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MEeting Minutes
Facility Investigations, Closure Projects,

and Well Installations
Camp Stanley Storage Activity
F11623-94-D0024/ rl83
Parsons ES 736071.02

Date: 24 September 1999

Time:  9:30 A.M. - 4:00 P.M.

Place:  Camp Stanley Storage Activity, Boerne, Texas

Subject: Technical Interchange Meeting #1
RL74, RL83, and DO23

Attendees:

Attendee

Organization

Phone

Greg Lyssy

EPA Region 6

(214)665-8317

Brian K. Murphy

CSSA ENV

(210)698-5208

Rene G. Hefner

AFCEE/ERC

(210)536-4763

Edward J. Brown

AFCEE/ERC

(210)536-5665

Brian Howard

AFCEE/ERC

(210)536-4755

Roger Peebles

WPI/TCAT

(210)321-5115

Michael (Moe) Ghazizadeh

WPI

(210)321-5114

Chris Beal

WPI/CSSA

(210)698-5208

Susan Roberts

Parsons ES-Austin

(512)719-6051

Scott Pearson

Parsons ES-Austin

(512)719-6087

Steve Rembish

Parsons ES-Austin

(512)719-6067

Tien-Yu (Tammy) Chang

Parsons ES-Austin

(512)719-6092

Minutes prepared by Susan Roberts, Parsons ES, and Chris Beal, WPI/CSSA.

Introduction

The meeting commenced at 9:30 AM at the CSSA conference room.  Brian Murphy began the meeting by noting that two persons were not able to be present — Jo Jean Mullen, AFCEE/ERD Contract Officer Representative, and Maria Martinez, EPA Region 6 Toxicologist. Susan Roberts began by stating to all that as Jo Jean was not able to be present at the meeting, no discussions can be considered final.  Parsons ES will provide a briefing to Jo Jean, and after AFCEE's and CSSA's review of draft meeting minutes, Parsons ES will prepare final minutes.

Greg Lyssy stated his objectives for the meeting are to:

  1. Have the EPA toxicologist view CSSA grounds, which is not possible today as Maria could not be present.

  2. Be briefed on the status of the projects and work since the last meeting that he attended in April 1999.

  3. Project future work (i.e. critical paths).

Introductions were followed by discussion of each project's status by Susan Roberts, with comments from others at the meeting as noted.

PROJECT STATUS AND DISCUSSION OF RECENT FIELD WORK

Each of the following delivery orders were discussed along with a status table presented in the meeting materials.

Delivery Order AMC RL17 (SWMU Investigations and Waste Mgt. Plan)

Work actions completed:

Outstanding:

Delivery Order AFCEE DO23 (Groundwater Monitoring and Well Installations, Upgrades)

Work actions completed:

Outstanding:

ACTION 1: Greg Lyssy wants to be called immediately if the Sept 99 sample analyses show any hits.  Parsons ES will ensure this is done.  [Note — Parsons ES called EPA, CSSA, and AFCEE on 30 Sep 99 when the onsite well results were received.  All results were as anticipated for a drought; chlorinated compound concentrations were detected in wells 16, MW-1 and MW-2 at lower levels than the November 1998 monitoring event which took place after high rainfall.  Results of offsite well results were e-mailed to EPA, CSSA, and AFCEE on 4 Oct. 99.  No volatile organic compounds (with the exception of very low levels of methylene chloride) were detected in the offsite wells.  All concentrations were below MCLs.]

ACTION 2: As Parsons ES was not able to download weather station data, Chris Beal said that he should be able to give it a try next week.  [Note — CSSA sent the downloaded weather station data via email to Parsons ES on 1 Oct 99.  The data files will be checked during the first week of October.]

Delivery Order AMC RL33 (SWMU and UXO Investigations; GIS Development)

Work actions completed:

Outstanding:

Delivery Order AMC RL53 (SWMU Investigations)

Work actions completed:

Outstanding:

Delivery Order AMC RL74 (Facility Investigations and Closures)

Work actions completed:

Outstanding:

ACTION 3: Parsons ES to check on the status of the draft SVE work plan addenda submittal.  [Note — this plan was submitted after 20 September 1999 to CSSA and AFCEE, and they received it on 27 September 1999.]

ACTION 4: Has the IM work plan been sent to EPA?  Susan said that it should be part of the Environmental Encyclopedia submittal on 2 Sep 99.  Parsons ES will check. .  [Note — this plan was submitted on 2 September 1999 to EPA, CSSA and AFCEE as part of the Environmental Encyclopedia.]

ACTION 5: When working on the mapping of wells within ¼ mile of CSSA, Scott found a well just southwest of CSSA.  Greg would like this well sampled during the next round.  Parsons ES will discuss this potential action with Jo Jean.  [Note — this action was discussed with Jo Jean on 29 September 1999, and pending a check on the scope of the DO23 project, it appears that the necessary sample and analysis can be conducted under AFCEE DO23.]

ACTION 6:  Roger Peebles recommended that Parsons ES get pumping records and other hydrologic data as available for the FairCO wells just west and northwest of CSSA.  [Note:  it was agreed that as Scott Pearson will be away for 2 weeks, Chris Beal, Brian Murphy, and Rene Hefner would undertake this discussion with FairCo during the first week of October 1999.  The FairCO meeting took place on October 5, 1999, and minutes from the meeting were provided to AFCEE, Parsons ES, and WPI.]

Delivery Order AMC RL83 (RFI, Closure Projects, and Well Installations)

Work actions completed:

Outstanding:

  1. Use well research for evaluation of groundwater receptors.

  2. Site visit to CSSA with EPA Toxicologist to review grounds and look for potential receptors and pathways.  Steve Rembish to coordinate with Brian Howard, Greg Lyssy, and CSSA on schedule for visit; tentatively discussed for 21-22 Dec 99.

  3. Preparation of basewide CSM.

  4. Preparation of Risk Assessment Technical Approach document.  Due to TNRCC's nonavailability to attend meetings, this may be the first time that CSSA receives input from TNRCC regarding risk assessment.

ACTION 7:  Discuss future drilling at B-56, B-48, and B-58, as these 3 sites had geophysical anomalies detected during the August 1999 survey.  Drilling is not currently scoped for these sites under RL83.

ACTION 8:  Discuss Data Chem RLs with Jo Jean, and Greg Lyssy's notes on how to approach TNRCC.  Further discussed below under "Lab Issues".

ACTION 9:  Steve Rembish to coordinate with AFCEE, EPA toxicologist via Greg Lyssy, and CSSA on a risk assessment site visit.

ACTION 10:  Send electronic CRP to Brian Murphy.

ACTION 11:  Check with Steve Schrader on when comments are due for the TPDES permit update.  [Note — the comments are due 29 September 1999.  CSSA and AFCEE to contact Parsons ES if an extension request will need to go to TNRCC, which Steve Schrader will oversee.]

GEOPHYSICAL SURVEYS

The handout included preliminary maps and evaluation of the EM and geophysical surveys completed in August 1999 under RL83.  Anomalies found at AOC-48, AOC-56, and AOC-58.  Scott noted that the EM was consistently more informative than GPR data.  Based on results, Parsons ES will discuss future scope for soil borings at AOCs 48, 56, and 58 with AFCEE and CSSA.  Currently under scope is collection of surface soil samples at AOC-47 and 61, where there were no anomalies.  Greg said that the approach of future drilling at the three AOCs with geophysical anomalies is OK.  Susan said that such a potential action will require discussion as a data gap with AFCEE and CSSA.  RL83 work tentatively scheduled for Nov., pending resolution of laboratory issues.

GROUND WATER

Completed September 1999 sampling event.  Tammy said that the lab reports are due from O'Brien & Gere about 10/11/99.  Will take 45 days to validate.  Next monitoring event scheduled for November or December 1999.

Latest gradient map was presented as a draft at the meeting, and shows a southwest gradient (consistent with normal drought conditions).  A graph of Well 16 groundwater elevation vs. precipitation data was also presented.  Roger noted that the potentiometric lines could also be drawn towards the west-northwest, if we knew more about the pumping of two FairCO wells that Scott found near the central area of the western CSSA boundary.

Susan stated that she would like to tentatively discuss the well locations.  As she and Jo Jean have not connected this week, and the draft August 10 meeting minutes are not finalized, no materials will be handed out for the discussion.  All notes will be reviewed by AFCEE prior to sending them out for final discussion.

Susan discussed proposed well locations, and said that she found general agreement with locations of:

CW-1 — upgradient of Wells D and 16 in the north pasture.  [Note:  Jo Jean Mullen, who could not be present at the meeting, later indicated that she disagreed with the placement of CW-1.]

CW-2 — located between SWMUs B-3 and O-1.

CW-3 — located to the west within the northern fault zone, between Wells D and 16 and Wells 9, 10, and 11 (CSSA water supply wells).

MW-3 — located in northern fault zone and east of Wells D and 16.

The group discussed the potential to keep locations of remaining wells flexible pending analytical results from initial drilling.  Other potential well locations include:

1)  A location further upgradient of CW-1, if CW-1 is found to contain COCs.

2)  In the CSSA H&I area, within fault zone, and west-southwest of MW-1.

3)  If MW-5 is found to contain COCs, a second well location near the southwest corner of CSSA (near old well 6 location).  Greg Lyssy said that the need for this well could be evaluated pending the analytical results of off-site well sampling in the same vicinity.

4)     A location south-southeast along Salado Creek, outside of fault zone.

5)     A location to the northwest, between well #16 and the FairCO well on Ralph Fair Road.

Preliminary Well Sampling — The idea of collecting preliminary water samples from each well immediately after installation and development was discussed.  The value of these screening samples could be to further delineate the next well locations.  Parsons ES can evaluate the changes in cost and schedule that may be caused by the drilling/ development plan.  Initially, Parsons had intended to drill all the wells followed by development after all drilling was complete.  CSSA said that it was possible for them to take on the costs of getting additional samples analyzed, if the results could be used for screening.

[Note from Parsons ES - There are no provisions under RL83 for 24-hour turnaround time for VOCs.  The original estimate was for 12 borehole samples to be analyzed for metals and anion/cations.  By drilling and developing concurrently, some costs may be increased by the time necessary to re-tool at each location, and there would be increased mob/demob costs.  Parsons ES is willing to look into the schedule and cost implications should AFCEE and CSSA be interested.]

Cluster Well Plans — 1) Open hole versus screening target intervals in the cluster wells was discussed.  EPA verbally agreed to keeping the completions open hole as long as each open hole interval was adequately separated from other target zones.  2) Consideration was given to the idea of testing each target zone in 2 or 3 of the cluster wells.  Then, if the preliminary sampling indicated the Cow Creek and or Bexar Shale were not contaminated, the need for the last cluster well(s) would be re-evaluated.  This would potentially free up two additional wells for further plume delineation.  Should AFCEE consider this viable, final decision on this approach would await initial analytical results.  3) Roger Peebles stressed that an open hole completion would allow for groundwater sampling at target intervals throughout the borehole.  He suggested that diffusive sampling be considered for characterizing stratified groundwater conditions.  Roger will send technical approach information to Chris Beal.

ACTION 12: The draft meeting minutes from the August 11 meeting need to be finalized and sent to the regulators. 

ACTION 13:  Susan's recommendations for discussion on well locations must be reviewed by Jo Jean.  Should any of the recommendations be considered viable, Parsons ES will provide a memo to AFCEE for further review.  If approved, this memo can be sent after the final August 11 meeting minutes.

ACTION 14:  Roger Peebles to send technical information on diffusion sampling to Chris Beal.

RISK ASSESSMENT ACTIONS

The EPA Toxicologist Maria Martinez could not attend the meeting.  Brian Howard attended for AFCEE.  Steve Rembish highlighted some of the changes between "Old" TNRCC Risk Reduction Standards and the "New" Texas Risk Reduction Program (TRRP), using a table prepared for the meeting's handouts.  Steve indicated that a letter requesting closure under the "old" rules for CSSA sites where investigations have begun was submitted to TNRCC on July 12, 1999.  To date, no response has been received.  [Note:  Parsons ES received TNRCC’s response on October 8, 1999.  Kirk Coulter approved all requests included in the letter.]  Steve is waiting on the finalization of the off-site well location and owner report to get started on the risk assessment CSM.  Steve, Brian Murphy, Brian Howard, and Greg tentatively discussed returning for a site visit and field work in December 1999.  The site visit will be followed by preparation of a basewide CSM and a risk assessment technical approach documents.  Steve expressed reservations about getting TNRCC to offer much input prior to submittal of final risk document.  TNRCC has been very reluctant to participate in scoping meetings.

Susan said that a letter was sent to TNRCC in July 1999 requesting approval of various issues discussed at the last meeting in April 1999.  It may be a good time to re-visit Kirk Coulter, TNRCC coordinator for CSSA work.

LAB ISSUES

Dioxins/furans — Tammy discussed the work to date.  Variances from the QAPP have been requested by all labs.  Parsons ES is waiting on risk sensitivity study to determine what variances will do to risk.  Discussed using PCB/pesticides as screening, but risk assessors reminded the group that the dioxin/furans analysis are necessary to the state to review the I-1 incinerator investigation and potential closure.  Tammy said that a potential lab for these analyses is Triangle out of North Carolina.

ACTION 15: Ed Brown said he will check the Triangle variances recently submitted on another AFCEE project.  If the variances are the same, then the review process may be expedited.

Explosives — DataChem is the potential lab.  Tammy provided a summary of variance requests.  Parsons ES is waiting on determination of how variations will affect risk and a 1-day lab audit.  The RL exceedance of one TNRCC risk reduction number was discussed.  Greg suggested that CSSA decide what the COCs are per site, then work through the DQO process to show what is at risk.

ACTION 16:            The discussion indicated that all 3 labs (O&G, APPL, and Data Chem) have one or more RLs above either "old" or "new" risk reduction comparison numbers, and the paucity of labs qualified to do this method under the base QAPP.  Parsons ES would like to recommend to Jo Jean that an audit go forward with Data Chem, and that the team try to work with TNRCC on acceptable RLs for compounds of concern.

Air — Air analyses are fairly routine and labs contacted have indicated no problems with QA/QC requirements.  Tammy said that Environmental Analytical Services of San Luis Obispo looks good.

Parsons sent a letter regarding O&G and APPL lab variances to TNRCC in July of 1999.  To date, the CSSA TNRCC coordinator, Kirk Coulter, has not responded.  [Note:  Response to July 12 letter to TNRCC was received on October 8, 1999.  Kirk Coulter approved all requests.]

ACTION 17:  Pending Jo Jean's approval, Susan Roberts will arrange for meeting with Kirk Coulter to discuss variance request.  [Note:  Since TNRCC responded to the July 12 letter, a meeting to discuss those variance requests is not needed.  However, a meeting with TNRCC to discuss planned field work and explosives variances may be warranted.]

SCHEDULE

A draft schedule from May 1999 through May 2000 was presented for discussion.  It seems to be a good idea to have a working schedule that looks ahead to the next 6 months, as well as the overall schedule for all of the major actions to be conducted under the Administrative Order.  The draft overall schedule was presented at the 30 June 99 meeting. 

ACTION 18: Brian and Chris at CSSA, and AFCEE to give input on the schedule.

SUMMARY OF ACTIONS

Parsons ES

ACTION 1:  Parsons ES to call Greg Lyssy immediately if the Sept 99 sample analyses show any hits.  [Note — Parsons ES called EPA, CSSA, and AFCEE on 30 Sep 99 when the onsite well results were received.  All results were as anticipated for a drought; chlorinated compound concentrations were detected in wells 16, MW-1 and MW-2 at lower levels than the November 1998 monitoring event which took place after high rainfall.]

ACTION 3:  Parsons ES to check on the status of the draft SVE work plan addenda submittal.  [Note — this plan was submitted after 20 September 1999 to CSSA and AFCEE, and they received it on 27 September 1999.]

ACTION 4:  Parsons ES will check on submittal of the IM Work Plan to EPA. .  [Note — this plan was submitted on 2 September 1999 to EPA, CSSA and AFCEE as part of the Environmental Encyclopedia.]

ACTION 5:  Parsons ES will discuss with Jo Jean additional sampling during the next round of groundwater monitoring.  Greg would like the well just southwest of CSSA to be sampled.  [Note — this action was discussed with Jo Jean on 29 September 1999, and pending a check on the scope of the DO23 project, it appears that the necessary sampling and analysis can be conducted under AFCEE DO23.]

ACTION 7:  Parsons ES to discuss future drilling at AOC-56, AOC-48, and AOC-58 with AFCEE and CSSA.  These 3 sites had geophysical anomalies detected during the August 1999 survey.  Drilling is not currently scoped for these sites under RL83.  [Note – recommended actions at these sites was discussed at the 3 Feb 00 teaming meeting.]

ACTION 8: Parsons ES to discuss Data Chem RLs with Jo Jean, and Greg Lyssy's notes on how to approach TNRCC.  [Note – this item discussed with Jo Jean on 29 Sep 99, and it was decided to go ahead with the Data Chem audit.]

ACTION 9:  Steve Rembish to coordinate with AFCEE, EPA toxicologist via Greg Lyssy, and CSSA on a risk assessment site visit.  [Note – Risk assessment site visit was held in December 1999.]

ACTION 10: Parsons ES to send electronic CRP to Brian Murphy.

ACTION 11:  Check with Steve Schrader on when comments are due for the TPDES permit update.  [Note — the comments are due 29 October 1999.  CSSA and AFCEE to contact Parsons ES if an extension request will need to go to TNRCC, which Steve Schrader will oversee.]

ACTION 12: Upon receipt of comments from AFCEE and CSSA, Parsons ES to finalize the August 10, 1999, meeting minutes and send to the regulators. 

ACTION 13:  Susan's recommendations for discussion on well locations must be reviewed by Jo Jean.  Should any of the recommendations be considered viable, Parsons ES provide a memo to AFCEE for further review.  If approved, this memo can be sent after the final August 11 meeting minutes.  [Note – this discussion took place on 29 Sep 99, and a memo detailing that discussion will be prepared by Parsons ES.]

ACTION 16: The discussion indicated that all 3 labs (O&G, APPL, and Data Chem) have one or more RLs above either "old" or "new" risk reduction comparison numbers, and the paucity of labs qualified to do this method under the base QAPP.  Parsons ES would like to recommend to Jo Jean that they go forward with an audit of Data Chem, and that the team try to work with TNRCC on acceptable RLs for compounds of concern.  [Note – Jo Mullen and Ed Brown gave approval to Parsons ES on 30 Sept 99 to proceed with audit of Data Chem.  Parsons ES has tentatively set an audit date of 12 Oct 99.

ACTION 17:  Pending Jo Jean's approval, Susan Roberts will arrange for meeting with Kirk Coulter to discuss variance request.  [Note –Jo Jean gave  approval for a meeting with TNRCC.  Susan Roberts left a phone message with Kirk Coulter on 1 Oct 99.]

WPI/CSSA

ACTION 2: As Parsons ES was not able to download weather station data, Chris Beal said that he should be able to give it a try next week.  [Note — CSSA sent the downloaded weather station data via email to Parsons ES on 1 Oct 99.  The data files will be checked during the first week of October.]

ACTION 6: Roger Peebles recommended that Parsons ES get pumping records and other hydrologic data as available for the FairCO wells just west and northwest of CSSA.  [Note:  it was agreed that as Scott Pearson will be away for 2 weeks, Chris Beal, Brian Murphy, and Rene Hefner will undertake this discussion with FairCo during the first week of October 1999.]

ACTION 12:CSSA to provide comments on the draft August 10, 1999, meeting minutes (Parsons ES to finalize and send to the regulators). 

ACTION 14: Roger Peebles to send technical information on diffusion sampling to Chris Beal.

ACTION 18:  Brian and Chris at CSSA to give input on the draft schedules provided 30 June 99 and 24 September 99.

AFCEE

ACTION 12:  AFCEE to provide comments on the draft August 10, 1999, meeting minutes (Parsons ES to finalize and send to the regulators).

ACTION 15:  Ed Brown said he will check the Triangle variances recently submitted to another AFCEE project.  If the variances are the same, then the review process may be expedited.

ACTION 16:  The discussion indicated that all 3 labs (O&G, APPL, and Data Chem) have one or more RLs above either "old" or "new" risk reduction comparison numbers, and the paucity of labs qualified to do this method under the base QAPP.  Parsons ES would like to recommend to Jo Jean that they go forward with an audit of Data Chem, and that the team try to work with TNRCC on acceptable RLs for compounds of concern.  [Note – Jo Mullen and Ed Brown gave approval to Parsons ES on 30 Sept 99 to proceed with audit of Data Chem.]

ACTION 18:  AFCEE to give input on the draft schedules presented on 30 June 99 and 24 September 99.