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7th Quarterly Progress Report
Interim Measures
IM are being conducted to mitigate a current or potential threat to human health and/or the environment. The IM are estimated to represent approximately 30% of the required actions at CSSA. The IM include Interim/Stabilization Measures Work Plan (7% of IM), Interim Measures Implementation (70% of IM), and Reports (23% of IM). Based on information currently available at the end of Quarter 7, the IM are approximately 44% complete.
Task Description
The Interim/Stabilization Measures Work Plan includes
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a description of on-going and planned interim measures;
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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
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proposed locations, design plans and specifications, construction, operation, and maintenance requirements of the interim measures, including a sampling and analysis plan.
Existing plans, which are included in CSSA’s Environmental Encyclopedia, will be referenced to the extent possible. As of August 2, 1999, completion of this task has been fully funded (under delivery order RL74).
Activities this Quarter
The original IM Work Plan was submitted in August 1999. The design of the cap was modified and a revised work plan reflecting the new design was submitted in October 1999. The IM work plan has been incorporated into the CSSA Environmental Encyclopedia (Volume 1-2, SWMU O-1). 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.
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Percent Complete
This task makes up approximately 7% of the IM phase and is 100 percent complete. Therefore, no changes occurred for progress report items: B (Summary of Findings), C (Summary of Changes), D (Summary of Contacts), E (Summary of Problems), F (Actions Taken to Correct Problems), G (Projected Work for the Next Quarter), and H (Copies of Daily Reports, Inspection Reports, Data, etc.).
Task Description
The Interim/Stabilization Measures Implementation includes sampling and analysis of groundwater from 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; IM activities at AOC 50 to remove nickel penetrate, 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 is partially funded. One round of sampling and analysis of three off‑site wells (RFR-3, RFR-8, and JW-30) located to the west of CSSA (under RL74) and sampling and analysis of CSSA wells is completely funded through March 2001 (under DO23, RL74, and RL83), along with interim measures and a partial facility closure of SWMU O‑1 (under RL74). In addition, sampling of 20 wells for 6 quarters (VOCs only) starting in June 2001 is funded (under DO 5084). 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 this Quarter
 | CSSA is currently in the process of identifying private wells for eventual off-site groundwater sampling under the AETC contract DO 5084. CSSA will be evaluating their public communication plans with regard to this off-site sampling, and will begin the process of obtaining access agreements from private well owners to allow sampling of their off-site wells. |
| | Actual sampling of 20 off-site wells (under DO5084) will begin after access agreements are finalized and after one round of sampling and analyses is complete at the new monitoring wells currently being installed. |
| | Excavation activities at SWMU B-10 were initiated during Quarter 6, and were completed in Quarter 7. Remediation at SWMU B-10 was not listed in the 3008(H) order as an interim measure; however, it is included in this discussion of IM activities due to its proximity to SWMU O-1. A closure report for SWMU B-10 will be submitted instead of an interim measures report. A total of approximately 4,500 cubic yards of soil have been disposed of at Covel Gardens (Waste Management, Inc.) and 1,500 tons of recovered metallic materials have been recycled at Newell Metals Recycling Facility. Also, IM actions were initiated during Quarter 7 at AOC 50 to remove up to an estimated 175 cubic yards of soils laden with nickel penetrate. A technical report documenting the removal will be prepared. |
| | Originally, government comments on the draft Well Research Report were provided to Parsons ES on September 11, 2000, and Parsons ES provided responses on September 29, 2000. Based upon Parsons ES’ responses, additional government comments were received on November 4, 2000. Upon approval of responses, the final version of the well survey report will be prepared and submitted as a new section to the CSSA Environmental Encyclopedia (Volume 5, Offsite Well Survey). Further data to satisfy the additional comments were collected in the field during the week of January 5, 2001. The report is expected to be issued during the beginning of Quarter 8. |
| | Quarterly groundwater monitoring of the on-site wells was performed the week of December 11, 2000. Wells 1, 2, 9, 10, 11, 16, D, I, MW-1, and MW-2 were sampled. In addition, one off-site sample was collected at well LS-7 on December 13, 2000. Samples were analyzed by O’Brien and Gere (O’B&G), and results were submitted to Parsons ES on January 8, 2001. Preliminary unvalidated groundwater results were forwarded to EPA on January 12, 2001. |
| | Efforts relating to the determination of proper disposition of previously sifted soil piles at SWMUs B-8, B-20, B-24, B-28, and Demo Dud (DD) were continued in Quarter 7. Initial investigation efforts were initiated in Quarter 4 with the collection of chemistry data on metals, VOCs, and explosives. The initial investigation samples were collected in a systematic random effort to identify contaminants of concern. Results indicated the sifted soil piles are impacted by metals contamination with minimal impact from VOCs or explosives. These data were used to identify “worst case” metals impacted soils for collection of TCLP data. In Quarter 7, sifted soils within SWMUs B-8, B-20, B-24,
B-28, and DD were collected from “worst case” locations and sent for TCLP metals analyses to provide data for determining proper disposition. Additionally, a composite sample was collected from each of the SWMUs of concern for waste characterization. The waste characterization data will include TCLP results for the metals regulated by the State of Texas (i.e., antimony, arsenic, barium, beryllium, cadmium, chromium, lead, mercury, nickel, selenium, silver, and vanadium). The waste characterization data is expected to be used to characterize the sifted soils in accordance with 30 TAC Chapter 335 subchapter R requirements. Other “worst case” data is expected to be used in determining appropriate treatment methods for the sifted soils. |
| | A treatability study for stabilization of the excavated soils at SWMUs B-8, B-20, B-24, B-28, and DD was continued during Quarter 7. 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. CSSA received six tractor-trailer loads of Apatite II material to be used during the PIMS stabilization effort. The initial results of the treatability study are further discussed under Task VI (Treatability Studies). The UFA Ventures treatability study will be incorporated into Volume 4 of the CSSA Environmental Encyclopedia. It is anticipated that a field scale treatability study will be initiated during Quarter 8. Additionally, the Draft Soil Disposition Assessment Report is expected to be completed, along with the initiation of other treatment technologies (e.g., density treatment, phytoextraction, etc.) during Quarter 8. |
| | A geophysical survey was completed at AOC 50. The events and preliminary results are presented in the RCRA Facility Investigation section of this report. |
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Percent Complete
This task makes up approximately 70% of the IM phase. This task is considered 28% complete, based on the current projected activities listed in Task II, Task Description. If investigation results at other sites indicate an immediate threat to human health or the environment such that IM activities are warranted at additional sites, the percent complete will be adjusted accordingly.
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Summary of Findings
Quarterly groundwater monitoring of the on-site wells and one off-site well was performed during the week of December 11, 2000 at CSSA (Attachment 2). A map of the well locations was provided in Attachment 3 of the 4th Quarterly Report.
On-site Wells, December 2000: CSSA wells 1, 2, 9, 10, 11, 16, D, I, MW-1, and MW-2 were sampled during the December 2000 sampling event. Wells G and H were not sampled during this event either because the water level in the well was too low (well G) or the well is inoperable (well H). Results of the December 2000 groundwater monitoring event will be formally reported in a draft Quarterly Groundwater Monitoring Report to be submitted to CSSA and AFCEE during Quarter 8 and placed in the Environmental Encyclopedia, Volume 5. A table showing preliminary unvalidated laboratory results is included as Attachment 2.
Off-site Wells, December 2000: One off-site sample was collected at well LS-7 during the December 2000 sampling event. Samples were analyzed by O’B&G, and results were submitted to Parsons ES on January 8, 2001. Results of the December 2000 groundwater monitoring event will be formally reported in a draft Quarterly Groundwater Monitoring Report to be submitted to CSSA and AFCEE during Quarter 8 and placed in the Environmental Encyclopedia, Volume 5. Preliminary unvalidated laboratory results are shown in Attachment 2.
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Summary of Changes
No changes were made for the IM activities during this reporting period.
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Summary of Contacts
The owner of well LS-7 (private off-site well) was contacted for permission to sample the well during the December 2000 activities. In addition, a letter summarizing the analytical results from well LS-7 from the September 2000 sampling event was provided to the well owner.
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Summary of Problems
No problems associated with IM activities this reporting period.
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Actions Taken to Correct Problems
No actions to correct problems associated with IM activities necessary this reporting period.
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Projected Work for the Next Quarter
Contractor procurement activities associated with treatability studies for the soil piles are expected to be complete next quarter. These duties include the generation of detailed statements of work for soliciting proposals for the anticipated treatability studies. Procurement of subcontractor services for the planned treatability studies at SWMUs B-8, B-20, B-24, B-28 and DD are expected to be complete during the next reporting period.
The IM removal actions at SWMU O-1 and SWMU B-10 are complete. CSSA will continue with the operation and maintenance activities for SWMU O-1 until a final remedy of the associated vadose and groundwater zone is complete. IM removal actions will continue at AOC 50 during Quarter 8.
The next quarterly groundwater monitoring event will be conducted in March 2001. This upcoming event will include existing CSSA wells typically sampled, as well as any new completed and developed wells. Final versions of the December 1999, March 2000, and June 2000 groundwater monitoring reports will be issued for inclusion into the CSSA Environmental Encyclopedia (Volume 5, Groundwater Monitoring).
The treatability studies anticipated for the soil piles that were generated during UXO investigations are expected to be initiated during the next quarter.
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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 B-10 from Quarter 7 are included in Attachment 3 of this quarterly report.
Task Description
Reports associated with the IM include quarterly progress reports and an Interim/Stabilization Measure Report. This progress report is submitted as part of this task. The O-1 IM/Closure Report documented IM activities conducted at SWMU O-1. In addition, it documents that the project is consistent with design specifications and was performed adequately. (Note: the progress reports also meet the Task VII requirements under the RFI).
Completion of this task has been partially funded. Progress reports for two years (August 1999 – May 2001) have been funded (under RL83 of the AMC contract). Another six progress reports (July 2001 – October 2002) were funded (under DO 5084 of the AETC contract). In addition, the IM Report associated with SWMU O-1 has been completely funded (under RL74). IM reports for each of the soil pile sites have not been funded.
While the determination of an appropriate disposition method for the soil piles is 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.
Activities this Quarter
The final March 2000 Groundwater Monitoring Report was submitted in late November 2000, for inclusion in Volume 5 of the Environmental Encyclopedia. Draft versions of the June 2000 and September 2000 Groundwater Monitoring Reports and the Offsite Well Survey were submitted for AFCEE and CSSA review during August 2000. Both reports are currently in the comment/response phase before being issued as final reports. The SWMU O-1 Interim Measures Report was submitted during the previous quarter.
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Percent Complete
This task makes up approximately 23% of the IM phase. With completion of this progress report, this task is approximately 44% complete based on the current projected activities listed in Task II, Task Description. If investigation results at other sites indicate an immediate threat to human health or the environment such that IM activities are at additional sites, the percent complete will be adjusted accordingly.
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Summary of Findings
No findings associated with progress reports or IM reports this reporting period.
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Summary of Changes
No changes associated with progress reports or IM reports this reporting period.
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Summary of Contacts
No contacts related to quarterly progress reports or IM Reports were made during this reporting period.
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Summary of Problems
No problems associated with progress reports or IM reports this reporting period.
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Actions Taken to Correct Problems
No actions to correct problems necessary during this reporting period.
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Projected Work for the Next Quarter
Preparation of the draft Soil Pile Disposition Report will be completed next quarter.
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Copies of Daily Reports, Inspection Reports, Data, etc.
No daily reports, inspection reports, or data related to the report generated during this reporting period.