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6th Quarter - Final Quarterly Progress Report

RCRA Facility Investigation

The 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 6, the RFI is approximately 44% 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 was 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, 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 an electronic format anticipated with the completion of the next CSSA Environmental Encyclopedia update in November 2000. Hard copies of these reports have been previously provided to the agencies.

  1. Percent Complete

This task makes up approximately 5% of the RFI phase. This task is 100% complete.

  1. Summary of Findings

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

  1. Summary of Changes

There are no changes associated with the Preliminary Report during this reporting period.

  1. Summary of Contacts

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

  1. Summary of Problems

No problems related to the Preliminary Report 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 work on this task is projected for next Quarter.

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

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 a Community Relations Plan (CRP). As previously agreed by US EPA, CSSA’s Environmental Encyclopedia, which includes all of the information required by the Order, will be used to fulfill this requirement. Additions to or modifications of these documents will be placed in the appropriate volume(s) of CSSA’s Environmental Encyclopedia as they are completed.

Completion of this task has been funded for the RFI tasks that have been planned under delivery order RL74 and DO5068.

Parsons ES created a draft of the electronic version of CSSA’s Environmental Encyclopedia, delivered on CDs for comment on August 10, 2000 to AFCEE, CSSA, US EPA and TNRCC for comment. Before additional drafts of the electronic environmental encyclopedia are developed, CSSA and AFCEE will evaluate the process used for their creation.

Modifications to the Work Plan, Field Sampling Plan, and Site-Specific Plans were submitted to AFCEE and CSSA for review on September 22, 2000. The updated plans addressed modifications to the DO5068 work scope for investigative actions at AOCs 35, 42, 43, and 50. The investigative approach for these sites were modified based upon Phase I geophysical results and roundtable discussions/decisions at the February 3, 2000 TIM. Upon comment receipt and resolution, draft final and final versions will be issued prior to initiating field activities.

  1. Percent Complete

This task makes up approximately 10% of the RFI phase. As of the end of Quarter 6, this task is approximately 95% complete. The remaining 5% of this task is associated with the CSSA Encyclopedia hypertext document.

  1. Summary of Findings

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

  1. Summary of Changes

There are no changes related to the RFI Work Plan made during this reporting period.

  1. Summary of Contacts

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

  1. Summary of Problems

No problems related to the RFI Work Plan 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 work on this task is projected for next quarter.

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

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 continue 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 as done in past investigations. 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. Planning for a soil gas survey near AOC 65 and AOC‑57 was initiated under DO 5084. Preparation of work plan addenda for the AOC-65 and AOC-67 RFIs will begin upon completion of soil gas surveys planned under the new AETC DO (No. 5084).

Funding for DO5068 SOW modification was approved on August 2, 2000. The modification allowed for a revised sampling strategy at AOCs 35, 42, 43, and 50. Modified work plans that reflect the SOW changes were submitted for review on September 22, 2000.

Final versions of the soil gas surveys for AOCs 37, 41, and 66 were included in the August 10, 2000 update of the Environmental Encyclopedia.

One September 11, 2000, one composite material sample was collected from the AOC 50 nickel penetrate waste stream to determine the approximate inorganic character of the material, and to evaluate its recyclable properties for potential disposal. Preliminary results of waste characterization and concentrations of recyclable metals within the nickel penetrate waste material indicate that the material meets class 2 non-hazardous levels as specified in 30 Texas Administrative Code (TAC) Chapter 335, Subchapter R and may have sufficient metal material for recycling.

Two composite samples of liquid IDW generated during the RFIs were also collected at that time to initiate waste profiling. Preliminary results indicated the IDW meets class 2 non-hazardous levels as specified in 30 TAC 335 Subchapter R.

Four draft RFI Closure reports were prepared and submitted for review by AFCEE and CSSA on September 29, 2000. The reports documented efforts to address the presence of near-surface PCE in the soil gas within the northern portion of the inner cantonment, in the general vicinity of well 16.

  1. Percent Complete

This task makes up approximately 45% of the RFI phase. As of the end of Quarter 5, this task is approximately 11.5% complete.

  1. Summary of Findings

Four draft RFI Closure reports were prepared and submitted for review by AFCEE and CSSA on September 29, 2000. The reports recommend closure for AOCs 36, 38, 39, and 40 based on analytical results surface sampling over areas which were reported with concentrations of PCE in the soil gas. The closure requirements for these sites are specified in 30 TAC 335 Subchapter S as Risk Reduction Standard 1 that allows a SWMU to close if all waste materials are removed to background levels or to practical quantitation limits (PQLs). For CSSA, the Quality Assurance Project Plan (QAPP) reporting limits (RL) are specified as the levels to meet the closure data quality objectives. The data from three sites (AOCs 36, 39, and 40) resulted with no detectable concentrations of the target analytes (i.e., all contaminants of concern below RLs). One sample and one duplicate sample out of 60 sampling locations reported PCE concentrations at the method detection limit at AOC 38. However, this site has also been recommended for closure since the concentrations are well below the RL.

A total of 114 data packages are in the data verification, validation and or AFCEE review process. The data packages represent analytical data resulting from ongoing facility investigations, interim measures actions and groundwater monitoring events. As of October 23, 2000, 18 packages have been reviewed and accepted by AFCEE. Results for these packages were submitted during the previous quarter. During this quarter, AFCEE returned the packages to Parsons ES for grouping by laboratory, contract, sampling effort, and matrix.

  1. Summary of Changes

The DO5068 SOW was revised and funded on August 2, 2000. The SOW amendment provides for a revised investigative approach at AOCs 35, 42, 43, and 50.

DO 5084 was issued under Parsons ES’ contract with AETC to continue RFIs at AOC-65 and AOC-67, and to complete a soil gas survey at AOC-65 and AOC-57. The DO will include four rounds of on-site groundwater monitoring and six rounds of off-site monitoring at 20 well locations, a Drought Contingency Plan, Technical Interchange Meetings, Community Relations Plan with updates and fact sheets and continuation of quarterly progress reporting.

  1. Summary of Contacts

No contacts related to facility investigation were made during this reporting period.

  1. Summary of Problems

No problems related to facility investigation 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

Contract modifications are underway in preparation for the installation of the deep wells/cluster wells. After the “Blue Dart” team review of the groundwater issues the designs of the wells were changed per their recommendation. The work plans have been modified to reflect construction changes, and have been reviewed and verbally approved by the EPA during Quarter 6.

The Cluster Well work plans were finalized in Quarter 6. Actual well installations are tentatively scheduled to begin starting November 2000. A notification of field activities was submitted on October 9, 2000 to the regulatory agencies to inform them of target mobilization date of either October 23, 2000 or October 30, 2000. A delay due to the drilling subcontractors rig maintenance pushed the mobilization date to November 13, 2000. The actual start date is dependent upon the drilling subcontractors rig availability and weather.

Pending the final work plan approval for AOCs 35, 42, 43, and 50, work will resume at these sites, including surface and subsurface sampling, a geophysical survey, and interim measures waste removal at AOC 50.

Under DO 5084, Parsons ES will perform a soil gas survey at AOC 65 and AOC 57 during the next quarter. Parsons ES will utilize a mobile field laboratory to provide daily analysis of soil gas samples. The soil gas survey will include up to 600 points with an expected duration of approximately 8 weeks. The tentative start date is December 4, 2000.

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

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

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 basewide human health and ecological Conceptual Site Model (CSM) for risk assessment. The CSM identifies potential human and ecological receptors and land use surrounding the facility. In addition, a Risk Assessment Technical Approach has been prepared.

The draft Conceptual Site Model (CSM) and 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. Comments were received from AFCEE on May 30, 2000.

During last quarter, revisions of the CSM and Technical Approach Document were initiated based on the CSSA and AFCEE comments received, and were submitted on August 10, 2000. Comments from the TNRCC and EPA will be incorporated when they are received. Site specific assessments will be performed if COCs are identified.

  1. Percent Complete

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 or have not yet been fully evaluated. The percent complete depends on the number of sites requiring risk assessment.

  1. Summary of Findings

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 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 Texas Risk Reduction Program.

  1. Summary of Changes

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

  1. Summary of Contacts

No contacts related to the Risk Assessments were made during this reporting period.

  1. Summary of Problems

No problems related to the Risk Assessments 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

Responses to comments will be prepared and the Technical Approach Document revised as necessary. The approach document will be submitted as part of the Environmental Encyclopedia.

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

No daily reports, inspection reports, or data related to risk assessment 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 Risk Reduction 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 is 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.

During this quarter, data tables were begun to compare investigation results to closure criteria.

  1. Percent Complete

This task makes up approximately 10% of the RFI phase, and is approximately 95% complete.

  1. Summary of Findings

No new findings associated with Investigative Analysis preparation during this reporting period.

  1. Summary of Changes

No changes associated with the Investigative Analysis during this reporting period.

  1. Summary of Contacts

No contacts related to the Investigative Analysis were made during this reporting period.

  1. Summary of Problems

No problems related to the Investigative Analysis 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

Continued work on investigation results to closure criteria.

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

No daily reports, inspection reports, or data related to risk assessment generated during this reporting period.

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 soil vapor extraction (SVE) system at SWMU B-3 (under RL74 and RL83).

As part of the Task II Interim/Stabilization Measures, a treatability study for stabilization of the excavated soils was continued during Quarter 6. 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 studies were completed during Quarter 5. During the next quarter, a field demonstration work plan will be developed for application of the PIMS to the excavated soils from SWMU B-20. It is anticipated that a field scale treatability study will be initiated during reporting Quarter 8.

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). Slight modifications were made to increase the removal rates experienced at the site during the initial five months of the assessment. These modifications included removing at least two vapor extraction wells (VEWs) from the extraction network, due to seal failures likely cause by drought conditions, and maintaining the flow through the main exhaust at least at 60 cubic feet per minute (cfm). During the first testing event, after submitting the interim assessment report, the flow was increased to approximately 4,500 feet per minute (or 98 cfm). During subsequent monitoring events, the flow at VEW has been adjusted, as needed, to maintain the main exhaust flow at or near 98 cfm. This flow rate is 10 cfm below the TNRCC-approved standard exemption for emissions from the SVE system.

According to the results reported in the interim assessment report of the SVE system, an estimated 68 pounds of TCE, 32 pounds of cis-1,2-DCE, 16 pounds of PCE, and less than 1 pound of vinyl chloride were removed from the SWMU B-3 trench during the last five months of continuous operation. Based on this data, operation of the SVE system has not resulted in contaminant emissions in exceedance of the standard exemption for the B-3 SVE system.

During the subject reporting period, the seal on several of the VEWs, primarily those VEWs screened in tighter formations within the trench, were observed to be broken. The VEW seal failures were likely caused by drought conditions resulting in the shrinking and cracking of the bentonite seals. This resulted in removing four VEWs from the extraction network, including VEW-8, VEW-11, VEW-14, and VEW-18, and significantly restricting the flow from VEW-10. The reason for the short-circuiting (seal breach) was investigated, and identified as the bentonite seal in VEW-8 and VEW-14. The source of the breach could not be identified in VEW-11 and VEW-18.

Data collected from re-sampling of the soil samples collected as part of the initial SWMU B-3 treatability study (1997) was continued during this reporting period.

A transducer was set in two of the VEWs removed from extraction (VEW-08 and VEW‑18) to collect data regarding the infiltration of water into and through the trench following significant rainfall events. A hermit data logger is recording information on water levels on a 30-minute frequency. Rainfall events from early October 2000 should provide enough data on infiltration of precipitation for accurate evaluation of the groundwater flow dynamics through the trench.

The final Phytoremediation Treatability Study Report for SWMU B-20 will be submitted in November 2000.

  1. Percent Complete

This task makes up approximately 10% 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 depends on the number of sites requiring treatability studies and/or the need for a Treatability Study Program.

  1. Summary of Findings

UFA Ventures recently completed a bench-scale treatability study on a small sample of B-20 sifted soils. On average, the soils contained about 2,000 mg/kg lead. Three leaching tests were run on the soil: one with rainwater, one using TCLP methodology, and one using SPLP methodology. The TCLP extraction moved the most (between 2 and 30 ppm) lead into solution. These three leaching tests were also run on soil mixed with appetite. TCLP extract results on the soil mixed with appetite were an order of magnitude lower. UFA Ventures will prepare a work plan for the field demonstration of the PIMS remedial effort during Quarter 7. It is expected that the field demonstration of PIMS will be initiated during Quarter 8.

Analytical data from the 5-month emissions sampling event (performed June 20-21, 2000) at B-3 were evaluated and validated. The results do not indicate a significant reduction in the contaminant levels present in the main exhaust emissions compared to the initial sample results. In some specific VEWs tested, the results indicate an increase in the contaminant levels from some VEWs, suggesting that the radius of influence for the tested VEWs may have broadened to include a larger treatment area.

Findings associated with the Soil Washing (density treatment) and Stabilization Treatability Studies are presented in the reports that are included in Volume 4 of the encyclopedia. In general, results of the soil washing techniques performed at B-20 indicate that the physical treatment step of the soil washing process produces significant reductions in the lead concentrations in the soil composite samples. However, the treatment technique results only in recovery of the larger particulate lead fractions within the soil matrix. Therefore, this remediation process must be used in conjunction with another technique in order to recover small particulate and ionic lead fractions to reach cleanup standards. Parsons ES recommends that the technology be combined with other appropriate technologies in order to test the viability of density treatment with other remedial technologies. Phytoremediation using genetically engineered plants to uptake the bioavailable lead within the soil matrix may offer promising results if used in conjunction with the soil density treatment. The laboratory benchscale results of the phytoextraction process on soils at SWMU B-20 provided data regarding the potential efficacy of the remedial technique. Based on the laboratory benchscale test results, phytoextraction can conceivably reduce the extractable lead concentration of B-20 site soils at the rate of 30 to 60 mg/kg per crop. This relates to the potential to remove 22.43 kg of lead per acre of soil.

  1. Summary of Changes

No changes associated with the treatability studies during this reporting period.

  1. Summary of Contacts

No contacts related to the treatability studies were made during this reporting period.

  1. Summary of Problems

No problems related to the O&M activities at SWMU B-3 or the B-20 treatability studies 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

The SVE unit at SWMU B-3 will remain on a bi-weekly system check schedule and will be continued until January 23, 2001. Data collection for the 10-month emissions sampling event is scheduled for November 2, 2000. The final SVE system assessment report is tentatively scheduled for submittal on January 30, 2001.

It is anticipated that UFA Ventures will finalize the field demonstration work plan for PIMS.

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

No daily reports, inspection reports, or data related to the treatability studies were 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 under RL83 of the AMC contract. Six additional progress reports (July 2001 – October 2002) are funded under DO5084 of the AETC contract.

  1. Percent Complete

This task makes up approximately 5% of the RFI phase. The percent complete is unknown because the number of treatability studies necessary is currently unknown.

  1. Summary of Findings

No findings associated with the progress reports during this reporting period.

  1. Summary of Changes

No changes associated with the progress reports during this reporting period.

  1. Summary of Contacts

No contacts related to the progress reports were made during this reporting period.

  1. Summary of Problems

No problems related to the Progress Reports 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

Progress Report for Quarter 6 will be submitted.

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

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

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