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

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 9, the RFI is approximately 39% complete.

Task I - Preliminary Report: Description of Current Conditions

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. The final DCC Report was submitted to EPA and TNRCC on August 1, 1999. No regulatory comments have been received on the report. This task makes up approximately 5% of the RFI phase, and it is 100% complete.

Task II - RFI Work Plan

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 required by the Order, in a unique format, will be used to fulfill this requirement. Completion of this task is funded for the RFI tasks that are planned.

Activities this Quarter

The RFI tasks at AOC 65 and AOC 67 were initiated earlier than originally scheduled to investigate the possible contaminant sources around Building 90 prior to collection of any off-post groundwater samples.

1. Percent Complete

This task makes up approximately 10% of the RFI phase. Estimation of percent complete is difficult due to the continuing need for plan addenda. As of the end of Quarter 9, work currently under scope is approximately 99% complete. The remaining 1% of this task is associated with a Waste Analysis Plan (WAP) for PIMS activities and the CSSA Encyclopedia hypertext document, which will be incomplete for an indefinite period of time as work plan addenda are prepared.

2. Summary of Findings

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

3. Summary of Changes

No changes to the RFI Work Plan were made during the reporting period.

4. Summary of Contacts

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

5. Summary of Problems

No problems related to the RFI Work Plan during this reporting period.

6. Actions Taken to Correct Problems

No actions to correct problems necessary during this reporting period.

7. Projected Work for the Next Quarter

All plans and plan addenda are completed, with the exception of the WAP for the PIMS activities. The WAP addenda will be prepared and submitted for AFCEE and CSSA review during the next quarter.

8. 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

Task Description

An investigation of the facility is being 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 are being conducted in accordance with the RFI Work Plan. Deviations have been documented with work plan addenda.

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 AOCs, except AOCs 44-46, 49, 51-55, 59, 60, 62-64, and 67-73, is funded. Currently, the installation of fifteen monitoring wells is funded.

Activities this Quarter

Groundwater

Through July 31, 2001, a total of thirteen monitoring wells have been installed. During this quarter, two well pairs have been installed and developed. 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. New to the drilling activities this quarter, discrete interval groundwater samples were collected from the MW7 and MW8 boreholes utilizing either a single or double packer system. Results of the interval screening are discussed in the Summary of Findings section under Task III of the RCRA Facility Investigation.

Low-flow pumps were installed at CSSA wells MW-3 LGR, MW-4 LGR, and MW-5 LGR, MW-9 LGR, MW-9 BS, and MW-9 CC during this reporting period.

SWMUs and AOCs

	Verification of data packages (152 packages for all CSSA projects excluding the soil vapor screening data packages from DHL Analytical) was completed during Quarter 9. AFCEE chemists approved 26 data packages as of the end of this quarter. Ninety four packages have been submitted and are awaiting AFCEE comments/approvals. The remaining 32 packages are being verified by Parsons chemists. Meetings with CSSA, AFCEE, and Informatics were held on May 17 and 22 to discuss DQOs for the June 2001 groundwater monitoring sampling event.
	The investigation work at AOC 65 and AOC 67 included drilling and sampling of 17 soil borings, 3 of which are inside Building 90 and the remaining 14 were located outside of the building. Drilling was completed, and four monitoring wells were installed by CSSA under a contract with JEDI. The four monitoring wells were located along the western and southwestern perimeter of Building 90. One of these wells is a nested well cluster, which includes two casings in one monitoring well borehole. The total depth of these wells ranged from 19 feet below grade to 33 feet below grade. Groundwater samples have been collected from three of the five monitoring well casings and one soil boring. The two remaining wells did not produce water in this upper zone.
	RFI/Closure Reports for sites investigated in February and March 2001 were prepared during Quarter 9. A total of 41 reports are being prepared. Although analytical packages have not yet been approved by AFCEE, Parsons ES submitted draft reports for AOC 58, SWMU B-5, and SWMU B-7 to CSSA and AFCEE for comment. Sites that meet RRS1 requirements will be certified by a professional engineer.

1. Percent Complete

This task makes up approximately 45% of the RFI phase. As of the end of Quarter 9, this task is approximately 21% complete.

2. Summary of Findings

Groundwater

Data collection from the well cluster installations continued through the end of Quarter 9. The installation of the MW7 and MW8 well pairs indicated that the overall stratigraphy in the southwest corner of the facility is similar to the MW6 cluster installed during Quarter 8. As an example, the Bexar Shale was encountered at nearly the same elevation at all three drilling locations. There was some marked variability between the borehole locations with respect to overall competence, fractures, voids, and water production. Geophysical logs have indicated evidence of faulting between MW6 and the MW7 and MW8 locations. The Cow Creek limestone has exhibited some poorer water quality characteristics at MW7 and MW8 than at other previously drilled locations, notably the presence of a hydrogen sulfide odor in the groundwater. In addition to the hydrogen sulfide odor, the Cow Creek water at MW8 remained slightly turbid after development was completed.

Discrete interval groundwater sampling was preformed during drilling at locations MW7 and MW8 to assess contaminant profile with depth and to provide directions regarding well installation and construction. Samples collected from MW8 showed stratified occurrences of MEK, acetone, PCE, TCE, cis-1,2-DCE, and toluene to a depth of approximately 300 feet below grade. Analytical results were provided by DHL Analytical of Round Rock, Texas under direct subcontract to CSSA. The analytical work was performed on a quick-turn basis (usually less than 8 hours from sample receipt) and was not validated. Thirteen samples were collected from MW8-LGR and five samples from MW8-CC. An additional nine groundwater samples were collected during the drilling of MW7-LGR and MW7-CC, seven in the Lower Glen Rose and two in the Cow Creek. A composite graph provided in Attachment 4 shows the relative concentration of contaminants with respect to depth at location MW8.

At the MW8 drilling site, concentrations up to 57 micrograms per liter (μg/L) PCE and 20.5 μg/L of TCE were detected in all samples collected between 83 feet and 300 feet below grade. Significantly lesser occurrences of cis-1,2-DCE (0.57 μg/L), MEK (15 μg/L), acetone (50 μg/L), and toluene (14.2 μg/L) were reported in the upper 300 feet of the Glen Rose Limestone. Similar COCs were identified in the MW7-LGR and MW7-CC discrete interval samples, but at generally lower concentrations. The highest PCE and TCE results were 10.2 and 8.32 μg/L, respectively.

SWMUs and AOCs

Soil/rock samples from AOC 65 and AOC 67 RFIs indicated PCE in eight samples, from six of the 17 borings advanced. The locations of the borings and monitoring wells are presented on a map in Attachment 5. These samples were retained primarily between the surface and depths up to 4 feet below grade. With the exception of the high levels detected in AOC65-SB03 (1.5-2 feet), PCE was detected in concentrations up to 1.491 mg/kg (SQL, 0.035 mg/kg) in all samples tested. Again, with the exception of AOC65-SB03 (1.5-2 feet), metals (barium, chromium, cadmium, zinc, copper, lead and nickel) were detected in 12 samples from 9 borings in low concentrations, all less than twice background. AOC65-SB03 (1.5-2 feet) located over the (drain), contained 6 metals and 7 VOCs, notably lead (1,259.95 mg/kg, background, 128 mg/kg), and zinc (979.5, background, 84.3) PCE (124.4 mg/kg, SQL, 2.8 mg/kg), and TPH-DRO (2,863.1, SQL, 500).

Groundwater samples were collected from the wells installed at AOC65. PCE was detected in AOC65-MW01 (11 ug/L), AOC65-MW04 (7.8 ug/L) and AOC65-MW02A (950 ug/L). TCE and DCE were detected in AOC65-MW01 (17 and 1.7 ug/L, respectively) and AOC65-MW02A (39 and 23 ug/L, respectively). Additionally, a groundwater sample was collected from soil boring SB-06, located on the eastern side of Building 90. Results of the sample from SB-06 included PCE at a concentration of 18 ug/L, whereas the TCE concentration was less than 1.0 ug/L. Attachment 5 presents approved data from the AOC 65 and AOC 67 RFI including soil and groundwater sample results.

3. Summary of Changes

CSSA is in the process of installing 15 new monitoring wells to evaluate ground water conditions in the Middle Trinity Aquifer. This work includes eight wells to be completed in the Lower Glen Rose limestone, five to be completed in the Cow Creek limestone, and two completed in the Bexar Shale. Through July 31, 2001, a total of thirteen wells are finished: 7 Glen Rose completions (MW9-LGR, MW3-LGR, MW4-LGR, MW5-LGR, MW6-LGR, MW7-LGR, and MW8-LGR), 4 Cow Creek completions (MW6-CC, MW7-CC, MW8-CC, and MW9-CC), and 2 Bexar Shale completions (MW6-BS and MW9-BS).

As a result of the discrete interval groundwater sampling, the well design at the MW8 well pair was modified to guard against the downward migration of contaminants in the Glen Rose Limestone. With EPA approval, temporary surface casing was installed during the LGR coring activities to a depth of 173 feet, followed by the installation of permanent casing to 273 feet before proceeding into the primary production zone of the Lower Glen Rose. At MW8-CC, the surface casing was extended to 303 feet based on the results of further testing of the Lower Glen Rose corehole. The second string of casing in the MW8-CC well was completed through the entire Glen Rose formation to protect the Bexar Shale and Cow Creek from the uphole contaminants. With EPA approval, no additional casing was installed to separate the Bexar Shale from the Cow Creek Limestone.

During Quarter 9, the installation approach changed to address potential off-post contamination plumes such that planned Bexar Shale wells at MW7 and MW8 were deferred from the groundwater program initiative in lieu of installing an extra Lower Glen Rose and Cow Creek well pair in the extreme southwestern corner of the facility. The additional well pair, MW10-LGR and MW10-CC, are scheduled to begin drilling at the start of Quarter 10.

Two pumping tests were started during the last two weeks of Quarter 9, and will be completed the first week of Quarter 10. A brief proposal to perform limited pumping tests at Wells 10 and 16 was presented to CSSA, EPA, and TNRCC on July 6, 2001. The basis of the pumping tests is to determine aquifer characteristics in the vicinity of the northern Inner Cantonment TCE plume, as well as near the current public water supply wellfield located at the western edge of the facility. Results from these limited pumping tests will be used to appropriately design and size an observation well network for future pumping test studies in the vicinity of Well 16 and Building 90. The benefit of performing a pumping test at Well 10 is that the purged groundwater does not require treatment for volatile organic compounds (VOCs). Groundwater extracted from Well 16 will require a VOC treatment unit to discharge to the surface. Verbal permission from Kirk Coulter and Abigail Power of the TNRCC has been given to CSSA to temporarily discharge treated groundwater at concentrations below the MCL during performance of these pump tests. Data from these pump tests was not available for inclusion into this quarterly report.

Under this new plan, more attention will be focused on the Lower Glen Rose and Cow Creek, which are the major groundwater producing intervals in both on- and off-base drinking water wells. The change was justified based on well development, injection test, and laboratory permeability data that was derived from MW6-BS and MW9-BS. This information indicated the Bexar Shale is relatively impermeable and not likely to transmit significant volumes of water to on- or off-base wells. If needed, Bexar Shale wells could be installed at a later date.

4. Summary of Contacts

CSSA has been in close contact with the EPA and TNRCC since contaminated (above MCL) groundwater was detected in the open borehole of the MW8 cluster. During the quarter, CSSA met with representatives of the San Antonio Metropolitan Health District, City of San Antonio Department of Public Works, Environmental Services Branch, and the Center for Water Research, University of San Texas San Antonio to brief them on groundwater contamination plume concerns, investigation findings, including implementation of the Off-Post Monitoring Response Plan.

Owners of off-post wells LS-1 through LS-7 were contacted regarding potential degradation of their groundwater supply during the at the MW10 site. The owners were informed that their wells would be sampled before, during and after drilling to confirm groundwater quality and establish baseline values. The owners were also informed that provisions would be made to supply them with bottled water while drilling is under way. Additionally, Bexar Metropolitan Water District, the owner of wells LS-1 through LS-4, has agreed to shut down wells LS-3 and LS-4 to minimize potential impacts to groundwater during drilling.

On May 15, 2001, CSSA submitted electronic correspondence to EPA regarding a revision to the approach for drilling, testing and completion of monitoring well MW-8-CC. In addition, on May 20, 2001, CSSA submitted via electronic correspondence to EPA a memorandum describing the proposed management of drilling fluids generated during the current monitoring well installation program. Where available, copies of correspondence are included as Attachment 6 of this report.

5. Summary of Problems

Slow submittal and approval of the large number of analytical data packages has hampered progress on completion of closure/investigation reports. There are numerous laboratories, chemists, and analytical methods involved. Between January 18, 2001, and April 8, 2001, no packages were submitted due to outstanding unresolved issues.

6. Actions Taken to Correct Problems

To address the slow submittal and approval of data packages, more frequent meetings and weekly teleconference calls have been held to expedite resolution of outstanding laboratory package issues. Between May 2, 2001, and July 9, 2001, 94 data packages have been submitted.

7. Projected Work for the Next Quarter

The installation and development of 15 monitoring wells will continue through Quarter 10. Data from the pumping tests will be evaluated, and a letter report documenting the results of the tests will be issued.

Under AETC DO5084, the Draft Technical Report for the soil gas survey will be completed for AFCEE and CSSA review. The draft RFI report for AOC 65 and AOC 67 will be prepared and submitted to AFCEE and CSSA for review.

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

Draft summary tables and figures are attached to this report that present the results from the AOC 65 and AOC 67 RFI (Attachment 5).

Task IV - Human Health and Ecological Risk Assessment

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.

During Quarter 9, additional information was incorporated into the Risk Assessment Technical Approach Document. Information regarding AFCEE quantitation limits and how they relate to TNRCC definitions, as well as information about wildlife, hunting areas, and ponds was added. 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.

Task V - Investigation Analysis

Task Description

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 last year was continued as described previously in RFI Task III.

1. Percent Complete

This task makes up approximately 10% of the RFI phase, and is approximately 27% complete.

2. Summary of Findings

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

3. Summary of Changes

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

4. Summary of Contacts

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

5. Summary of Problems

No problems related to the Investigative Analysis during this reporting period.

6. Actions Taken to Correct Problems

No actions to correct problems necessary during this reporting period.

7. Projected Work for the Next Quarter

Continued work on comparison of investigation results to closure criteria.

8. 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

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. Funded activities included bench-scale treatability studies for SWMU B-20 and additional study of the SVE system at SWMU B-3. In addition, a treatability study of a stabilization process is also taking place.

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 9. The PIMS field demonstration construction activities were initiated May 16, 2001 and completed June 21, 2001. Initial sampling and data collection efforts were completed July 9, 2001 with analytical results anticipated to be available for the next quarterly progress report. The field construction activities included the construction of a synthetic lined test cell with an approximate volume of 500 cubic yards. The test cell was constructed to allow leachate to be collected and redistributed on the surface of the unit. Additionally, a 50,000-gallon water storage pond was installed to provide the anticipated water requirements for a 30-year rainfall simulation event (approximately 3.5 million gallons of water applied to the surface of the test cell). Monitoring of the field treatment efforts are expected to continue for a minimum of one calendar year. The additional 2,000 cubic yards of sifted soils at the SWMU B-20 site were treated with the PIMS apatite II material and remain stockpiled at the site. Approximately 10 cubic yards of untreated soil remain at the B-20 site for use in other treatability studies.

Analytical results from resampling of the soil samples collected as part of the initial SWMU B-3 treatability study (1997) were received during the Quarter 8 reporting period. The data from this resampling event are continuing to be reviewed and evaluated, and are not yet approved.

CSSA received a pilot study Scope of Work for asphaltic stabilization of metals impacted soil from Raba Kistner Consultants. CSSA is reviewing the SOW for potential use.

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 all pertinent data (e.g., analytical, physical, etc.) 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.

2. Summary of Findings

Analytical data received from waste characterization efforts for the soil piles generated from UXO investigations at SWMUs B-8, B-20, B-24, B-28, and DD Area resulted in a non-hazardous waste classification. >All results will be reported in the Soil Pile Disposition Report, which will be completed during Quarter 10.

Analytical data from the 10-month emissions sampling event (performed November 6 and 7, 2000) at B-3 was approved on May 10, 2001. The draft Operations and Maintenance Assessment Report for the entire year of testing will be completed upon AFCEE approval of the data packages.

3. Summary of Changes

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

4. Summary of Contacts

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

5. 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.

6. Actions Taken to Correct Problems

No actions to correct problems necessary during this reporting period.

7. Projected Work for the Next Quarter

No additional O&M testing is planned at SWMU B-3 until the findings and recommendations from the O&M report are evaluated. The final SVE system assessment report is tentatively scheduled for submittal during the next quarter (Quarter 10).

Monitoring of the PIMS treatability study is expected to continue during the next quarter. Additionally, field scale treatability studies of soil density separation followed by phytoextraction are expected to be initiated during the next quarter (Quarter 10) for the previously sifted soil piles as part of the IM activities.

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

Daily reports and inspection reports relating to the PIMS treatability study were generated during this reporting period and are included in Attachment 6.

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 (June 2001 – October 2002) are funded under DO5084 of the AETC contract.

1. 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 7%.

2. Summary of Findings

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

3. Summary of Changes

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

4. Summary of Contacts

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

5. Summary of Problems

No problems related to the Progress Reports during this reporting period.

6. Actions Taken to Correct Problems

No actions to correct problems necessary during this reporting period.

7. Projected Work for the Next Quarter

Progress Report for Quarter 6 will be submitted.

8. 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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