Interim/Stabilization Measures

Interim Measures (IM) will be conducted to mitigate a current or potential threat to human health and/or the environment. The individual tasks and percent of each IM task represents are shown in the pie chart below. The IM is estimated to represent approximately 20% of the required actions at CSSA. At the end of Quarter 1, the IM is approximately 5% complete.

Task I - Interim/Stabilization Measures Work Plan

The Interim/Stabilization Measures Workplan includes A) a description of on-going and planned interim measures; B) a statement of the objectives of each interim/stabilization measure, including how the measure mitigates a potential threat to human health and the environment and is consistent with and integrated into any long-term remedy for CSSA; and C) proposed locations, design plans and specifications, construction, operation, and maintenance requirements of the interim measures, including a sampling and analysis plan. To the extent possible, existing plans which are included in CSSA’s Environmental Encyclopedia will be referenced. As of August 2, 1999, completion of this task has been fully funded (under delivery order RL74).

This task makes up approximately 7% of the IM phase. Approximately 64% of this task has been completed as of the end of Quarter 1.

No new findings associated with the IM Workplan during this Quarter.

No changes associated with the IM Workplan during this Quarter.

No contacts related to the IM Workplan were made during this Quarter.

No problems related to the IM Workplan during this Quarter.

No actions to correct problems necessary during this Quarter.

Parsons Engineering Science (Parsons ES) will submit the draft IM Workplan to CSSA and the Air Force Center for Environmental Excellence (AFCEE) for their comments. CSSA and AFCEE will provide comments to Parsons ES; Parsons ES will incorporate their comments, and the draft final IM Workplan will be submitted to EPA by September 1, 1999.

No daily reports, inspection reports, or data related to the IM Workplan generated during this Quarter.

Task II - Interim/Stabilization Measures Implementation

The Interim/Stabilization Measures Implementation includes sampling and analysis of groundwater in off-site wells; sampling and analysis of groundwater in CSSA wells; location of all off-site water wells located within ¼-mile of the facility boundary; evaluation of alternative measures and implementation of selected interim measures at the oxidation pond (SWMU O-1); closure of SWMU O-1; characterization and determination of proper disposition of SWMUs B-8, B-20, B-24, B-28, and the Demolition Dud Area (DD) soil piles; and implementation of the identified disposition method.

As of August 2, 1999, completion of this task has been partially funded. One round of sampling and analysis of three off-site wells (under RL74) and eight rounds of sampling and analysis of CSSA wells has been completely funded (under DO23, RL74, and RL83), along with interim measures and closure of SWMU O-1 (under RL74). An appropriate disposition method will be identified for the soil piles (under RL83). However, final implementation of that disposition method has yet to be funded. Due to the amount of soil in these piles, it is anticipated that funding may have to be spread over several years.

This task makes up approximately 70% of the IM phase. With the June and July 1999 disposal of B-20, B-32, and B-33 soil piles containing elevated lead levels, this task is considered to be 3% complete.

Soil piles containing shot from B-32 and B-33 were stabilized prior to disposal. A total of 215 cubic yards of stabilized soil from these two sites were disposed of. Nonhazardous waste was disposed of at WMI’s Covel Gardens Landfill in San Antonio. Soil piles from B-20/21 were disposed of as hazardous waste and were treated to meet LDR standards by the landfill. A total of 100 tons of soil from the B-20/21 site were disposed.

Stabilization treatability studies indicated that the soils at B-20/21 could not attain treatment goals for disposal; therefore, the waste was disposed of as hazardous at Texas Ecologists’ Robstown Landfill.

No contacts related to the IM Implementation were made during this Quarter.

One of the interim measures, groundwater monitoring, has been delayed by difficulties in finding a laboratory capable of meeting SW-846 and AFCEE Quality Assurance Project Plan (QAPP) requirements; however, results of a recent audit of O’Brien & Gere Laboratory in Syracuse, New York indicate that this laboratory may be suitable. Final corrective actions by the laboratory are anticipated to be completed by mid-August, 1999.

No actions necessary.

With the possible exception of groundwater sampling and analysis, interim measures will commence after EPA has approved the IM Workplan. Because CSSA had a groundwater sampling and analysis program in place before the Order was signed, it is planned that this work will be initiated prior to workplan approval. CSSA would like to conduct a round of groundwater sampling and analysis, including sampling and analysis of three off-site wells, as soon as possible after the laboratory has been procured. This sampling and analysis will be conducted in the same manner as previous rounds; however, pending approval from the Texas Natural Resource Conservation Commission (TNRCC), analytes will be limited to trichloroethene (TCE) and related compounds (tetrachloroethene (PCE), cis-1,2-dichloroethene (cis-1,2-DCE), trans-1,2-dichloroethene (trans-1,2-DCE), and vinyl chloride (VC)) and metals. This abbreviated groundwater analyte list was approved by EPA at a meeting held April 5, 1999 at the Parsons ES office in Austin, Texas.

Other interim measures, which will commence after EPA approval of the IM Workplan, include IM at SWMU O-1 and determination of an appropriate disposition of soil piles at SWMUs B-8, B-20, B-24, B-28, and DD.

No daily reports, inspection reports, or data related to the IM Implementation generated during this Quarter.

Task III - Reports

Reports associated with the IM include progress reports and an Interim/Stabilization Measure Report. This progress report is submitted as part of this task. The IM Report will document all IM activities conducted at the facility. In addition, where appropriate, it will document whether the project is consistent with design specifications and whether the IM is performing adequately.

As of August 2, 1999, completion of this task has been partially funded. Progress reports for two years (August 1999 – May 2001) have been funded (RL83). In addition, the IM Report associated with SWMU O-1 has been completely funded (RL74). While the determination of an appropriate disposition method for the soil piles has been funded, actual completion of the soil pile IM will likely be spread over several years due to funding difficulties. Therefore, completion of an IM Report for the soil piles has not yet been funded.

This task makes up approximately 23% of the IM phase. With completion of this progress report, this task is approximately 2% complete.

This task has not been initiated.

This task has not been initiated.

No contacts related to the IM Report were made during this Quarter.

This task has not been initiated.

This task has not been initiated.

No work projected for this task during the next Quarter.

No daily reports, inspection reports, or data related to the IM Report generated during this Quarter.