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9th Quarterly Progress Report, May 1 - July 31, 2001

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 9, the IM are approximately 41% complete.

Task I - Interim/Stabilization Measures Work Plan

Task Description

The Interim/Stabilization Measures Work Plan includes:

  1. a description of on-going and planned interim measures;

  2. 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

  3. 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 is fully funded under delivery order RL74.

Activities this Quarter

The off-post and on-post groundwater sampling plan addenda were revised based on modification to AETC DO5084. This modification removed four rounds of on-post groundwater sampling from three wells and two rounds of off-post sampling of 20 wells and added three rounds of on-post sampling. The three rounds of on-post sampling includes sampling of 24 wells in June 2001, increasing to 28 wells during the September and December 2001 sampling events as newly installed monitoring wells are incorporated into the sampling scheme.

Percent Complete

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

Task II - Interim/Stabilization Measures Implementation

Task Description

The Interim/Stabilization Measures Implementation includes sampling and analysis of groundwater from off-post wells; sampling and analysis of groundwater in CSSA wells; identification of all off-post 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. Although activities at AOC 50 to remove the nickel penetrate waste are not included in the Order as an IM, this task is also considered to include the work at this site. The status of each is described below.

Completion of this task is partially funded along with interim measures and a partial facility closure of SWMU O-1 under RL74. In addition, sampling of 20 off-post wells for 4 quarters (VOCs only) is funded under AETC DO5084. This task was originally funded for 6 quarters, but funding from two of the quarters was removed in May 2001 to partially fund three quarterly on-post groundwater sampling events from June through December 2001. The first round of off-post groundwater sampling under DO5084 is tentatively scheduled to begin in September 2001.

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.

A water well survey was conducted (under RL 83) to identify all wells within 0.25 miles of the CSSA facility boundary. The final version of the Water Well Survey Report will be submitted during Quarter 10.

Activities this Quarter

CSSA finalized the Off-Post Monitoring Response Plan. This Plan provides a brief history of CSSA groundwater contamination, outlines potential off-post wells for sampling, and includes VOC action levels and Army responses. In addition, letters requesting site access and formal access agreements for the potential off-post sampling effort have been finalized. Both of these documents are integral to the off-post sampling effort.
CSSA has finalized Fact Sheets 1 and 2 that give a general overview of the CSSA environmental program and environmental concerns. These fact sheets will be mailed to the community in early August.
Preparations are being made to install granular activated carbon (GAC) wellhead treatment at off-post well LS-7. Vendors have been contacted and preliminary cost estimates are being reviewed. The installation of this GAC unit will be done in accordance with the Off-Post Monitoring Response Plan.
CSSA is currently in the process of identifying private wells for off-post groundwater sampling under the AETC contract DO5084. CSSA evaluated their public communication plan with regard to this off-post sampling, and began the process of public notice and obtaining access agreements from private well owners to allow sampling of the selected off-post wells. Sampling of 20 off-post wells will begin after access agreements are finalized in September 2001.
Work resumed at AOC 50 after the discovery of a disposal trench and additional nickel penetrate buried in the subsurface. A new waste profile was generated for the disposal of trench wastes discovered in March 2001. The profile was submitted to Waste Management, Inc. along with analytical data that characterized the waste stream in June 2001. The waste profile was accepted on July 6, 2001. Eagle Construction and Environmental Services re-mobilized to the site on July 16, 2001 to collect approximately 150 cubic yards of stockpiled trench contents and an additional 100 cubic yards of soil laden with nickel penetrate for transport to Coral Gardens Landfill in San Antonio, Texas, where the waste was disposed.
Parsons ES is currently incorporating changes into the final version of the Water Well Survey. Recent data acquired from Camp Bullis was reviewed to determine the proximity and applicability to the report. The review showed that only one Camp Bullis monitoring well was located within 1 mile of CSSA. The remaining Camp Bullis wells, located at potential hazardous waste sites, are located distances of 2 to 4 miles from CSSA, and are not considered relevant to the well survey report. Additional data received during a meeting with the Bexar Metropolitan Water District on July 2, 2001 is also being incorporated into the final report. The final version will be submitted as a new section to the CSSA Environmental Encyclopedia (Volume 5, Water Well Survey) during Quarter 10.
Quarterly groundwater monitoring of the on-post wells was performed the week of June 11, 2001. CSSA wells 1, 2, 9, 10, 16, D, G, H, I, MW1-LGR, and MW2-LGR, MW3-LGR, MW4-LGR, MW5-LGR, MW6-CC, MW6-BS, MW6-LGR, MW8-CC, MW8-LGR, MW9-CC, MW9-BS, and MW9-LGR were sampled. In addition, one off-post sample was collected at well LS-7 on June 12, 2001. The locations of the sampled wells are shown on Figure 2.1 in Attachment 2. Well 11 was not sampled during this event because the pump control panel was not functioning at the time of sampling. Samples were analyzed by APPL and results were submitted to Parsons ES in mid-July, 2001. Preliminary unvalidated groundwater results are included in Attachment 2. In addition, quarterly groundwater monitoring reports for December 2000 and March 2001 were issued for inclusion into the CSSA Environmental Encyclopedia (Volume 5, Groundwater Monitoring) during this reporting period.
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 9. In Quarter 7, samples were collected from the sifted soils within SWMUs B-8, B-20, B-24, B-28 and DD and analyzed for TCLP metals to determine proper disposition. Analytical results received in Quarter 8 indicate that all excavated soil piles are non-hazardous as defined in 30 TAC Chapter 335, Subchapter R. The Draft Soil Disposition Assessment Report is expected to be completed, along with the initiation of bench-scale studies of other treatment technologies (e.g., density treatment, phytoextraction, etc.) during Quarter 10.
A treatability study for stabilization of the excavated lead-contaminated soils at SWMU B-20 continued during Quarter 9. The initial results of the treatability study, which is being conducted by UFA Ventures, ESTCP, with support from Parsons ES, are further discussed under Task VI (Treatability Studies). The UFA Ventures treatability study will be incorporated into Volume 4 of the CSSA Environmental Encyclopedia. The PIMS field scale treatability study construction efforts were completed during Quarter 9. The PIMS field scale treatability study monitoring efforts are expected to continue through August of 2002. A final report of the PIMS treatability study is expected in September 2002.
The CSSA GAC water treatment unit was brought on-line during Quarter 9. Treatment of purged groundwater from the MW8 well cluster began the first week of May 2001. Treatment began after discrete interval groundwater samples from the borehole indicated concentrations of contaminants above the MCLs. The GAC unit operates at a maximum capacity of 20 gallons per minute (28,800 gallons per day). During its two week treatment period for MW8 groundwater, 20,020 gallons of groundwater were treated at the GAC unit. The treated water was discharged at the TPDES-permitted outfall 002.
CSSA held a meeting on July 12, 2001 to plan public communication strategy for notifying local government/community representatives, media and local residences related to the CSSA groundwater investigation program and obtaining access to off-post residences. Meetings were held with Bexar Metropolitan Water District, the Edwards Aquifer Authority, Fort Sam Houston, and Fair Oaks Water Company. Additional meetings were also held with the Alamo Area Council of Governments. Also, congressional notices and fact sheets were mailed to area state and federal legislators. Minutes from the July 12, 2001 strategy meeting are presented in Attachment 3. Lists of attendees and meeting agenda (minutes) from the meetings held to discuss the CSSA groundwater investigation program are also included in Attachment 3.
  1. Percent Complete

This task makes up approximately 70% of the IM phase. This task is considered 29% complete, based on the current projected activities listed in Task II, Task Description. The percent complete for this task has been adjusted to include on-post groundwater which was initiated in January 2000. As a result of this modification to the scope for this task, the percent complete is lower than reported during Quarter 8. 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.

  1. Summary of Findings

Quarterly groundwater monitoring of the on-post wells and one off-post well was performed during the week of June 11, 2001 at CSSA. A revised map of the well locations is provided as Attachment 2 of this report. This map includes well installations completed through the end of Quarter 9.

On-post Wells, June 2001: CSSA wells 1, 2, 9, 10, 16, D, G, H, I, MW1-LGR, MW2-LGR, MW3-LGR, MW4-LGR, MW5-LGR, MW6-CC, MW6-BS, MW6-LGR, MW8-CC, MW8-LGR, MW9-CC, and MW9-BS were sampled during the June 2001 sampling event. Well 11 was not sampled during this event because the pump control panel was not functioning at the time of sampling. Results of the June 2001 groundwater monitoring event will be formally reported in a draft Quarterly Groundwater Monitoring Report which will be submitted to CSSA and AFCEE during Quarter 10 and placed in the Environmental Encyclopedia, Volume 5. A table showing preliminary unvalidated laboratory results is included in Attachment 2.

Off-post Wells, June 2001: One off-post sample was collected at well LS-7 during the June 2001 sampling event. Samples were analyzed by APPL. Results of the June 2001 groundwater monitoring event will be formally reported in a draft Quarterly Groundwater Monitoring Report to be submitted to CSSA and AFCEE during Quarter 10 and placed in the Environmental Encyclopedia, Volume 5. Preliminary unvalidated laboratory results for the off-post well sampling are included in Attachment 2.

  1. Summary of Changes

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

  1. Summary of Contacts

During the reporting period CSSA held meetings to discuss upcoming drilling activities with water supply agencies and plan public communication strategy related to groundwater issues. CSSA met with representatives of Bexar Metropolitan Water District on July 2; representatives of the Edwards Aquifer Authority (EAA) on July 3; Commanding General of Fort Sam Houston and Garrison Commander on July 10; and representatives of Fair Oaks Water Utility on July 16. Also, CSSA contacted the owners of off-post wells LS-5 and LS-6 regarding drilling at the MW10 location and potential impacts to groundwater quality.

Other meetings conducted during the quarter included a July 12th meeting between CSSA, USACE and Parsons ES to discuss public participation and upcoming meetings. Additionally, Parsons ES attended the EAA Board Meeting on July 10 for a review of CSSA groundwater issues given by the EAA Chief Technical Officer. No other contacts, with the exception of the owner of well LS-7, associated with IM activities, were made during this reporting period. Where available, agendas and participant lists for the Quarter 9 meetings are included in the Environmental Encyclopedia Volume 1-1 behind the Meetings tab. A list of Quarter 9 project meeting is included as Attachment 3 of this report.

  1. Summary of Problems

No problems associated with IM activities this reporting period.

  1. Actions Taken to Correct Problems

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

  1. 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 planned 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.

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. These continued O&M activities include watering the cap to maintain vegetative cover. Confirmation surface samples from AOC 50 will be collected and analyzed for VOCs, metals and explosives, to verify that all waste materials have been removed.

The next quarterly groundwater monitoring event will be conducted in September 2001. This upcoming event will include the existing CSSA wells that are typically sampled, 20 off-post wells (VOCs only), as well as newly completed and developed wells. A final version of the June 2001 groundwater monitoring report may be issued for inclusion into the CSSA Environmental Encyclopedia.

Activities for contract efforts to install additional monitoring wells and a sub-slab SVE system for Building 90 remediation will be initiated.

CSSA anticipates holding an open house in September to inform local residences of the CSSA groundwater investigation and RFI program. One meeting is planned with the residences of Leon Springs and another with residences of Fair Oaks.

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

Preliminary groundwater data for the June 2001 sampling event are included in Attachment 2.

Task III - Reports

Task Description

Reports associated with the IM include quarterly progress reports, groundwater monitoring reports and an Interim/Stabilization Measure Report. This quarterly progress report is submitted as part of this task. The O-1 IM/Closure Report documented IM and RFI activities conducted at SWMU O-1.

Completion of this task has been partially funded. Progress reports for two years (August 1999 – May 2001) were funded (under RL83 of the AMC contract). Another six progress reports (July 2001 – October 2002) are also funded (under DO5084 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. Three on-post and four off-post groundwater monitoring reports are funded under DO5084 of the AETC contract.

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.

A report summarizing the most recent groundwater findings is submitted as part of the quarterly groundwater monitoring task. The quarterly groundwater monitoring reports present the groundwater elevations and the analytical results that were recorded for each well. The groundwater elevations are presented in a potentiometric surface map as well as in tabular format. Analytical results from the most recent sampling event are compared to levels from the previous quarters while historical analytical results can be found in the Introduction to the Quarterly Groundwater Monitoring Program document.

Activities this Quarter

The draft March 2001 Groundwater Monitoring Report was submitted by Parsons ES in June 2001 for technical review by AFCEE and CSSA. Comments/responses received indicated that the Quarterly Groundwater Reports should include data collected prior to June 2000 and be updated each quarter to include the most recent analytical and groundwater elevation data.

CSSA and AFCEE commented on the draft December 2000 and March 2001 Groundwater Monitoring Reports during Quarter 9. The final December 2000 and March 2001 Groundwater Monitoring Report were submitted to AFCEE and CSSA in July 2001 for inclusion in Volume 5 of the Environmental Encyclopedia.

  1. Percent Complete

This task makes up approximately 23% of the IM phase. With completion of this progress report, this task is approximately 60% 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 require at additional sites, the percent complete will be adjusted accordingly.

  1. Summary of Findings

No findings associated with progress reports or IM reports this reporting period.

  1. Summary of Changes

No changes associated with progress reports or IM reports this reporting period.

  1. Summary of Contacts

No contacts related to quarterly progress reports or IM Reports were made during this reporting period.

  1. Summary of Problems

Preparation of the Soil Pile Disposition Assessment Report was delayed due to analytical data package verification, validation, and review.

  1. Actions Taken to Correct Problems

Several meetings were held to discuss the appropriate methodologies for analytical data packages including contractual agreements between the government, contractors and subcontractors. Results of these meetings provided a clear path for the level of effort expected on the verification, validation and review of the remaining analytical data packages.

  1. Projected Work for the Next Quarter

Preparation of the draft Soil Pile Disposition Report will be completed next quarter.

Parsons ES will submit the draft June 2001 Groundwater Monitoring Report, and will revise the report based on comments/responses received from CSSA and AFCEE. The final Quarterly Groundwater Monitoring Report will be submitted for inclusion into the Environmental Encyclopedia during the next quarter. Groundwater data from the September 2001 quarterly sampling event will be received and data review and validation will be initiated for the draft September 2001 Groundwater Monitoring Report.

CSSA is currently developing a new Task Order for the installation of 24 new monitoring wells, fourteen wells completed in the Lower Glen Rose, three wells in the Bexar Shale, and seven wells in the Cow Creek. Also included in the new task order are quarterly groundwater monitoring of the 24 new wells through September 2002, and upgrades to six existing monitoring wells.

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

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

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