this audit have yet to be worked out).

4. For the RL33/RL53 lab procurement, Parsons ES will consider another RFP to find a lab that will provide quality work whether the AFCEE QAPP or an SW-846 + CLP approach is utilized.

5. To speed up the process for the RL17 and RL33 resampling due to ITS problems, Parsons ES will try to use approved and audited labs.

6. Parsons ES will talk with Kirk Coulter of TNRCC about their review of variances from the AFCEE QAPP, use of SW-846 + CLP approach for lab work, and a phased approach for closures.

The draft TNRCC Investigation Report was handed out; few persons at the meeting had reviewed it other than Jo Jean. Susan noted that we may not need to use the form for all CSSA sites. Jo Jean said that we’ll need some notification, and Greg noted that the Consent Order supersedes. Jo Jean and Greg recommended use of the form for at least one site, and as guidance in preparing sections of the Encyclopedia. Greg will ask EPA Corrective Action staff to look at the form. Jo Jean will email this file to Greg and Brian. Parsons ES will talk to Kirk Coulter of TNRCC about how this report might fit into CSSA’s Environmental Encyclopedia.

The groundwater program was briefly reviewed. One of the main issues holding up installation of monitor wells is correct placement. Rene Hefner discussed the AFCEE rationale for slightly revising the order of groundwater program actions. In looking at previous wells, the site geology known to date, and the many unknowns about the hydrogeology under CSSA, AFCEE feels another look at the subsurface would be very helpful. Particularly in the area of faulting around Well 16, more insight into structure and stratigraphy would be important prior to installing expensive wells. AFCEE and CSSA have looked at the previous geophysical surveys (EM, GPR, and seismic). While some helpful data was gathered, a better look at the subsurface system through 3-D seismic reflection would greatly aid in determining the best well placement and installation criteria. Rene has spoken with a geophysicist in the San Antonio area, Dr. Tom Ewing, and says that Dr. Ewing has a lot of experience with SAWS and petroleum geophysical work. Rene feels that the geology dictates why contamination is found around Well 16, and should be more thoroughly understood before initiating a well installation program.

Susan pointed out that while 3-D seismic reflection could be very helpful, the team also needs to discuss the site conditions with the geophysicist. No matter what equipment is used, it could continue to be difficult to find the contact and faults between limestone and limy shale. Rene will meet with Dr. Ewing and go over the site conditions to see if Dr. Ewing has helpful input on what may or may not be possible with 3-D seismic (or other) geophysical approaches.

The discussion moved into potential well installation scenarios. Jo Jean said that if we could determine whether or not contamination was present at the bottom of the Cow Creek, then we could better plan future well depths. Drilling a pilot hole to collect analytical, geophysical and geological data was proposed. Greg said that to determine whether or not contamination is present in the Cow Creek, the pilot hole must go to the bottom of the Cow Creek and into the Hammett Shale for at least 10 feet. Susan said that downhole geophysics will definitely be a part of the plan. Jo Jean would like to see a flowmeter tested as well. It was agreed that Radian can use the results of the pilot hole to install their wells. Greg said that CSSA will eventually need perimeter wells and that Radian’s wells could be used for this purpose.

This discussion was followed by review of items for the next delivery order (see Item 6 below).

5a. GIS Updates

The following items were discussed to address in the near future: getting the LAN running; air calculations, CSSA buildings with elevations, spill equipment and containment areas; AST information; roads; utilities, etc. Julie and the RL74 GIS team will work with Brian to determine future CSSA GIS needs.

5b. List of Proposed Groundwater Target Analyses

The list of proposed target analytes for CSSA groundwater monitoring was handed out. Greg commented that we should add any PCE breakdown products such as vinyl chloride. He also asked what work has occurred since the last meeting in October 1998; Parsons ES showed him the draft report of groundwater monitoring from November 1998. After discussing the number of events (12) on which Parsons ES’ request for the reduced target list is founded, Greg agreed that there was sufficient data on which to base the list if we add vinyl chloride. Parsons ES agreed to send a letter with the revised list for approval. Jo Jean requested that the letter also state that CSSA understands the agreement could change if data are different in the future. A copy of the letter will be added to the Encyclopedia groundwater volume and in the correspondence section.

As for the metals, it was agreed that CSSA needs a background evaluation of metals in groundwater prior to deciding upon a target list. Jo Jean added that the draft November 1998 groundwater monitoring report can go final.

5c. Table of Prioritized SWMUs

Disposition of soil piles at B-8, -20, -24, -28 and the DD area under the Consent Order Interim Measures (IM) was the first topic. Evaluation of the treatability studies to date followed by a risk assessment on the soils for evaluation of risk to human health and environment were discussed as potential future actions. The disposition could be done for the Consent Order IM SOW 2.e., as part of a new project. Parsons ES will work on actions and costs.

The soil piles near B-20 and other excavated SWMU areas could be part of a CAMU for CSSA, and treatability studies for these piles are underway. One of the studies will be soil washing without acidic enhancement. These studies are online and will be conducted ASAP.

Handouts for this discussion were the "Overall Program for CSSA Based on Consent Order Tasks" and the "Cost Guess-timates for Not-Yet-Funded, Potential High Priority Actions under Consent Order." The following items were agreed upon as preferred actions for the next delivery order for CSSA.

Interim Measures SOW of the Consent Order:

	Mapping all wells with ¼ mile of CSSA (IM SOW 2.b)
	Determine disposition of soils at B-8, -20, -24, -28, and DD (IM SOW 2.e)
	Quarterly progress reports for the IM (IM SOW 3.a)

RCRA Facility Investigation (RFI) SOW of the Consent Order:

	Data Collection Quality Assurance Plan (FSP) (RFI SOW 2.B). It was agreed to use the extensive RL17 FSP to the extent possible with updates as necessary.
	Health and Safety Plan (RFI SOW 2.D). It was agreed to use the extensive RL17 HSP to the extent possible with updates as necessary.
	Surface water and sediment characterization (RFI SOW 3.A.3). Jo Jean and Brian will discuss further; due to funding constraints, this action is recommended for Year 2 of the RFI.

It was not feasible to address other portions of the RFI until more planning and data collection has taken place. Parsons ES is to email the "Overall Program for CSSA Based on Consent Order Tasks" (5 April 1999) to AFCEE, CSSA, EPA, and TNRCC.

Other

	3-D seismic reflection survey if possible (Rene will talk to Dr. Ewing).
	If Dr. Ewing does not believe that the geophysical surveys will be helpful beyond what is already known, then the team will plan 4 pilot holes, to be completed as cased, 6-inch diameter for pump installations at the bottom of the Cow Creek limestone (about 480-500 feet below ground). The wells will be close to source areas, and potentially "horseshoe" around the source areas. Parsons ES will cost the pilot hole drilling for AFCEE and CSSA to decide if the costs will fit into the DO23 funds for well installation, or if the funds are best placed on a new delivery order. Onsite lab costs will also be considered.
	TPDES permit update and cost estimate
	Environmental Encyclopedia and GIS updates (Brian will need to decide what should be included, as it may be cost prohibitive to include all items discussed this spring, such as LAN, MODFLOW Visual links, permits list, placement of all CSSA features and utilities, etc.) Julie and her GIS team will follow up on this item with Brian and estimate costs.
	Cost estimates for team meeting with Radian, and handling of Radian-generated data for the GIS and Trellix-Website.
	Lab audits and data validation for new labs under the QAPP (with and without forms).
	Parsons ES will review the KVA flowmeter equipment and costs.
	Background monitor wells; Parsons ES will estimate the costs of installation.
	Cost estimate for meeting with AFCEE GIS staff to set up ArcView at AFCEE

Agreed-Upon Action

Parsons ES:

	Review the meeting minutes with Kirk.
	Ask Kirk about TNRCC’s review process for laboratory variances from the project’s data quality program.
	Discuss use of 5030 rather than 5035 for resampling points previously analyzed by ITS.
	Ask about TNRCC’s review of projects using SW-846 + CLP procedures
	Request TNRCC’s review of lab audits and subsequent corrective actions.
	Discuss a phased approach for SWMU closures if SW-846 + CLP lab reporting is used.
	Discuss use of Environmental Encyclopedia rather than draft IRF.

AFCEE and CSSA:

EPA and TNRCC: