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 4, the RFI is approximately 20% 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.

This task makes up approximately 5% of the RFI phase. This task is 99% complete, and will be 100% complete as soon as the electronic versions of the above documents are completed.

As this was a review of known information, there were no new findings.

No changes associated with the Preliminary Report during this reporting period.

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

No problems related to the Preliminary Report during this reporting period.

No actions to correct problems necessary during this reporting period.

No work on this task is projected for next Quarter.

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

Task II - RFI Work Plan

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.

	Parsons ES received EPA comments on work plans on January 6, 2000.
	EPA approval was received on January 12, for variances of three explosive compounds with higher reporting limits and one method modification for Data Chem Laboratories, Inc. TNRCC approval of these variances was received on February 9, 2000.
	Work Plans for work that must be redone due to ITS Laboratory’s questionable practices were submitted in December to AFCEE and CSSA.
	During December 1999, 1,986 questionnaire postcards were sent to homeowners within approximately two miles of the installation boundary. Respondents to this mail-out will formulate the initial mailing list for the base.
	Prior to March 28, 2000, 486 community postcards were returned to the installation. Of these 486 cards, 437 postcards were used to create the current base mailing list. A total of 437 postcards contained address information of neighboring homeowners, 31 postcards were returned from vacant residences, 10 were returned for incorrect address information, and eight were returned for insufficient postage. This information has been imported into a database to facilitate data management.
	The CSSA encyclopedia will be in a hypertext document format that will be structured like an internet web site. The encyclopedia can be placed on a CD-ROM and viewed using a web browser. The encyclopedia can also be copied to a web site server to become part of an internet/intranet web site. Trellix, a web building tool, was chosen to convert existing documents to hypertext because of it's linking features and it's strong capabilities in converting Microsoft Word 97 files to hypertext. In the process of developing the encyclopedia, Parsons ES discovered and began to exceed the file size limitations of Trellix. Parsons will continue to use Trellix to develop small portions of the encyclopedia, which will then be linked to create one hypertext document. Parsons can use Trellix and a web site development tool to finish the encyclopedia. This method may be difficult to maintain. Other methods and software for creating the large hypertext encyclopedia will be investigated.
	On February 24, 2000, CSSA Environmental met with personnel from Fort Sam Houston to discuss the development and management of a CSSA Environmental Program web site.

This task makes up approximately 10% of the RFI phase. As of the end of Quarter 4, this task is approximately 95% complete.

No new findings associated with RFI Work Plan preparation during this reporting period.

No changes associated with the RFI Work Plan during this reporting period.

TNRCC indicated by telephone that their work plan comments would not be ready for some time. As described above, EPA’s comments were received in early January 2000, and responses to comments were provided in February 2000.

No problems associated with the RFI Work Plan during this reporting period.

No actions to correct problems necessary during this reporting period.

• The Cluster Well work plan will be finalized in Quarter 5.

• A figure for the CRP demonstrating the location of the distribution area of the initial community mail-out, the location of the respondents, and the location of the respondents with significant comments will be completed.

• A CD-ROM showing an example of the draft electronic encyclopedia will be available for CSSA and AFCEE comment.

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

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 SWMU B-2 is funded, and investigation of all but AOCs 44- 46, 49, 51- 55, 57, 59, 60, 62- 64, and 67- 70 is funded. A list of soil samples collected during this reporting period, listed by delivery order and site, is included in Attachment 4.

• In early November 1999, 30 soil samples were collected from 25 borings and 10 waste characterization samples were collected from SWMU O-1 under RL 74. This work was described in the Interim Measures section of this progress report.

• Background soil samples (70 total) were collected at various locations throughout CSSA as part of the ITS rework. Ten additional samples of Glen Rose limestone background samples were collected from 10 borings ranging in depth from 9 to 15 feet. Parsons received the data packages in late December 1999, and submitted the packages and the data validation report to AFCEE on February 18, 2000. Parsons received AFCEE’s comments on the Glen Rose limestone background samples on March 30, 2000. AFCEE did not require responses for the comments; however, several pages of the package must be revised. Status of the data packages are included in a table as Attachment 5.

• Geophysical surveys were conducted at AOCs (AOCs 35, 42, 43) and SWMU B-9 between November 29 and December 9, 1999 under DO 5068. Results are summarized in Section B below. These results were also presented at a February 3, 2000 teaming meeting attended by EPA, CSSA, AFCEE, WPI, and Parsons ES. The data packages provided during the February 3, 2000 Technical Interchange Meeting (TIM) can be referred to for detailed information. These data packages include geophysical survey data in tables and depict the data on maps.

• Soil gas samples (146 total) were collected at AOCs 41, 37, and 66. The samples were collected between November 29 and December 17 under DO 5068, and a draft report was submitted to CSSA and AFCEE on March 10, 2000.

• Because regulatory approval of variances associated with the explosives analytical method had not yet been received by early January, field work scheduled for January 10, 2000 through February 18, 2000 was delayed until February 28, 2000, with the exception of surface soil sampling at the AETC sites. This field effort, which included RFI surface soil and subsurface soil sampling at numerous sites was completed on April 14, 2000. The only outstanding funded RFI sampling is at SWMU B-23A, where ampoules of unknown contents are present, and at SWMU I-1, where two wipe samples for dioxins are required. Parsons is awaiting TNRCC approval of Triangle Laboratory’s procedures for the dioxins analysis.

• Soil samples (80 total) were collected at AOCs 36, 38, 39, and 40. The samples were collected between 10 and 14 January 2000 under DO 5068. Parsons received three analytical data packages from O’B&G on February 2, 2000, and the packages and data validation report were submitted to AFCEE on March 7, 2000. AFCEE provided comments on one package on April 4, 2000, one on April 28, 2000, but comments have not yet been provided for the third package. The status of the data packages is described in a table included as Attachment 5.

• In February 2000, 15 borings were completed at SWMU B-9, Bldg. 43 and I-1 under RL53 (45 samples) and in April 2000, six surface soil samples were collected from SWMU B-10 and I-1 (three samples each). The status of the data packages is described in a table included as Attachment 5.

• The week of March 27, 2000, rework drilling activities were completed at SWMU B-20. As part of the recent SWMU B-20 sampling activities, additional soil samples were collected and submitted to the Southwest Regional Institute (SRI) for perchlorate analysis. Preliminary analytical results found no detectable perchlorate above the detection limit of 22 ppb, which was well below the lowest Texas Risk Reduction Program (TRRP) residential protective concentration level (PCL) of 91 ppb. Validation of this preliminary data is in progress. To evaluate potential for perchlorate contamination in groundwater, perchlorate sample(s) from selected CSSA wells will be submitted for perchlorate analysis. The status of the data packages is described in a table included as Attachment 5.

• In April 2000, 76 soil samples were collected under RL 83 from SWMUs B-8 (3 sift samples), B-15/16 (9 borings, 27 samples), B-20/21 (13 sift samples), B-23 (3 borings, 9 samples), B-24 (18 sift samples), B-28 (3 sift samples) and DD (3 sift samples). The status of the data packages are included in a table as Attachment 5.

• In late March and early April 2000, 34 samples were collected from SWMUs B-24 and DD under RL33, and the samples were sent to APPL Labs for analysis. Parsons received analytical packages for SWMU B-24 on May 1, 2000. The status of the data packages are included in a table as Attachment 5.

• Two soil samples were collected from beneath the PCE degreasing vat at AOC 65 on April 7, 2000 under DO 5068. Additional samples were collected from the same locations on April 8, 2000 and provided to the TNRCC. CSSA collected nine subsurface samples from one soil boring and split the samples with TNRCC. These samples were analyzed for VOCs, metals and total petroleum hydrocarbons (TPH). This soil boring was located in a drainage-way on the west side of Building 90. This drainage-way potentially received runoff from a previously unplugged floor drain, a former steam degreaser and from the AOC 65 sump. This work was completed by CSSA, and is not affiliated with any AFCEE, AMC or AETC delivery order.

• On January 19, 2000, CSSA Environmental met with base management to discuss purchasing recycled products and establishing an Affirmative Procurement Program.

• On April 17, 2000, CSSA Environmental met with AFCEE to develop work scopes for a new delivery order (DO). The DO tasks will include work that is currently not funded and follow-on work from existing DOs. It will also include new investigations, remediation and community relations projects. The follow-on work includes UXO Avoidance, completion of the CSSA Spill Prevention Plan, updating the community relations plan, and additional efforts or equipment related to the PIMS pilot study. Investigation work includes additional soil sampling activities at the Building 90 sumps, soil gas survey of the southwestern corner of the base and installation of additional cluster wells in the Building 90 vicinity. Community relations work includes funding for two public meetings and two fact sheets.

• On April 27, 2000, CSSA Environmental met with Weldon Hammond, University of Texas at San Antonio (UTSA) Dean of Engineering and Sciences to discuss the upcoming CSSA drilling program and the opportunity for UTSA to acquire approximately 2,800 feet of Trinity Aquifer core. The UTSA geology department can use the core as part of ongoing sequence stratigraphy studies of the Trinity Aquifer. CSSA also indicated that geophysical logs and water level data could be made available to further the aquifer study. Logistics, storage, site access and indemnification were discussed. Additional topics discussed included the use of groundwater flow/contaminant transfer models for the CSSA Trinity Aquifer contamination plume and the possibility of securing UTSA support with upcoming community relations projects. Hammond recommended Groundwater Vistas tied to the Modflow modeling package as a good program to start with. This modeling package is relatively easy to use and is Arcview GIS compatible.

This task makes up approximately 45% of the RFI phase. As of the end of Quarter 4, this task is approximately 10% complete.

	One hundred and forty-six points were sampled during the soil gas surveys at AOCs 37, 41, and 66. PCE was detected in only 22 points; however, only three points were above the 0.1 parts per billion by volume (ppbv). TCE, DCE, and benzene, ethylbenzene, toluene and xylenes (BTEX) were not detected in any of the points, with the exception of one TCE detect at AOC 66 at the same location as the highest PCE detect. The PCE detects closed the contours of the PCE soil gas "plume" near AOCs 36 and 38 that had been previously identified during a 1995 investigation. Please refer to the data packages provided during the February 3, 2000 Technical Interchange Meeting (TIM). These data packages include geophysical survey data in tables and depict the data on maps.
	The following are results from the evaluation of the EM-31 and GPR geophysical surveys at three AOCs (AOC 35, 42, 43) and SWMU B-9, which were begun during the week of November 29, 1999:
	AOC 35 – Data for this site showed no subsurface anomalies that were not associated with utilities surrounding Well 16.
	AOC 42 – Two linear anomalies in the north-south trend in the eastern portion of the site may be due to trenches with metallic debris. Two additional anomalies were detected that were not associated with the linear trenches.
	AOC 43 - Data for this site showed no anomalies.
	SWMU B-9 - Data for this site showed no anomalies.
	Summary results for surface soil and subsurface soil samples collected between November 1999 and April 2000 will be provided after analytical data packages have been reviewed and approved by AFCEE.

Based on the geophysical results conducted at AOCs 35, 42, and 43 under DO 5068, scope amendments were submitted to modify the remaining investigative activities at those sites. Since no geophysical anomalies were detected at AOCs 35 and 43, it is proposed that only surface samples be collected at these sites. On the other hand, AOC 42 geophysical results indicated significant subsurface anomalies, and will require additional delineation beyond the three soil borings originally scoped. These matters were discussed with the EPA during the February 3, 2000 Technical Interchange Meeting (TIM). With EPA concurrence, six additional borings have been proposed for AOC 42. All boring depths have been extended to 15 feet below grade, and will include analysis for explosives. The uncertainty regarding potential unexploded ordnance (UXO) at this site will also warrant explosive ordnance disposal (EOD) avoidance support.

During a site survey at AOC 50 in January 2000, additional areas of nickel penetrate were found in the vicinity. Additionally, some potential UXO was also located and removed by CSSA support personnel. One area of potential disturbance was also identified. Cedar clearance and UXO clearance near AOC 50 has been completed to enable future work activities to proceed. Based on these events, the original DO 5068 statement of work (SOW) will be amended to incorporate the additional areas of disposal and EOD avoidance support. A geophysical survey has also been proposed for the suspected area of disturbance.

The DO 5068 SOW is expected to be revised by June 2000 (Quarter 5), when work can resume at the scheduled AOCs.

No contacts related to this task were made during this reporting period.

Work began at SWMU B-4 on January 10, 2000. Eleven borings were scheduled to be drilled to characterize possible waste previously identified by geophysical survey. It was learned while drilling that possible hazards, including UXO, might be present at the site. The work was halted at the time to complete appropriate safety measures. After UXO clearance was complete, the work was resumed and completed in April 2000 with the supervision of UXO/EOD technicians.

Soil samples (9 total) were collected at AOCs 56, 58, and 61. The samples were collected on January 14 under RL 83 and sent to APPL Laboratory for analysis. The laboratory did not follow the QAPP and was unable to provide data for the samples. The sites were resampled on February 11, 2000.

• APPL entered a written agreement with Parsons ES to pay for the resampling and reanalysis of the soil samples (9 total) collected at AOCs 56, 58, and 61.

Anticipated field work under DO 5068 includes nine 15’ borings at AOC 42. Five soil samples will be collected at AOC 35 and three soil samples will be collected at AOC 43. Interim measures will involve soil removal at AOC 50.

Contract modifications are underway in preparation for the installation of the deep wells/cluster wells.

Data packages, including analytical data from the laboratories that are flagged by Parsons ES, have been submitted for AFCEE approval. A listing of these data packages is included as Attachment 5.

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.

• A site visit to support this task by Parsons personnel, accompanied by CSSA, AFCEE, and EPA personnel, was conducted December 15 and 16, 1999.

• A site visit report providing the findings of the site visit titled Land Use and Receptor Survey, CSSA was submitted on February 25, 2000.

• Comments on the site visit report from CSSA Environmental were received on March 24, 2000. While a second version of the site visit report will not be submitted, comments have been noted and will be incorporated into the Technical Approach Document (TAD).

• The internal draft Technical Approach Document for Risk Assessment was submitted for review on March 17, 2000. Comments were received on this document from CSSA on April 5, 2000. AFCEE has not supplied comments as of April 30, 2000.

This task makes up approximately 15% of the RFI phase. The amount of effort needed to accomplish this task is not yet known because analytical data are not yet available. The percent complete will depend on the number of sites requiring risk assessment.

The site visit resulted in the identification of potential human and ecological receptors within and surrounding CSSA. There are numerous residential areas and private and public water wells. These will be considered in any further risk assessments that are conducted. In addition, habitats and jurisdictional wetlands were identified for consideration during any subsequent ecological risk assessments.

A technical approach for conducting risk assessments under the TRRP was proposed. This approach will evaluate a site for closure to background under the Risk Reduction Standard 1 of the Risk Reduction Rule. If it is determined that this approach is not feasible, then consideration will be given to closure under the new TRRP.

No changes associated with the Risk Assessments during this reporting period.

Submittal of the site visit report occurred on February 25, 2000, and submittal of the TAD occurred on March 17, 2000. Comments on the site visit report were received on March 24, 2000 from CSSA, and comments on the TAD were received on April 5, 2000.

No problems related to the Risk Assessments during this reporting period.

No actions to correct problems necessary during this reporting period.

Comments on the TAD will be received from AFCEE. Responses to comments will be prepared and the TAD revised as necessary. The draft TAD will be submitted for review to CSSA, AFCEE, TNRCC, and EPA.

No daily reports, inspection reports, or data related to the Risk Assessments generated during this reporting period.

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.

This task makes up approximately 10% of the RFI phase. It was not active during Quarters 3 and 4, and no actions are anticipated during Quarter 5.

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).

• The blower on the soil vapor extraction (SVE) unit at SWMU B-9 was replaced during the week of January 4. The system was run through an initial startup and system check before initial samples were collected.

• SVE laboratory and field data were collected in accordance with the SVE operations and monitoring (O&M) schedule detailed in the Soil Vapor Extraction Test Work Plan, Second Addendum (December 1999). The results of this testing are scheduled to be evaluated as part of the interim O&M Report due to CSSA on July 25, 2000.

• On April 6, 2000, CSSA, Parsons ES and UFA Ventures met to discuss the Work Scope, Objectives and Approach of Phosphate Induced Metals Stabilization (PIMS) Treatability Study. This project has received funding through the Department of Defense (DOD) Environmental Security and Technical Certification Program (ESTCP) and will treat stockpiled soils at SWMUs B-20, B-24 and B-28. The Treatability Field Demonstration is currently underway.

This task makes up approximately 10% of the RFI phase. This task is approximately 5% complete.

No findings associated with the Treatability Studies during this reporting period.

No changes associated with the Treatability Studies during this reporting period.

No contacts related to the Treatability Studies were made during this reporting period.

The samples collected during the initial startup of the SVE were not analyzed because Environmental Analytical Services Laboratory exceeded the holding times defined by the AFCEE QAPP.

Environmental Analytical Services Laboratory entered a written agreement with Parsons ES to pay for the resampling and reanalysis SVE samples collected during the initial startup. The samples were re-collected at the laboratory’s expense on February 14 and 15, 2000.

• The final Soil Stabilization/Solidification Treatability Study Report and the final Soil Washing Treatability Study Report will be submitted to AFCEE in Quarter 5.

• The SVE unit at SWMU B-3 will remain on a biweekly system check schedule. Data evaluation will be initiated upon receipt of analytical data from the 5-month emissions sampling event tentatively planned for June 15, 2000. The draft interim O&M Report will be prepared for CSSA and AFCEE review, and will be submitted by July 25, 2000.

No daily reports, inspection reports, or data related to the Treatability Studies generated during this reporting period.

Task VII - Progress Reports

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).

This task makes up approximately 5% of the RFI phase. With completion of this progress report, this task is approximately 50% complete.

No findings associated with the Progress Reports during this reporting period.

No changes associated with the Progress Reports during this reporting period.

No contacts related to the Progress Reports were made during this reporting period.

No problems related to the Progress Reports during this reporting period.

No actions to correct problems necessary during this reporting period.

Progress Report for Quarter 5 will be submitted.

No daily reports, inspection reports, or data related to the Progress Reports generated during this reporting period.

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