[Home] [Master Table of Contents]

[Table of Contents] [Next Section]

3rd/4th Quarters - Final Quarterly Progress Report

Interim Measures

Interim Measures (IM) will be conducted to mitigate a current or potential threat to human health and/or the environment. The IM is estimated to represent approximately 30% of the required actions at CSSA. The IM includes Interim/Stabilization Measures Work Plan (7% of IM), Interim Measures Implementation (70% of IM), and Reports (23% of IM). At the end of Quarter 4, the IM is approximately 13% complete.

Task I - Interim/Stabilization Measures Work Plan

The Interim/Stabilization Measures Work Plan 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 CSSAs Environmental Encyclopedia will be referenced. As of August 2, 1999, completion of this task has been fully funded (under delivery order RL74).

Parsons Engineering Science (Parsons ES) submitted the final IM Work Plan to EPA for comment on September 2, 1999. A revised IM Work Plan for O-1, incorporating a revised liner design, was submitted to EPA for comment on December 23, 1999. EPA commented on the IM Work Plan on January 6, 2000. Responses to comments were submitted to EPA during a project meeting on February 3, 2000 and by letter on February 25, 2000. CSSA has not yet received comments from the Texas Natural Resource Conservation Commission (TNRCC).

  1. Percent Complete

This task makes up approximately 7% of the IM phase. The majority of this task was completed during Quarter 2, but as described below, a revision was made to the IM Work Plan for O-1 during Quarter 3. In addition, during Quarter 3, EPA comments on the IM Work Plan were incorporated into the document.

  1. Summary of Findings

No new findings associated with the IM Work Plan during this reporting period.

  1. Summary of Changes

The original IM Work Plan for SWUM O-1 called for a liner system to be installed directly on top of the bedrock (approx. 4 ft deep), and clean soil placed over the liner. The primary purpose of the liner is to prevent infiltration of rainwater which could provide a driving force for the potential contamination in the bedrock into the groundwater. However, a design change relocated the liner from underground to the surface to allow for rainwater runoff. Parsons ES has prepared text for the final IM Work Plan.

  1. Summary of Contacts

No contacts related to the IM Work Plan were made during this reporting period, with the exception of responding to EPA comments on the work plan.

  1. Summary of Problems

No problems related to the IM Work Plan were observed during this reporting period.

  1. Actions Taken to Correct Problems

No actions to correct problems necessary during this reporting period.

  1. Projected Work for the Next Quarter

No new work is projected on the IM Work Plan during the next reporting period.

  1. Copies of Daily Reports, Inspection Reports, Data, etc.

No daily reports, inspection reports, or data related to the IM Work Plan were generated during this reporting period.

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 -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. The status of each is described below.

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 the yet to be selected disposition method is not funded. Due to the amount of soil in these piles, it is anticipated that funding may be spread over several years.

Activities completed between November 1999 and April 2000 include the following:

As described in the Quarter 2 progress report, quarterly groundwater monitoring was reinitiated in September 1999. At that time, CSSA wells and three private off-base wells (JW-30, RFR-3 and RFR-8) were sampled, and samples were analyzed by OBrien & Gere Laboratory (OB&G) (data package DO23 #1). Parsons received the labs data package on September 30, 1999. Parsons validated the data and submitted it to AFCEE on December 10, 1999. AFCEE commented on the analytical package on January 27, 2000. AFCEE had the two following comments on the package: 1) the laboratory performed a reporting limit verification measurement, which is not required by AFCEE, and 2) unique sample numbers were not assigned to each container. AFCEEs first comment has been addressed, and the verification measurement will not be included in future packages. However, regarding AFCEEs second comment, the laboratory cannot assign a unique number to each sample container with their current LIMS system. A compromise procedure has been submitted to AFCEE. Furthermore, a third issue was noted by AFCEE in later packages. OB&G deviated from their approved SOP in their initial calibration curve determination procedures. In April, OB&G revised their SOP for initial calibration curve determination, and AFCEE accepted the revision. The final data package and report will be submitted upon AFCEEs final approval of the responses to the unique sample identification issue.

Quarterly groundwater monitoring of the on-site wells was also performed the week of December 13 - 17, 1999 at CSSA (Attachment 2). Additionally, one privately owned offsite well (well LS-7) adjacent to CSSA was also monitored. The results of this monitoring event are summarized in Section B (Summary of Findings). Samples were analyzed by OB&G, and Parsons received the analytical data package on January 7, 2000. The validated data package and data validation report were submitted to AFCEE on January 14, 2000. Parsons received AFCEEs comments on the package on March 3, 2000, and Parsons provided a response on March 22, 2000. Comments were similar to the September package comments: 1) unique sample numbers were not assigned to each container, and 2) initial calibration curve determination procedures did not follow approved SOP. In April, OB&G revised their SOP for initial calibration curve determination, and AFCEE accepted the revision. The final data package and report will be submitted upon AFCEEs final approval of the responses to the unique sample identification issue.

Quarterly groundwater monitoring of the on-site wells was also performed the week of March 17, 2000 at CSSA. Samples were analyzed by OB&G, and results were submitted on April 13, 2000. Parsons validated the data and sent the results and data validation report to AFCEE on April 28, 2000. AFCEE approved the data package on May 9, 2000. VOC results for one sample were rejected due to laboratory error, and the well was resampled on April 27, 2000. Analytical results from the resampling event are due to Parsons ES on May 19, 2000.

CSSA continued ongoing testing of alternative groundwater sampling methods. Methods under evaluation include diffusion sampling techniques for VOCs and "Hydrasleeve" No Purge bailer sampling for metals.
Initial results from the diffusion sampler tests are favorable. At well 16, the diffusion sample results ranged from 88 to 151 parts per billion (ppb) cis-1,2-dichloroethene (cis-1,2-DCE), 117 to 215 ppb tetrachloroethene (PCE) and 115 to 224 ppb trichloroethene (TCE). Samples collected using conventional low flow sampling techniques found 134 ppb cis-1,2-DCE, 161 ppb PCE and 177 ppb TCE. At well 3, the diffusion sampler results ranged from 0.67 to 0.75 ppb PCE, while the most recent well 3 sampling event (December 1999) results found 0.99 ppb PCE. In both events, compounds identified in the diffusion sample identically match compounds found using the low flow technique. From April 20 through 24, 2000, CSSA collected samples from wells 3, 16, and MW2 for metals analyses using a "Hydrasleeve" No Purge bailer. The samples were submitted to OB&G for analyses. The results from this sampling effort are due back from the laboratory in late May 2000. When the metals analyses is complete, CSSA will develop a summary paper of the alternative sampling methods. The paper will include CSSAs recommendation regarding the sampling methods and will be provided to the EPA, TNRCC and Parsons ES.

During Quarter 3, JEDI Drilling, Inc. initiated surface and subsurface investigation at SWMU O-1 for determining vertical and lateral extent of contamination. The surface soil investigation for determining the lateral extent of contamination was completed during Quarter 4. Eagle Construction & Environmental Services Inc. was subcontracted for excavation, capping and waste hauling activities. Excavation anticipated to begin in Quarter 5, pending EPAs approval of the SWMU O-1 IM Work Plan. No additional subcontracting efforts are planned for the IM at SWMU O-1. A statement of work for treatability studies, planned as part of the IM on sifted soil piles at SWMUs B-8, B-20, B-24, B-28 and DD, was initiated during Quarter 3. Investigation and characterization sample collection at SWMUs B-8, B-20, B-24, B-28 and DD for determining proper disposition and/or treatment of the excavated soils was completed during Quarter 4. Analytical results will be submitted by the laboratory in May 2000.

A treatability study for stabilization of the excavated soils was initiated during Quarter 4. The Environmental Security Technology Certification Program (ESTCP) and UFA Ventures, Inc. are demonstrating a stabilization process using Phosphate Induced Metal Stabilization (PIMS) on soils contaminated with lead and other metals.

On January 6 and 26, 2000, CSSA Environmental Office met with the CSSA Environmental Quality Control Council (EQCC) to discuss updates, changes and requirements of the CSSA Spill Prevention, Control, and Countermeasures Plan and the Installation Spill Contingency Plan.

On January 19, 2000, CSSA Environmental met with Jerry Thompson and David Carr of Camp Bullis to discuss opportunities for CSSA Environmental to share environmental data, information and resources with Camp Bullis. Areas of interest included: a) coordinating groundwater monitoring events, b) adding Bullis data points to the CSSA upcoming groundwater model, c) sharing down-hole geophysical logs, d) potentially treating Bullis investigative derived waste (IDW) water in the CSSA granular activated carbon (GAC) system, e) picking up the digital topographic maps and geologic maps that cover the Camp Bullis area, and f) soil background studies. CSSA would like to compare approaches and results with the CSSA Background Study.

On February 24, 2000, CSSA employees were notified via a posted Memorandum of TCE concentration exceeding the action level in well 1.

On April 5, 2000, CSSA Environmental met with Mario Napolitano of Carbtrol Corporation to discuss GAC treatment of VOC contamination in groundwater. Installation, operation and maintenance of large high capacity and small low capacity systems were discussed.

A Draft Off-Site Monitoring Program Response Plan (the Plan) was developed by CSSA Environmental as a work plan strategy document for approaching off-site residents regarding potential groundwater impacts. The Plan includes a purpose statement, a list of offsite wells that are targeted for sampling, a well owner notification strategy, sampling and analyses plan, proposed VOC Action Levels and proposed Army responses.

Two Draft CSSA Environmental Fact Sheets for distribution to the surrounding community were also developed by CSSA Environmental. The first Fact Sheet covers general information regarding the history, mission, and an overview of the CSSA environmental program. The second Fact Sheet provides more specific information on soil and groundwater contamination at CSSA, the Off-Site Monitoring Response Plan and information on CSSA initiatives to protect area endangered bird species and to conserve groundwater.

A Draft Responsiveness Summary was also developed by CSSA. The Responsiveness Summary provides a summary of questions and comments generated by the December Community Relations mail-out and includes CSSA responses to the questions/comments.

  1. Percent Complete

This task makes up approximately 70% of the IM phase. With the well research and off site well sampling conducted during this reporting period, this task is considered 6% complete.

  1. Summary of Findings

Results of the December 1999 groundwater monitoring event were formally reported in a draft Quarterly Groundwater Monitoring Report which was submitted to CSSA and AFCEE during Quarter 4. A table of groundwater VOC analytical results and a map indicating the well locations is included as Attachment 3. A summary of the preliminary validated results is provided below:

Onsite Wells, December 1999: CSSA wells 1, 2, 3, 9, 10, 11, 16, I, MW1, and MW2 were sampled during the December 1999 sampling event. Well D was not sampled during this event because the water level in the well was too low. Well D is set in the Lower Glen Rose Formation and the pump is approximately 250 feet below ground surface. This monitoring event also did not include Well G because the down-hole pump was not operational. Concentrations of TCE, PCE, and cis-1,2-DCE that exceeded maximum contamination levels (MCLs) were detected in Well 16. The results for Well 16 showed that cis-1,2-DCE and TCE concentrations decreased somewhat as compared to the September 1999 sampling event while the PCE concentration decreased only slightly. Wells MW1 and MW2 were found to have PCE and TCE concentrations that exceeded MCLs and concentrations of cis-1,2-DCE that were below MCLs were also found in these wells. None of the samples analyzed displayed metal concentrations above MCLs during this sampling event.

Offsite Wells, December 1999: One of the wells at CSSA that is usually included in the monitoring program could not be sampled due to a non-operational pump. Instead, a sample was collected from a private well (well LS-7) located approximately 500 feet from the southwest corner of CSSA. No contaminant levels above MCLs were found, but a PCE concentration of 2.51 u g/L was detected and a TCE concentration of 0.3 u g/L was detected. The value for TCE was above the MDL (method detection limit) but below the PQL (practical quantitation limit).

Results of the March 2000 groundwater sampling event will be formally reported in a Quarterly Groundwater Monitoring Report, which will be completed during Quarter 5. A summary of the event is provided below.

Onsite Wells, March 2000: CSSA wells 1, 2, 9, 10, 11, 16, I, MW1, and MW2 were sampled during the March 2000 sampling event. Wells D and G were not sampled during this event because the water levels in the wells were too low. OB&G diluted the sample collected for volatile organic compounds (VOCs) analysis from well 16 and reported the results. However, the AFCEE Quality Assurance Project Plan (QAPP) requires that all samples be analyzed undiluted first, before any dilution is made. OB&G agreed to be responsible for all resampling activities costs. Well 16 was resampled on April 27, 2000, and the analytical results are due to Parsons ES from the laboratory on May 19, 2000.

Offsite Wells, March 2000: No offsite wells were sampled by Parsons ES in March 2000. However, CSSA resampled well LS-7 on March 6, 2000 by collecting two samples from the well. Three analytes were present in these samples: chloroform at concentrations of 0.10 u g/L and 0.11 u g/L, PCE at 2.79 u g/L and 2.87 u g/L, and TCE at 0.5 u g/L in both samples. CSSA also split these samples with EPA Region 6. The split samples were shipped by CSSA to EPAs Houston Laboratory for analysis. As of May 10, 2000, CSSA has not received official notification of the split sample results.

  1. Summary of Changes

The schedule for IM activities at SWMU O-1 was revised based on the problems with O-1 analytical data described below in Summary of Problems.

  1. Summary of Contacts

On March 15, 2000, CSSA Environmental (Brian Murphy and Chris Beal) met with the TNRCC San Antonio Regional Office personnel. Participants from TNRCC included Tom Haberle, Abigail Power, Craig Meppen, and Jay Don Jobson. Main items of discussion included:

  1. Recent analytical results from drinking water wells located on CSSA and from an offsite well (well LS-7) located approximately 100 feet from the southwest corner of the installation. Analyses showed PCE and TCE in the wells.

  2. Guidance for CSSA and recommendations regarding community outreach and additional site monitoring.

  3. Establishing a single TNRCC Regional point of contact (POC) to help coordinate future environmental activities through the POCs office in cooperation with Kirk Coulter at the TNRCC Austin office. TNRCC is considered essential to the success of the CSSA environmental program and at each milestone of the process.

On February 24, 2000, TNRCC was notified of the September and December 1999 exceeded TCE action level (0.5 u g/L) in well 1, one of CSSAs three potable drinking water wells.

On February 24, 2000, TNRCC was notified of the December 1999 exceeded PCE action level (0.5 u g/L) in offsite well LS-7. On that date, the private owner of the offsite well was also notified of the exceeded level.

On March 22 and 23, 2000, CSSA Environmental supported the base commander with a March 22, 2000 Town Hall meeting. The meeting covered a wide range of topics including CSSA groundwater issues.

On April 13, 2000, EPA was contacted (see Letter dated April 18, 2000) regarding the third quarter progress report. Per EPAs agreement, the third and fourth quarterly progress reports were combined.

CSSA Environmental prepared a letter to TNRCC regarding the September and December 1999 Action Level exceedance at CSSA well 1. The levels of TCE found in the well triggers quarterly monitoring activities. The Letter to the TNRCC provides a summary of the well 1 analytical results and informs TNRCC that CSSA has already initiated a quarterly monitoring program for all of the base wells, including well 1.

CSSA prepared two letters to the owner of offsite well LS-7 to explain the analytical results from the groundwater sample collected from his well. The letters cover the December 1999 and the March 2000 sampling events, and requests permission to resample the well in the future.

  1. Summary of Problems

Analytical problems resulting in questionable data were noted for the samples collected as part of the delineation of extent of contamination at SWMU O-1. Parsons ES collected surface and subsurface soil samples from SWMU O-1 on November 4, 5, and 8, 1999. The samples were analyzed for VOCs and metals, with all analyses being performed by OB&G following procedures outlined in the AFCEE QAPP, version 3.0. Results of the analytical data validation concluded that all metal analyses were considered usable. However, eighty-two results from the VOC analysis were flagged "R" initially due to the misinterpretation of the method and AFCEE QAPP by the laboratory. OB&G has revised the data package and Parsons ES has also revised the data validation report since this issue was resolved.

To date, Parsons ES has not completed definition of the lateral or vertical extent of contamination at SWMU O-1. As part of the IM, all contaminated soils to bedrock limestone will be removed within the defined lateral extent using the analytical data from the IM soil sampling effort. To define the lateral extent, Parsons ES located twenty sample points (SB5 through SB24) surrounding the known extent of SWMU O-1. Composite surface soil samples were collected from fifteen of these twenty sample points. The lateral extent will be defined when analytical results on all outer points indicate that the surface soils meet background conditions (i.e., below reporting limits for VOCs and below established background concentrations for cadmium and chromium). During the week of April 24, 2000, Parsons ES conducted a resampling effort at SWMU O-1. Parsons ES located and sampled five additional points within SWMU O-1 to define the lateral extent of contamination on April 25, 2000. Additionally, ten samples were collected from soils within the tentatively defined extent of O-1 for toxicity characteristic leaching procedure (TCLP) wastes characterization analysis.

In addition to problems with OB&G SWMU O-1 data, contracts with Data Chem Laboratories (DCL) were not signed until February 26, 2000, due to negotiations on technical and contractual issues between Parsons ES and Data Chem, as well as delayed approval of explosives variances from TNRCC.

  1. Actions Taken to Correct Problems

Data packages and the data validation report for the OB&G data have been revised following AFCEEs instructions.

  1. Projected Work for the Next Quarter

Procurement activities will continue next quarter. A request for quotation for contractors to perform treatability studies at the sifted soil pile sites will be sent out during Quarter 5.

It is anticipated that IM removal actions at SWMU O-1 will be initiated during Quarter 5, pending EPAs final approval of the IM Work Plan.

The next quarterly groundwater monitoring event will be conducted in June 2000, and will include onsite wells only.

  1. Copies of Daily Reports, Inspection Reports, Data, etc.

Copies of the daily reports, inspection reports, and/or data related to the IM Implementation at SWMU O-1 will be included in the Quarter 5 report (or after the data are approved by AFCEE).

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.

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. The IM Report will be in three phases. The first phase will be a baseline report, the second phase will be a progress report, and the third phase will be a final report at the completion of the project. Funding for the first two phases, and maybe even the third phase, is anticipated to be completed in the next fiscal year.

  1. Percent Complete

This task makes up approximately 23% of the IM phase. With completion of this progress report, this task is approximately 8% complete.

  1. Summary of Findings

No findings associated with progress reports this reporting period.

  1. Summary of Changes

No changes associated with progress reports this reporting period.

  1. Summary of Contacts

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

  1. Summary of Problems

No problems associated with progress reports this reporting period.

  1. Actions Taken to Correct Problems

No actions to correct problems necessary during this reporting period.

  1. Projected Work for the Next Quarter

No work, aside from preparation of the next progress report, is projected for this task during the next Quarter.

  1. Copies of Daily Reports, Inspection Reports, Data, etc.

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

[Next Section]