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7th
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 and any additional IM that may be warranted.
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
7, the RFI is approximately 37% complete.
Task Description
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.
Activities this Quarter
The majority of the
three reports mentioned in the above paragraph were provided to CSSA and AFCEE
in an electronic hyperlinked format.
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Percent Complete
This task makes up
approximately 5% of the RFI phase. This
task is 100% 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 Next Quarter), and H (Copies of Daily Reports, Inspection Reports,
Data, etc.).
Task Description
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 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.
Activities this Quarter
Modifications to the work
plan and a health and safety addendum for the work activities planned under AETC
DO 5084 were submitted to AFCEE and CSSA for review on December 14, 2000. A draft addendum for the site-specific soil gas survey task
at AOC-57 and AOC-65 was also prepared for AFCEE and CSSA review.
CSSA and AFCEE completed their review of the plan modification and
addenda and provided comments to Parsons ES on December 20, 2000.
Parsons ES resubmitted the revised addenda and the modified work plan on
December 22, 2000. A mobile
laboratory (DHL Analytical) is supporting the soil gas survey effort, and
Parsons ES received conditional approval of their standard operating procedure
for modified method 8021B (8021mobile-sv-01) from AFCEE on December 22, 2000. Site specific field sampling plan addenda for the RFI soil
and perched groundwater sampling planned at AOC 67 and AOC 65, and the off-site
and on-site groundwater sampling (under AETC DO 5084) will be prepared for those
respective tasks prior to initiating field activities.
Funding
for DO 5068 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. Draft final work plan
revisions were submitted on December 8, 2000.
The final versions of the amended work plans will be submitted during
January 2001.
The majority of the RFI
Work Plan was submitted to CSSA and AFCEE in an electronic hyperlinked format on
January 10, 2001. Additional RFI
Work Plan material will be added as it is finalized.
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Percent Complete
This task makes up
approximately 10% of the RFI phase. As of the end of Quarter 7, this task is approximately 99%
complete. The remaining 1% of this
task is associated with the CSSA Encyclopedia hypertext document, and will be
incomplete for an indefinite period of time.
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Summary of Findings
No new findings
associated with RFI Work Plan preparation during this reporting period.
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Summary of Changes
Work plan amendments to
the DO 5068 AOC investigations and RL83 Well Installations were submitted and
approved during Quarter 7.
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 DO 5068 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. Comments with respect to
the amended plans were received on October 16, 2000.
Responses to these comments were prepared and submitted on November 3,
2000. Additional clarifications
were requested on November 21, 2000.
The
draft final work plans were submitted on December 8, 2000.
Work at these sites is anticipated to resume after the submittal of the
final work plan revisions during January 2001.
An addendum to the RL83
Cluster Well Work Plan and Sampling and Analysis Plan was submitted to CSSA,
AFCEE, and the EPA on November 14, 2000.
The
addenda provided for the use of drilling foam (QuikFoamä)
to assist drill-cutting removal from large-diameter boreholes during the
drilling program. This addendum was
approved by AFCEE and CSSA. A
second addendum to the RL83 work plans was submitted on January 11, 2001 to
provide for alternative grouting methods of surface casing and re-sizing the
mesh size of the monitoring well filter pack.
CSSA and AFCEE provided comments to Parsons ES for this second addendum
on January 19, 2001, and their comments are currently being addressed.
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Summary of Contacts
No contacts related to
the RFI Work Plan were made during this reporting period.
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Summary of Problems
No problems related to the RFI Work Plan
during 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
Based on the results from
the soil gas survey, site specific sampling and analysis plan addenda will be
prepared for the soil borings planned at AOC 65 and AOC 67.
The planned duration of the soil gas survey is eight (8) weeks beginning
on January 2, 2001, so preparation of the plan addenda for the work planned at
AOC 65 and AOC 67 may be delayed until the second quarter (April-June 2001).
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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 Description
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 SWMUs, except SWMU B-2, is funded, and investigation
of all AOC, except AOCs 44-46,
49, 51-55,
57, 59, 60, 62-64,
and 67-70,
is funded. Preparation of work plan
addenda for the AOC65 and AOC67 RFIs will begin upon completion of soil gas
surveys planned under the new AETC DO (No. 5084).
The investigation work at AOC 65 and AOC 67 includes drilling and
sampling of 16 soil borings, 3 of which are inside Building 90 and 13 of which
are located outside of the building.
Currently,
the installation of four well clusters and three individual wells (12 wells
total) has been funded.
Activities this Quarter
Four
draft RFI Closure reports were prepared by Parsons ES 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 South Pasture. Comments
regarding the draft submittals for AOCs 36, 38, 39, and 40 Closure Reports were
received on October 30, 2000 from CSSA reviewers. Responses to the CSSA comments were prepared during November
2000. Comments regarding the
closure reports were received from AFCEE reviewers on December 18, 2000.
Responses to those comments will be prepared in January 2001.
A
geophysical survey, consisting of two parts, was conducted at AOC 50 between
December 19 and 22, 2000. The first
part included a primary survey area using electromagnetic (EM) and
ground-penetrating radar (GPR) technologies at a potentially disturbed area
south of the originally defined site boundary.
The second part included a secondary survey area using EM methods only,
and was an attempt to detect nickel penetrate within the future excavation area.
The
installation of monitoring wells began on November 15, 2000. Field activities initiated with the start of the MW9 well
cluster, located in the North Pasture serving as an upgradient well position.
Cores were retrieved, sampled, and archived from the Glen Rose, Bexar
Shale, and Cow Creek members of the Middle Trinity Aquifer.
Borehole geophysics and injection packer tests were performed in the
borehole, which penetrated the underlying Hammett Shale at 457 feet below grade. A second rig was mobilized to the site on January 19, 2001 to
assist in the well installations.
Validation
of data packages continued during Quarter 7.
A meeting was held December 15, 2000, with CSSA, AFCEE, Informatics, and
Parsons ES to discuss data validation. Content
of the Informal Technical Information Reports (ITIRs) was agreed to include data
packages, approved laboratory variances from the AFCEE QAPP,
verification/validation checklists, and a data validation report.
ITIRs previously submitted to AFCEE were returned to Parsons to
incorporate the agreed items. Descriptions of data verification, data validation, and
reviewed data are provided in the “Other” section of this report.
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Percent Complete
This task makes up
approximately 45% of the RFI phase. As of the end of Quarter 7, this task is approximately 18%
complete.
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Summary of Findings
A total of 120 data
packages are in the data validation/AFCEE review process.
As of October 23, 2000, 18 packages were 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.
Preliminary field
results of the AOC 50 geophysical survey suggest that no subsurface anomalies
are present at AOC 50. Initial
results also indicate that the EM-31 instrument was able to detect the presence
of nickel penetrate slag with some success.
The identification of the slag material will be beneficial for the
impending IM removal of the waste during Quarter 8.
In its present form, the preliminary data is unsuitable for draft
presentation, and therefore is not included with this quarterly report.
Data collection from the
well cluster installations continued through the end of Quarter 7.
Qualitative data indicates that perched water may be present in the North
Pasture during wetter periods of the year. Thus far, the thickness and depth of each formational member
was observed as previously estimated.
Contacts
between the Glen Rose, Bexar Shale, and Cow Creek members are sharp and
definitive. The Bexar Shale is
considerable less permeable than other bounding members.
As of yet, determinations regarding hydraulic connectivity between the
formational members have not been established.
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Summary of Changes
One
new SWMU (SWMU 71) and two new AOCs (AOC 72 and AOC 73) were identified at CSSA.
SWMU 71, located on approximately 1 acre in the South Pasture, is an area
where spent ammunition was buried. AOC
72, approximately 0.1 acre, is located near the northwestern corner of CSSA,
near well H, and is an area of surface metal debris and a possible disposal
trench. AOC 73 is located near the
southwestern corner of the base, due west of Building 94 and is an area of fill
material where transite panels have been identified.
The DO 5068 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 AOC65 and AOC67, and
complete a soil gas survey at AOC65 and AOC57.
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Summary of Contacts
The USEPA, AFCEE and CSSA
were contacted regarding use of a foaming agent (QuikFoamä)
to help remove drill cuttings from boreholes during monitoring well
installation. Based on discussions
and review of the foaming agent material safety data sheet (MSDS), the decision
was made to allow use of the foam. As
an added precaution, a gas chromatograph “finger print analyses” was run on
a sample of the foaming agent to confirm the constituents.
This analyses found the foam sample contained ethanol, 2-propanol,
1,4-dioxane, long chain olefinic compounds starting at 1-octene, long chain
alcohols starting at 1-hexanol, and other miscellaneous long chain hydrocarbons.
Given that these compounds are not contaminants of concern at CSSA and
because of the small volume of foam added to the wells (approximately 1 quart),
it was confirmed that the use of foam would not cause a cross contamination
problem in the well bore.
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Summary of Problems
Agreements were made
regarding the use of QuikFoamä
during drilling activities. By
December 3, 2000, it became apparent that drill-cuttings removal from large
diameter boreholes was extremely difficult at depth.
The major problem was that the cuttings could not be adequately flushed
from the borehole for setting casing.
CSSA
advised the EPA that they would use QuikFoamä
to "clean out" troublesome borings.
The use of QuikFoamä
was initiated on December 4, 2000. A
sample of QuikFoamä
was submitted to an independently contracted laboratory for analysis on December
20, 2000.
On December 5, 2000,
during the installation of well MW9-CC, the 12" steel casing collapsed
during the grouting process. Beginning
December 11, 2000, Parsons ES and GeoProjects relocated to a nearby location and
began redrilling MW9-CC. The
12-inch casing was successfully installed nine days later on December 19, 2000. The remainder of the well was completed in January 2001.
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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
The
installation and development of 15 monitoring wells at CSSA will continue
through Quarter 8.
Pending
the final work plan approval for AOCs 35, 42, 43, and 50, work will resume at
these sites, including surface and subsurface sampling, and interim measures
waste removal at AOC 50.
Under
AETC DO 5084, the soil gas survey will be performed during the next quarter.
Preparation of the Technical Report for the soil gas survey will be
initiated following the completion of the field activities.
Site specific sampling and analysis plan addenda will be prepared for the
AOC 65 and AOC 67 soil borings based on the results from the soil gas survey.
The soil gas survey will include up to 600 points with an expected
duration of approximately 8 weeks. The
tentative start date was postponed from December 4, 2000 to January 3, 2001 to
enable review of the soil gas survey sampling and analysis plan addendum, the
health and safety plan addendum, and the AETC DO 5084 modification to the work
plan.
The
installation of 15 new groundwater monitoring wells will continue into Quarter
8. Well installation activities
began November 15, 2000.
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Copies of Daily
Reports, Inspection Reports, Data, etc.
No daily reports,
inspection reports, or data related to the RFI were generated during this
reporting period.
Task Description
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.
Activities this Quarter
No actions this quarter.
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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. Since there have been no actions associated with this task
this quarter, 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
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. 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.
Activities this Quarter
During this quarter, data
table preparation was continued to compare investigation results to closure
criteria. Preparation of investigation/closure reports for each SWMU
investigated this spring was initiated.
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Percent Complete
This task makes up
approximately 10% of the RFI phase, and is approximately 23% complete.
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Summary of Findings
No new findings
associated with Investigative Analysis preparation during this reporting period.
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Summary of Changes
No changes associated
with the Investigative Analysis during this reporting period.
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Summary of Contacts
No contacts related to
the Investigative Analysis were made during this reporting period.
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Summary of Problems
No problems related to
the Investigative Analysis during 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
Continued work on
investigation results to closure criteria.
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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 Description
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).
Activities this Quarter
As part of the Task II
Interim/Stabilization Measures, a treatability study for stabilization of the
excavated soils was continued during Quarter 7.
The ESTCP and UFA Ventures, Inc. are demonstrating a stabilization
process using PIMS on soils contaminated with lead and other metals.
The PIMS laboratory benchscale treatability studies were completed during
Quarter 5. A work plan is scheduled
for submittal to CSSA and ESTCP for review in January 2001, with implementation
of a field scale treatability study scheduled to begin during reporting Quarter
8.
SVE laboratory and field
data were collected at SWMU B-3 in accordance with the SVE operations and
monitoring (O&M) schedule detailed in the Soil Vapor Extraction Test Work
Plan, Second Addendum (December 1999). During
the past five months of operation, the extraction flow rate from the SVE system
was increased to approximately 4,500 feet per minute (or 98 cfm). The flow at various VEWs was 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 data
collected through 10 months of operation, the SVE system has not resulted in
contaminant emissions in exceedance of the standard exemption for the B-3 SVE
system. Data from the 10-month
sampling event were verified, but validation and review were not completed for
inclusion into the final report during the subject reporting period. Assuming that the system was 90% operational during the
initial 10 months of continuous extraction at SWMU B-3, and using average
removal rates measured initially at 5 months and at 10 months, over 215 pounds
of VOCs have been removed. An
estimated 119 pounds of TCE, 60 pounds of cis-1-2-DCE,
and 36 pounds of PCE are included in this mass removal estimate.
Perched water samples
were collected from four of the B-3 VEWs. Analyses
of these samples indicated TCE at concentrations ranging from 110 mg/L
to 27,000 mg/L.
In addition, high concentrations of TCE breakdown products were observed.
This information indicates that significant VOC contamination remains at
SWMU B-3.
During Quarter 6, the
seal on several of the SWMU B-3 VEWs were observed to be broken.
This resulted in removing four VEWs from the extraction network,
including VEW-08, VEW‑11, VEW-14, and VEW-18, and significantly
restricting the flow from VEW-10. With
the onset of numerous rainfall events during the subject reporting period, it
was observed that the seals in all but one of these VEWs was re-established.
It can be concluded from this observation that the apparent leaks in the
VEW bentonite seals observed during Quarter 6 were caused by excessively dry
conditions. The only exception was
VEW-08, which continued to exhibit free flow conditions and high oxygen levels
indicative of an open and direct pathway to the surface.
The bentonite seal around this VEW has experienced a significant amount
of settling, providing further evidence of a likely disruption of the VEW’s
seal.
Resampling of the soil
samples collected as part of the initial SWMU B-3 treatability study (1997) was
completed during this reporting period. The
data from this resampling event is continuing to be reviewed and evaluated.
A transducer was set in
one of the SWMU B-3 VEWs (VEW-01) to collect data regarding the infiltration of
water into and through the trench following significant rainfall events.
A hermit data logger recorded information on water levels on a 15-minute
frequency. The weather station at
Well 16 and the transducer in VEW-01 recorded data from early October through
December 20, 2000. This recorded
data should provide valuable insight on infiltration and recharge of
precipitation into and through the trench for future evaluations on the dynamics
of flow and recharge characteristics of the water within the trench.
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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.
-
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 apatite.
TCLP extract results on the soil mixed with apatite were an order of
magnitude lower. UFA Ventures
prepared a draft 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
10-month emissions sampling event (performed November 6 and 7, 2000) at B-3 were
verified, but validation and review are not completed.
The results continue to suggest that the contaminant levels present in
the main exhaust emissions remain relatively stable when compared to the initial
and 5-month sample results. In some
specific VEWs tested, the results indicate a continued increase in the
contaminant levels from some VEWs, suggesting that the radius of influence for
those tested VEWs may be broadening to include a larger treatment area. The increase may also result from increased contaminant
mobility facilitated by the higher moisture conditions encountered at the site
prior to the November sampling event.
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Summary of Changes
No changes associated
with the treatability studies during this reporting period.
-
Summary of Contacts
No contacts related to
the treatability studies were made during this reporting period.
-
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.
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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
The SVE unit at SWMU B-3
will remain on a bi-weekly system check schedule and was continued until January
23, 2001. The final SVE system
assessment report is tentatively scheduled for submittal during the next quarter
(Quarter 8).
It is anticipated that UFA Ventures will
finalize the field demonstration work plan for PIMS and initiate the field
demonstration effort during the next quarter.
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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.
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 DO 5084 of the
AETC contract.
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Percent Complete
This task makes up
approximately 6% of the RFI phase. The percent complete is unknown because the number of
treatability studies necessary is currently unknown, however it is estimated at
approximately 6%.
-
Summary of Findings
No findings associated
with the progress reports during this reporting period.
-
Summary of Changes
No changes associated with the progress
reports during this reporting period.
-
Summary of Contacts
No contacts related to
the progress reports were made during this reporting period.
-
Summary of Problems
No problems related to
the Progress Reports during this reporting period.
-
Actions Taken to
Correct Problems
No actions to correct
problems necessary during this reporting period.
-
Projected Work for
the Next Quarter
Progress Report for
Quarter 6 will be submitted.
-
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.