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Minutes for Technical Interchange Meeting #5

AMC Delivery Order RL83

Parsons ES 736071.02000

Date: July 19, 2001, Thursday

Time: 8:30 A.M. - 5:00 P.M.

Place: Camp Stanley Storage Activity (CSSA), Boerne, Texas

Subject: EPA and TNRCC update

Attendees:

Attendee

Organization

Phone

Brian K. Murphy

CSSA ENV

(210) 698-5208

Jason Shirley, LTC

CSSA 

(210) 295-7416

Greg Lyssy

USEPA

(214) 665-8317

Kirk Coulter

TNRCC

(512) 239-2572

Chris Beal

WPI/CSSA

(210) 295-7417

Agnieszka Hobson

TNRCC

(210) 403-4075

Craig Meppen

TNRCC

(210) 403-4060

Abigail Power

TNRCC

(210) 403-4064

Tanya Lopez

TNRCC Intern

(210) 403-4018

Susan Roberts

Parsons ES

(512) 719-6051

Scott Pearson

Parsons ES

(512) 719-6087

Eric Tennyson

Parsons ES

(210) 828-4900

Karuna Mirchandani

Parsons ES

(512) 719-6048

Minutes prepared by Karuna Mirchandani, Parsons ES.

The meeting sign-in sheet for this meeting is in Attachment 1.

Introductions

Brian Murphy took Greg Lyssy, Susan Roberts, and Karuna Mirchandani to check possible pump test discharge sites around the base. Greg Lyssy met with the regional TNRCC staff for 30 minutes upon their arrival. 

The meeting with EPA, TNRCC, CSSA and Parsons was opened at approximately 10:00 a.m. with brief introductions.

Audit Outbriefing

Agnieszka Hobson opened the outbriefing by requesting the AOC-65/split sample results. Scott Pearson said he would send them to her by the end of the month.

Ms. Hobson went over her findings during the audit, which are as follows:

Violations

There were three “unauthorized discharges” which will be noted as NOVs. 

There were documentation violations regarding hazardous waste manifests. These will also be included as NOVs.

Ms. Hobson asked about a Source Reduction and Waste Minimization Plan. Mr. Murphy mentioned there was no requirement for this plan. 

Another document violation was noted regarding cleaning fluids used on weapons. Only one of the two waste streams generated during this process has a TNRCC waste code. Both waste streams need to be on the NOR and have waste codes.

Areas of Concern

NOR should be reviewed and updated. 

Hazardous waste determination must be made on the granular activated carbon (GAC) unit when ready for disposal; if found to be hazardous, a waste code must be identified and the NOR updated.

Ms. Hobson wanted to know if there was a letter to the laundry service regarding the rags soaked with solvent. CSSA will find out.

Labels from roll-off boxes that come from other installations need to be removed (e.g. Kelly roll-off boxes). CSSA will talk to Eagle Construction about the boxes.

Manifests for gasoline previously shipped from the motor pool could not be located. CSSA will look for them.

Miscellaneous Issues

Cleanup of Building 40 – chip vs. swipe samples. TNRCC indicated that in most cases, they do not accept swipe samples of concrete for site closure verification.

Report has not yet been finalized.

Kirk Coulter will review.

Photographs of floor/wall are important to include.

Craig Meppen will look into what kind of samples are needed. 

Mr. Meppen requested a copy of the EPA order with timeframes. Mr. Lyssy advised that the State did not need to track the Order. EPA would do so.

Hazardous waste training was also discussed. Mr. Murphy and Chris Beal need refresher training.

Coverage of stormwater permit – Since CSSA is a less than 90 day storage facility, it is not permitted as a hazardous waste facility.

CSSA was questioned regarding underground storage tanks at the base and status of their closure.

CSSA Presentation

Mr. Murphy gave a presentation on the work going on at CSSA with the intention of updating EPA and TNRCC. Mr. Murphy asked TNRCC representatives to name their point of contact in the event they were called by the media. Mr. Meppen said those type of calls would typically be directed to TNRCC Media Relations. However, in emergency situations, when camera interviews are required, Richard Garcia or Henry Karnei of the Regional Office would likely speak for TNRCC. Mr. Coulter will find out whom specifically at Media Relations to contact. He also noted that in the case of a call or visit from the media, he should be notified as soon as possible. Also discussed were the various people to notify in the event TNRCC were to receive any media calls. They are as follows:

CSSA – the Commander’s office - LTC Jason Shirley

EPA – Greg Lyssy

Public Affairs Office at Fort Sam Houston – Phil Reidinger

Abigail Power mentioned that Camp Bullis was meeting with Edwards Aquifer Authority, TNRCC, Bexar Met, and the Health Department on July 19, 2001. They are potentially going to invite all neighboring wells to be sampled. Ms. Power was also anticipating a public meeting on July 24, 2001 or August 24, 2001.

LTC Jason Shirley asked when the public would consider any action acceptable. Ms. Power replied when their water was cleaned up. The CSSA mustard gas investigation (AOC 36) was also discussed. Mr. Coulter said that issue was closed to TNRCC and was between CSSA and the public. In addition formal written notification of field activities would go through Henry Karnei, Jr, while verbal notification could go through Craig Meppen and or Abigail Powers.

Conclusion

Mr. Lyssy asked what the EPA and TNRCC were going to do about the pumping tests. TNRCC will talk to the permit folks. Mr. Coulter will talk to his contact by July 23, 2001 (Monday). Mr. Lyssy was willing to send a letter explaining EPA’s position. Mr. Meppen thought the groundwater pumped to PIMS would not be an issue.

Ms. Power will contact the PST program regarding the closure reports. She will get report titles and dates from Mr. Murphy. She will also find out about the Kelly roll-off box. Mr. Coulter will call the permit staff regarding the pump test discharge.

The meeting was adjourned at approximately 4:30 p.m. by Mr. Murphy.

Attachment 1 - Sign-in Sheet