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 2, the IM is approximately 16% 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 CSSA’s Environmental Encyclopedia will be referenced. As of August 2, 1999, completion of this task has been fully funded (under delivery order RL74).

Parsons ES received authorization from the EPA on July 11, 2000 to proceed with the planned IM actions at SWMU O-1. On July 17, 2000, CSSA notified TNRCC of planned IM activities at SWMU O-1 with no comments received.

This task makes up approximately 7% of the IM phase. This task is 100 percent complete.

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

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

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

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

No actions to correct problems necessary during this reporting period.

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

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 ¼-mile of the facility boundary; evaluation of alternative measures and implementation of selected interim measures at 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 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 May 1, 2000 and July 31, 2000 include the following:

Quarterly groundwater monitoring of the on-site wells was performed the week of June 12, 2000 at CSSA. One off-site sample was also collected at well LS-7. Samples were analyzed by O’B&G, and results were submitted to Parsons ES on July 12, 2000. Parsons ES validated the data and submitted the package to AFCEE on July 26, 2000. Analytical results for the March 2000 groundwater sampling event (except for Well 16) were approved by AFCEE on May 9, 2000.

Replacement analytical results for the March 2000 rejected Well 16 VOC results were received by Parsons ES on May 22, 2000. The data package was validated and sent to AFCEE on May 23, 2000.

After EPA’s approval of the SWMU O-1 IM Work Plan was received during this reporting period, excavation of contaminated soils began in Quarter 5. An approximate total of 1,480 tons of soil was removed and disposed at Covel Gardens landfill facility operated by Waste Management Inc. in San Antonio, Texas. No additional subcontracting efforts are planned for the IM at SWMU O-1. The interim measures activities for SWMU O-1 are expected to be completed by August 18, 2000.

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 continued during Quarter 5. 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 were received from the laboratory in May 2000. Validation efforts on the analytical data were initiated during Quarter 5.

A treatability study for stabilization of the excavated soils was continued during Quarter 5. 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. The PIMS laboratory benchscale treatability study was completed during Quarter 5. Results of the benchscale treatability study indicate that the PIMS stabilization process may be applicable in reducing leachable lead content and to inhibit the bioavailability of the lead into the environment. The initial results of the treatability study are further discussed under Task VI (Treatability Studies). It is anticipated that a field scale treatability study will be initiated during the next reporting period. Additionally, the Draft Soil Disposition Assessment Report is expected to be completed, along with the initiation of two other treatment technologies (density treatment and phytoextraction) during the next reporting period.

CSSA has reviewed information on several varieties of "Discrete Sampling Systems" for possible installation in wells 16 and D, which are currently open boreholes. Some of these technologies have included a multi-level sampling device to perform discrete sampling at selected intervals and prevent vertical migration of contaminants in ground water in the borehole. Prices for the technology range from $13- $20K depending on sampling intervals. CSSA will review this technology further to determine its applicability to CSSA’s groundwater program.

CSSA has been in communication with the US Army ""Blue Dart" team, who specialize in evaluating ground water contamination problems associated with Army facilities. During the week of June 12, 2000, CSSA provided the most recent data on wells located both onsite and offsite, VOC results, a map of potential source areas, and well locations to the Army Environmental Center "Blue Dart" team leader per his request. The "Blue Dart" team will visit CSSA during August 2000. Correspondence between CSSA and "Blue Dart" is presented in Attachment 1.

This task makes up approximately 70% of the IM phase. This task is considered 10% complete.

Quarterly groundwater monitoring of the on-site wells was performed the week of June 12, 2000 at CSSA (Attachment 2). A map of the well locations was provided in the last quarterly report, and may be found in Attachment 3 of the 4th Quarterly Report.

Onsite Wells, June 2000: CSSA wells 1, 2, 9, 10, 11, 16, I, MW1, and MW2 were sampled during the June 2000 sampling event. Wells D, G and H were not sampled during this event because the water levels in the wells were too low (wells D and G) or the well is inoperable (well H). Results of the June 2000 groundwater monitoring event will be formally reported in a draft Quarterly Groundwater Monitoring Report submitted to CSSA and AFCEE during Quarter 6 and placed in the ENV Encyclopedia, Volume 5. A table showing preliminary unvalidated laboratory data is included as Attachment 3.

Offsite Wells, June 2000: One off-site sample was collected at well LS-7 during the June 2000 sampling event. Samples were analyzed by O’B&G, and results were submitted to Parsons ES on July 12, 2000. Parsons ES validated the data and submitted the package to AFCEE on July 26, 2000. Results of the June 2000 groundwater monitoring event will be formally reported in a draft Quarterly Groundwater Monitoring Report submitted to CSSA and AFCEE during Quarter 6 and placed in the ENV Encyclopedia, Volume 5.

CSSA received validated data from AFCEE for well LS-7, sampled on March 6, 2000. Three analytes were present in the two LS-7 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 ug/L in both samples. These samples were also split with the EPA Region 6 at the time of sampling. The analytical results from the EPA’s samples indicate the highest levels of analytes to date: 3.2 u g/L for PCE and 2.1 u g/L for TCE. However, no formal report from the EPA has been received.

In addition, during the week of May 8, 2000, CSSA prepared a response to the State from an inspection of CSSA’s drinking water system in November 1999. An open issue of contention is deed recordation of CSSA’s potable drinking water wells due to a sanitary easement for a 150-foot radius around the water source for wellhead protection. CSSA’s current position, in agreement with representatives from the Army Material Command (AMC) General Counsels’ Office and General Services Administration real estate division, is to apply for an easement exception. CSSA cannot deed record each well in perpetuity since the future of the government lands in question is not known. CSSA was required to respond to the State by June 9, 2000.

A response (Attachment 4) from the TNRCC was received on July 21, 2000 which approved a temporary exception to the sanitary control easement rule for land owned by CSSA for Wells 1, 9, and 10. There has been recent legal objection to the use of a sanitary control easement as the proper legal document to establish sanitary control for lands within 150 feet of a well. Until the rule is changed to correct the problem, a temporary exception is granted. Once the rule is changed, the temporary exception will expire and the system will be required to implement the resolution.

The TNRCC also forwarded a memorandum on July 21, 2000 regarding the Period 3, 2000 lead and copper analyses performed by the Texas Department of Health Laboratory. The 90th percentile lead and copper sample results were 0.0073 mg/l and 0.110 mg/l, respectively. The CSSA water system did not exceed the lead or copper action level mandated. The TNRCC memorandum is also included in Attachment 4.

No changes were made for the IM activities during this reporting period.

On June 28, 2000, Parsons ES notified EPA and the TNRCC regarding the anticipated schedule for initiating the interim corrective action at SWMU O-1. EPA provided authorization to proceed on July 11, 2000. The TNRCC was notified of the authorization to proceed on July 17, 2000, and had no comment. Work was initiated July 24, 2000 with the excavation and off-site disposal of contaminated soils from SWMU O-1.

The week of May 8, 2000, CSSA’s Commander hand-delivered a letter to the owner of well LS-7. The letter summarized the analytical findings in the groundwater samples collected from the well on March 6, 2000. In addition, a copy of the letter was sent by certified mail to the appropriate points of contact for the EPA and TNRCC.

No problems associated with IM activities this reporting period.

No actions to correct problems associated with IM activities necessary this reporting period.

Procurement activities associated with treatability studies for the soil piles will continue next quarter. A request for quotation for contractors to perform treatability will be sent out during Quarter 6.

It is anticipated that IM removal actions at SWMU O-1 will be completed during Quarter 6.

The next quarterly groundwater monitoring event will be conducted in September 2000, and will include onsite wells only. However, should groundwater levels remained depressed at Wells D of G such that no groundwater sample is obtainable, offsite well LS-7 will be sampled.

Copies of the daily reports, inspection reports, and/or data related to the IM Implementation at SWMU O-1 from Quarter 5 are included as Attachment 5. Any reports completed in the next quarter will be included in the Quarter 6 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 is anticipated to be completed in the next fiscal year. Currently it is uncertain if the budget for the next fiscal year will fully fund the third phase, and may carry over to the following fiscal year.

This task makes up approximately 23% of the IM phase. With completion of this progress report, this task is approximately 10% complete.

No findings associated with progress reports this reporting period.

No changes associated with progress reports this reporting period.

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

No problems associated with progress reports this reporting period.

No actions to correct problems necessary during this reporting period.

Preparation of the draft IM report will begin next quarter.

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

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