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1st Quarter - Final Quarterly Progress Report
RCRA Facility Investigation
The RCRA Facility Investigation (RFI) will be conducted to characterize the environmental setting of CSSA, define the sources of contamination, define the degree and extent of contamination, and identify actual or potential receptors. The individual tasks and percent of the RFI that each task represents are shown in the piechart below. The RFI is estimated to represent approximately 35% of the required actions at CSSA. At the end of Quarter 1, the RFI is approximately 7% complete.
Task I - Preliminary Report: Description of Current Conditions
This task includes preparation of the Description of Current Conditions (DCC) Report. The DCC Report includes information from previous investigations and other relevant data. Information related to the facility background, nature and extent of contamination, and pre-investigation evaluation of corrective measure technologies is included in the DCC Report. CSSA’s Environmental Encyclopedia is used to meet the DCC Report submittal requirements.
As of August 2, 1999, completion of this task has been fully funded (under delivery order RL74).
Percent Complete
This task makes up approximately 5% of the RFI phase. Approximately 95% of this task has been completed as of the end of Quarter 1.
Summary of Findings
As this is a review of known information, there were no new findings during this Quarter.
Summary of Changes
No changes associated with the Preliminary Report during this Quarter.
Summary of Contacts
No contacts related to the Preliminary Report were made during this Quarter.
Summary of Problems
No problems related to the Preliminary Report during this Quarter.
Actions Taken to Correct Problems
No actions to correct problems necessary during this Quarter.
Projected Work for the Next Quarter
The draft final DCC Report will be submitted to EPA on August 2, 1999. Comments from EPA will be responded to and incorporated into the final DCC Report. In addition, electronic copies of the Groundwater Investigation and Source Characterization Report (Parsons ES, June 1996), the B-20 Remedial Investigation Report (Parsons ES, June 1995), and Addendum to the B-20 Remedial Investigation Report (Parsons ES, June 1996) will be provided to the EPA and TNRCC during the next quarter.
Copies of Daily Reports, Inspection Reports, Data, etc.
No daily reports, inspection reports, or data related to the DCC Report generated during this Quarter.
The Order requires that the RFI Workplan include a Project Management Plan, Data Collection Quality Assurance Plan, Health and Safety Plan, and Community Relations Plan (CRP). As previously agreed by EPA, CSSA’s Environmental Encyclopedia, which includes all of the information required by the Order, with the exception of the CRP, but in a slightly different format, will be used to fulfill this requirement.
As of August 2, 1999, completion of this task has been funded for the RFI tasks that have been planned.
Percent Complete
This task makes up approximately 10% of the RFI phase. As of the end of Quarter 1, this task is approximately 27% complete.
Summary of Findings
No new findings associated with RFI Workplan preparation during this Quarter.
Summary of Changes
Five additional areas of concern (AOCs) were discovered through review of historic aerial photographs and records during this Quarter. These additional AOCs, AOCs 63, 65, 66, 67, and 68, have been added to the RFI Workplan. Descriptions of these new AOCs are included in the DCC Report.
In addition, although EPA and TNRCC were initially notified that an EM-61 geophysical instrument would be used for surface geophysical surveys planned for several AOCs, it was later determined that a combination of EM-31 and ground penetrating radar (GPR) equipment would be more appropriate to detect the presence of trenches. EPA was notified of this change in an advance copy of the workplan for the geophysical surveys faxed on July 16, 1999.
No other changes associated with the RFI Workplan during this Quarter.
Summary of Contacts
No contacts related to the RFI Workplan were made with local community groups or public interest groups during this Quarter.
On May 10, 1999, Susan Roberts and Julie Burdey of Parsons ES visited Mr. Kirk Coulter of TNRCC to brief him on the outcome of the April 5, 1999 meeting with EPA, CSSA, AFCEE, and Parsons ES. Subsequently, on July 12, 1999, a letter including the following items was sent to Mr. Coulter:
Copy of signed 3008(h) Order;
Notification of intent to close sites under 30 Texas Administrative Code (TAC) 335, Subchapter S;
Copy of minutes from April 5, 1999 meeting with EPA, CSA, AFCEE, and Parsons ES;
Request for approval of laboratory reporting limits;
Request for approval of abbreviated groundwater analyte list;
Request for approval of laboratory variances from version 3.0 of the AFCEE QAPP;
Request for approval to use Method 5030 rather than Method 5035 for extraction of volatiles samples;
Request for TNRCC review of laboratory audit reports; and
Request for use of encyclopedia format for reporting.
In addition, on July 12, 1999, Mr. Coulter was notified of geophysical surveys planned for July 26, 1999
Summary of Problems
No problems associated with the RFI Workplan during this Quarter.
Actions Taken to Correct Problems
No actions to correct problems necessary during this Quarter.
Projected Work for the Next Quarter
The RFI Workplan will be submitted by September 1, 1999. This plan will consist of pages that will need to be added to the Environmental Encyclopedia, which will initially be submitted by August 2, 1999. Where applicable, workplans previously completed, but for which the work has not yet been conducted, are considered to be the RFI Workplans for those sites. Workplans for work that must be redone due to ITS Laboratory’s questionable practices will also be considered to be the RFI Workplans for the affected sites.
The RFI Workplan will include the CRP. To complete the CRP, interviews with up to 20 community members and local government leaders will be necessary. These interviews will be used to gauge the level of public interest in environmental activities at CSSA, as well as to determine how the public prefers to be informed (fact sheets, meetings, Internet, etc.). This information will be used to prepare the CRP during Quarter 2. CRP questionnaires that will be used to gain information on community concerns during the interviews will be finalized.
Copies of Daily Reports, Inspection Reports, Data, etc.
No daily reports, inspection reports, or data related to the RFI Workplan generated during this Quarter.
Task III - Facility Investigation
An investigation of the facility will be conducted to A) characterize the environmental setting of the facility; B) define the source(s) of contamination; C) define the nature and extent of contamination; and D) identify actual or potential receptors. In some cases, multiple phases of investigation may be necessary. The investigation results will be used to develop and evaluate alternatives during the Corrective Measures Study. All investigation activities will be conducted in accordance with the RFI Workplan.
As of August 2, 1999, completion of this task has been partially funded for the RFI tasks that have been planned. Investigation of all of the SWMUs has been funded, but investigation of 31 of the 36 AOCs has not. However, plans are currently underway to initiate another project to address many of the AOCs that have not been funded.
Percent Complete
This task makes up approximately 45% of the RFI phase. As of the end of Quarter 1, this task is less than 0.5% complete. This small percentage includes EM-31 and GPR geophysical surveys at five AOCs (AOC 47, 48, 52, 56, and 61) which were begun during the week of July 26, 1999.
Summary of Findings
Geophysical survey data are still being evaluated. No findings this Quarter.
Summary of Changes
No changes associated with the RFI during this Quarter.
Summary of Contacts
As described above, EPA and TNRCC were notified on July 12, 1999 of initiation of geophysical surveys. No contacts related to the RFI were made with local community groups or public interest groups during this Quarter.
Summary of Problems
No problems associated with the RFI during this Quarter.
Actions Taken to Correct Problems
No actions to correct problems necessary during this Quarter.
Projected Work for the Next Quarter
Upon EPA’s approval of the RFI Workplan, the facility investigation will commence.
Copies of Daily Reports, Inspection Reports, Data, etc.
No daily reports, inspection reports, or data related to the RFI generated during this Quarter.
Task IV - Human Health and Ecological Risk Assessment
This task includes a screening risk assessment, or if necessary, a baseline risk assessment for the potential human health and environmental risks posed by the site in absence of any remedial action. For human health risks this effort will involve the following components: 1) contaminant identification; 2) exposure assessment; 3) toxicity assessment; and 4) risk characterization. For ecological risks, the effort will include the following components: 1) problem formulation; 2) exposure assessment; 3) ecological effects assessment; and 4) risk characterization.
As of August 2, 1999, completion of this task has been partially funded. Currently planned and funded (under RL83) is preparation of a preliminary base-wide human health and ecological conceptual Site Model (CSM) for risk assessment. The CSM will identify potential human and ecological receptors and land use surrounding the facility. In addition, a Risk Assessment Technical Approach and Plan will be prepared. The preliminary CSM will later be refined as additional investigation information is available.
This task makes up approximately 15% of the RFI phase. It was not active during Quarter 1, and no actions are anticipated during Quarter 2.
Task V - Investigation Analysis
This task includes preparation of an Investigation Analysis to support the selection of protection standards for CSSA. It will be submitted along with the Risk Assessment Report, and it will describe the extent of the contamination in relation to background levels indicative for the area around CSSA. It will also include groundwater protection standards, background levels in groundwater, and other relevant protection standards.
As of August 2, 1999, completion of this task has been partially funded. Currently planned and funded (under RL83) is installation of two background monitoring wells (pending analytical results).
This task makes up approximately 15% of the RFI phase. It was not active during Quarter 1, and no actions are anticipated during Quarter 2.
Task VI - Treatability Studies
This task may include a Treatability Study Program, if so directed by EPA. Treatability studies are performed to determine the applicability of corrective measure technologies to conditions or problems at or resulting from waste management activities at CSSA. Where it is determined by EPA that treatability testing is necessary, candidate technologies will be identified, a treatability study workplan will be prepared, the treatability study(ies) will be implemented, and a treatability study report will be prepared.
As of August 2, 1999, completion of this task has been partially funded. Currently planned and funded (under RL33) is completion of a treatability study report for SWMU B-20. Previously, phytoremediation, gravity separation, and stabilization studies were completed, included in Volume 4 of the Environmental Encyclopedia. A second part to the gravity separation test is also being considered. Additional plans for study of treatment technologies are included as part of the Interim Measures phase of work.
In addition to the B-20 treatability studies, an electrokinetics treatability study has been completed at SWMU O-1, and several phases of an SVE treatability study have been underway at SWMU B-3.
This task makes up approximately 10% of the RFI phase. It was not active during Quarter 1, and no actions are anticipated during Quarter 2.
This task includes quarterly progress reports pertaining to the status of the RFI phase of work. This progress report is submitted as part of this task.
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).
Percent Complete
This task makes up approximately 5% of the RFI phase. With completion of this progress report, this task is approximately 7% complete.
Summary of Findings
No findings associated with the Progress Reports during this Quarter.
Summary of Changes
No changes associated with the Progress Reports during this Quarter.
Summary of Contacts
No contacts related to the Progress Reports were made during this Quarter.
Summary of Problems
No problems related to the Progress Reports during this Quarter.
Actions Taken to Correct Problems
No actions necessary.
Projected Work for the Next Quarter
Progress Report for Quarter 2 will be submitted.
Copies of Daily Reports, Inspection Reports, Data, etc.
No daily reports, inspection reports, or data related to the Progress Reports generated during this Quarter.