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2nd Quarter - Final Quarterly Progress Report
RCRA Facility Investigation
The RCRA Facility Investigation (RFI) is being 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 RFI is estimated to represent approximately 30% of the required actions at CSSA. The RFI includes a Preliminary Report (5% of RFI), RFI Work Plan (10%), Facility Investigation (45%), Investigation Analysis (10%), Treatability Studies (10%), and Progress Reports (5%). At the end of Quarter 2, the RFI is approximately 15% 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.
Completion of this task has been fully funded (under delivery order RL74).
The final DCC Report was submitted to EPA and TNRCC on August 1, 1999. No regulatory comments have been received on the 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 as soon as they are available in a current electronic format.
Percent Complete
This task makes up approximately 5% of the RFI phase. This task is 100% complete.
Summary of Findings
As this was 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
No work on this task is projected for 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 Work Plan 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 (with the exception of the CRP) required by the Order, in a unique format, will be used to fulfill this requirement.
Completion of this task has been funded for the RFI tasks that have been planned.
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The RFI Work Plan and the CRP were submitted to EPA and AFCEE on September 2, 1999. To complete the CRP, an initial mailing list was developed and sent to both AFCEE and CSSA on October 29, 1999 for their comments and review. |
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The postcards include a brief description of the environmental program at CSSA. Recipients will be asked to return the postcards to CSSA if they are interested in being on the mailing list. The mailing list of approximately 2,000 people is comprised of residents in close proximity to CSSA, as well as people who indicated that they would like to receive more information during the August CRP interviews. |
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Summary of CRP Interview Results: The principal finding of the interview process is that CSSA does not have a large community presence, and thus, many people are unaware of the installation's mission as well as its environmental program. Due to its relative size and purpose, CSSA is overshadowed by the other five military installations in the San Antonio area. Ninety-two percent (92%) of those interviewed stated that they were unaware of the environmental program at CSSA, and 69% stated that they could not remember any environmental projects at the base since living or working in the area.As there has been little media coverage (i.e., only one news story cited), many interviewees felt that associated questions were not applicable.The fact that visibility of the installation is low seemed to either heighten or nullify the communities' concerns about the base. Some stated that their level of concern about environmental activities at CSSA was high, since little information is available, while others stated that they are not interested at all. In general, perception of the installation is neither positive nor negative. There seems to be a need for more information about the base in general, and about its environmental program. Response to the idea of the dissemination of information about the base seemed positive, with 85% of those interviewed wanting to be added to a mailing list. More detailed information pertaining to the August 1999 community interviews may be found in Section 5 of the Community Relations Plan, located in Volume 1-6 of the CSSA Environmental Encyclopedia. |
Percent Complete
This task makes up approximately 10% of the RFI phase. As of the end of Quarter 1, this task is approximately 95% complete. Although the RFI Work Plan was submitted in early September, additional Work Plan information related to installation of deep cluster wells and recollecting samples analyzed by ITS Laboratory will be submitted during Quarter 3.
Summary of Findings
No new findings associated with RFI Work Plan preparation during this Quarter.
Summary of Changes
No changes associated with the RFI Work Plan during this Quarter.
Summary of Contacts
Several members of the local community were contacted during the preparation of the CRP. Thirteen interviews were conducted through questionnaires for the CRP. Four of the thirteen interviewed were Federal, State, County, and City officials. Two of the thirteen interviewed were civic organizations and/or community leaders. the remaining seven individuals were local residents.
The following is a list of officials interviewed for the CRP:
Patrick Heath, Mayor of Boerne
Shelly Whitworth, Deputy Director, Alamo Area Council of Governments
Lyle Larson, County Commissioner, Precinct 3
Roy Thomas, Mayor of Fair Oaks
Linda Tom, Boerne Independent School District
Laura Syphers, Dominion Headquarters
Summary of Problems
No problems associated with the RFI Work Plan during this Quarter.
Actions Taken to Correct Problems
No actions to correct problems necessary during this Quarter.
Projected Work for the Next Quarter
During the next quarter, the mailing list of 2,000 people will be finalized. Additionally after incorporating CSSA's and AFCEE's comments on the postcards, these will be mailed out to residents who live in close proximity of CSSA.
Work plans for work that must be redone due to ITS Laboratory's questionable practices will be submitted next quarter, along with a work plan for installation of deep cluster wells.
It is anticipated that 70 surface soil samples (0-2 ft bgs) will be collected for RL17 during the next quarter. This is part of the ITS rework. These samples will be sent to APPL Laboratories and will only be analyzed for metals analyses.
In addition, 10 background soil boring samples will be collected for RL53 during quarter 3. These rock borings range from 9 to 15 feet in total depth.
Copies of Daily Reports, Inspection Reports, Data, etc.
No daily reports, inspection reports, or data related to the RFI 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 Work Plan.
Completion of this task is partially funded for the RFI tasks that are planned. Investigation of all but one of the SWMUs has been funded, but investigation of 17 of the 36 AOCs has not. During this quarter, another project was initiated to investigate one SWMU (B-9) and 12 AOCs.
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Investigations were initiated during Quarter 2. Geophysical surveys were conducted at AOCs (AOCs 47, 48, 56, 58, and 61) between July 26 and August 4, 1999. Results are summarized in Section B below. |
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In addition, efforts to procure laboratories that can meet the project data quality objectives (DQOs) continues during Quarter 2. Based on the laboratories' capabilities and the large number of samples which will be generated during the investigation, a total of five laboratories will be procured for the CSSA environmental program. The status and work done towards each of these procurements is described in the following paragraphs: |
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O'Brien & Gere Laboratory (O'B&G): O'B&G (Syracuse, NY) will provide VOCs, SVOCs, pesticides, and metals analysis of soil and water samples. O'B&G was audited by Parsons ES, AFCEE, and CSSA personnel from June 2 through June 4, 1999. A number of corrective actions were required. O'B&G demonstrated through Corrective Action Plan and the corrective actions that they were capable of addressing all of the audit concerns. O'B&G was officially procured on September 1, 1999. TNRCC approved O'B&G variances and reporting limits on October 5, 1999. |
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APPL Laboratory (APPL): APPL (Fresno, CA) will provide VOCs, SVOCs, pesticides, total ions, PCBs, and metals analysis of soil and water samples. APPL was audited by Parsons ES, AFCEE, WPI, and CSSA personnel from August 4 through August 6, 1999. A number of corrective actions were required. APPL demonstrated through the Corrective Action Plan and the corrective actions that they were capable of addressing all of the audit concerns. APPL was officially procured on November 3, 1999. TNRCC approved APPL variances and reporting limits on October 5, 1999. |
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DataChem Laboratory (DataChem): DataChem (Salt Lake City, UT) has been tentatively identified for explosives analysis of soil samples. DataChem was audited by Parsons ES, AFCEE, and CSSA personnel on October 12, 1999. A number of corrective actions were required. The Corrective Action Report (CAR) from DataChem was received by Parsons ES on October 28, 1999 and is currently being reviewed. In addition, Parsons ES is awaiting regulatory approval of DataChem's variances which were submitted to TNRCC on October 13, 1999. Our experience is that responses from the TNRCC take approximately three months, despite our requests for faster responses. Upon DataChem's demonstration of adequately meeting the project DQOs, Parsons', CSSA's and AFCEE's review and approval of the CAR, and regulatory approval of DataChem's variances; procurement for the explosives analysis will be completed. |
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Environmental Analytical Services (EAS): EAS (San Luis Obispo, CA) will tentatively provide TO-14 analysis for air samples. Parsons ES reviewed EAS' prelimiinary data package which included MDL studies, control limits, SOPs, and the instrument calibration forms. Upon AFCEE's review of EAS' preliminary data package it was discovered that EAS' QA Manual needed to be updated. The updated QA Manual is due to Parsons ES on November 17, 1999. After Parsons' approval of the QA Manual, it will be sent to AFCEE and CSSA for their review and approval. |
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Triangle Laboratory (Triangle): Triangle (Durham, NC) has been tentatively identified for dioxins/furans analysis for one soil and one wipe sample. Parsons ES is currently discussing technical issues with the laboratory. |
Percent Complete
This task makes up approximately 45% of the RFI phase. As of the end of Quarter 2, this task is less than 0.5% complete.
Summary of Findings
The following are results from the evaluation of the EM-31 and GPR geophysical surveys at five AOCs (AOC 47, 48, 56, 58, and 61) which were begun during the week of July 26, 1999:
AOC 56: There was a large area of multiple EM anomalies associated with a surface depression and three other anomalies that may be associated with road construction or related to the old rail line.
AOC 48: A linear anomaly in the north-south trend may be due to either a pipeline or trench with metallic debris.
AOC 58: There were 3 major anomalies found in a linear trend and one minor anomaly.
AOC 61: Data for this site showed no anomalies.
AOC 47: Data for this site showed no anomalies.
Summary of Changes
No changes associated with the RFI during this Quarter.
Summary of Contacts
A Technical Interchange Meeting (TIM) was held on September 24, 1999 to discuss the results of the geophysical survey data (as discussed above) and the risk assessment approach (as discussed under Task IV).
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
The facility investigation will be ongoing. Sampling of background soils and bedrock will be conducted in early November, and investigation activities are expected to be conducted through May 2000. A schedule is included with this progress report.
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.
Completion of this task is 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.
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A TIM was held on September 24, 1999 at CSSA with AFCEE and EPA. The purpose of the meeting is discussed under Task III(D). Regarding this task, a brief discussion concerning a comparison between the new Texas Risk Reduction Program and the existing Risk Reduction Rule was held. A site visit with AFCEE, EPA, and CSSA is planned for December 15 and 16, 1999. The purpose of the site visit is to gather information required to develop a conceptual site model for CSSA. |
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. If possible, background levels will be used to determine the possibility of closure under the Risk Reduction Rule Standard 1. The Investigation Analysis will also include groundwater protection standards and other relevant protection standards. The relevant protection standards will be used at sites where a Standard 1 Closure was not applicable. Due to the recent promulgation (September 23, 1999) of the Texas Risk Reduction Program (TRRP, 30 TAC §350) by the TNRCC, two options are being considered for the protection standards. One option is to base the protection standards on the Risk Reduction Rule Standard 2 Media-Specific Concentrations. The other option is to use the Protective Concentration Limits developed under TRRP. The decision will be made as additional information becomes available.
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 2, and no actions are anticipated during Quarter 3.
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 Work Plan will be prepared, the treatability study(ies) will be implemented, and a treatability study report will be prepared.
Completion of this task is partially funded. Currently planned and funded (under RL33) is completion of a treatability study report for SWMU B-20, and continued operations and maintenance of the SVE system at SWMU B-3 (under RL74 and RL83).
A draft work plan for the SVE system at B-3 was submitted to CSSA and AFCEE on September 20, 1999. Comments were received from AFCEE and CSSA and will be incorporated in the final Work Plan. The field work is currently scheduled to begin in early January 2000.
This task makes up approximately 10% of the RFI phase.
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.
Completion of this task is partially funded. Progress reports for two years (August 1999 – May 2001) are funded (RL83).
Percent Complete
This task makes up approximately 5% of the RFI phase. With completion of this progress report, this task is approximately 14% 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 to correct problems necessary during this Quarter.
Projected Work for the Next Quarter
Progress Report for Quarter 3 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.