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10th Quarter - Final Quarterly Progress Report
RCRA Facility Investigation (RFI)
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 percent of the required actions at CSSA. The RFI includes a Preliminary Report (5 percent of RFI), RFI Work Plan (10 percent), Facility Investigation (45 percent), Investigation Analysis (10 percent), Treatability Studies (10 percent), and Progress Reports (5 percent). As of the end of Quarter 10, the RFI is approximately 42 percent 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 the EPA and TNRCC on August 1, 1999. No regulatory comments have been received on the report. This task makes up approximately 5 percent of the RFI phase, and is 100 percent complete.
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 will be used to fulfill this requirement. The Environmental Encyclopedia includes all the information required by the Order in a unique format. Completion of this task is funded for the RFI tasks that are planned.
Activities this Quarter
No RFI work plan activities were performed during the subject-reporting period.
Percent Complete
This task makes up approximately 10 percent of the RFI phase. Estimation of percent complete is difficult due to the continuing need for plan addenda. As of the end of Quarter 10, work currently under scope is approximately 99 percent complete. The remaining 1 percent of this task is associated with the groundwater sampling plan addenda for AETC Delivery Order 5084 and the CSSA Environmental Encyclopedia hypertext document, which will continually be updated as documents are added
Summary of Findings
No new findings are associated with RFI Work Plan preparation during this reporting period.
Summary of Changes
No changes to the RFI Work Plan were made during the reporting period.
Summary of Contacts
CSSA has contacted Veni and Associates and the Earth and Physical Sciences Department at the University of Texas at San Antonio (UTSA) to discuss groundwater investigations and possible remediation options. Both Veni and Associates and UTSA have submitted outlines of possible scopes of work and investigation goals. CSSA and Parsons will evaluate whether services from UTSA are necessary in the future.
Summary of Problems
No problems related to the RFI Work Plan occurred during this reporting period.
Actions Taken to Correct Problems
No actions to correct problems were necessary during this reporting period.
Projected Work for the Next Quarter
All plans and plan addenda are complete, with the exception of the revised groundwater sampling plan addenda. These addenda will be prepared and submitted after receipt of all comments from AFCEE and CSSA during the next quarter.
Copies of Daily Reports, Inspection Reports, Data, etc.
No daily reports, inspection reports, or data related to the RFI Work Plan were 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 planned RFI tasks. 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 39 monitoring wells is funded. Fifteen of these wells have been completed. Parsons will initiate work on a new Task Order for the installation of 24 new monitoring wells, 14 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.
Activities this Quarter
Groundwater
Through October 31, 2001, 15 monitoring wells have been installed. During this quarter, one well pair was installed and developed, designated CS-MW10-LGR and CS‑MW10-CC. 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. Discrete interval groundwater samples were collected from the CS-MW10-CC boreholes utilizing a double packer system. Results of the interval screening are discussed in the Summary of Findings section of this Task Order of the RFI (below).
As part of the drilling program, nearby off-post wells LS-2, LS-3, LS-5, LS-6, and LS-7 were monitored periodically for significant changes in water quality due to drilling impacts. A baseline round was collected on August 1, 2001 for VOCs, TSS, TDS, turbidity, pH, and specific conductance on August 1, 2001. A follow-up round for VOCs only was collected from LS-2, LS-3, LS-6, and LS-7 on August 30, 2001. A sample from RFR-12 was substituted for LS-5 during that round of sampling. A final round of samples was collected upon completion of the drilling on September 27, 2001 from LS-2, LS-3, LS-6, and LS-7, and included VOC, TSS, TDS, turbidity, pH, and specific conductance analyses. Results for the final round are not yet available. Nearby off-post well owners at locations LS-6 and LS-7 were provided bottled water during the drilling event as a precautionary measure.
Low-flow pumps were repaired and re-installed at CSSA wells CS-MW3-LGR, CS‑MW4-LGR, CS-MW5-LGR, CS-MW9-LGR, CS-MW9-BS, and CS-MW9-CC during this reporting period. New low flow pumps were installed at recently completed well pairs CS-MW6, CS-MW7, and CS-MW8. CSSA has initiated the ordering process for low flow pumps to be installed in CS-MW10-LGR and CS‑MW10-CC.
Two pumping tests were conducted at CSSA during Quarter 10 between the dates of July 16 and August 13, 2001. The tests were conducted at CSSA Wells CS-10 and CS-16. Existing wells within the inner cantonment were utilized as observation wells. At Well CS-10, a 48-hour flow test was followed by at 72-hour pumping test and 24-hour recovery test. The purged groundwater was used in the distribution system as normal, with excess volumes diverted to the “D” Tank within the inner cantonment. In addition, an 8-hour step-drawdown test was conducted at Well CS-16. High capacity GAC units were used to treat the groundwater at a maximum flowrate of 50 gpm. The step test was followed by a 72-hour pumping test and 24-hour recovery test. The CSSA distribution system was utilized to convey purged and treated groundwater 3,300 feet to the south near Building 45. These efforts were coordinated through the EPA and TNRCC.
SWMUs and AOCs
Verification of additional data packages was continued during Quarter 10. AFCEE chemists approved two additional data packages during Quarter 10 for a total of 28 data packages as of October 2001. Parsons submitted 11 additional data packages during Quarter 10. Through October 31, 2001, approximately 124 data packages were submitted and waiting for AFCEE comments/approvals. Five teleconferences were conducted to discuss AFCEE QAPP during Quarter 10.
Preparation of RFI/Closure Reports for CSSA SWMUs and AOCs continued during Quarter 10. A total of 41 reports are being prepared. To date, 22 draft reports have been completed. Although analytical packages have not yet been approved by AFCEE and CSSA, Parsons submitted draft reports for SWMUs B-2, B-8, B-11, B-12, B-13, B‑15/16, B-20/21, B-22, B-23, B-24, B-25, B-27, B-28, B‑30, B-31, B-33, and DD, and AOCs 36, 38, 39, 40, 47, 48, 56, and 61 to CSSA and AFCEE for comment. Sites that meet RRS1 closure requirements will be certified by a professional engineer. A summary of the status of each site is provided in Attachment 1.
Work continued on RFI/Closure reports for AOC 65 and AOC 67, near Building 90, during Quarter 10.
The Draft Technical Report for the Soil Gas Survey was submitted to CSSA, prepared under AETC DO5084. Comments were received during Quarter 10 from AFCEE and CSSA on this report.
Percent Complete
This task makes up approximately 45 percent of the RFI phase. As of the end of Quarter 10, this task is approximately 22 percent complete.
Summary of Findings
No new findings are associated with RFI Work Plan preparation during this reporting period.
Groundwater
Data collection from the well cluster installations continued through the end of Quarter 10. Installation of the CS-MW10 well pair indicated that the overall stratigraphy in the southwest corner of the facility is similar to the CS-MW6 cluster installed during Quarter 8, and CS-MW7 and CS-MW8 well pairs installed during Quarter 9. Geophysical and observation logs indicate evidence of faulting between CS‑MW10 and the CS-MW7 and CS-MW8 locations, as geologic contacts were encountered approximately 30 feet lower in elevation than predicted.
Discrete interval groundwater sampling was performed during drilling at location CS‑MW10-CC to assess contaminant profile with depth and to provide directions regarding well installation and construction. Samples collected from CS‑MW10‑CC showed localized occurrences of PCE and toluene in the Glen Rose Limestone to a depth of approximately 368 feet below grade. One occurrence of acetone was reported at 447 feet within the Bexar Shale. Analytical results were provided by DHL Analytical of Round Rock, Texas. The analytical work was performed on a quick-turnaround basis (usually less than 8 hours from sample receipt) and was not validated. These results were not validated because the data were used for screening purposes only. Eight samples were collected from CS‑MW10-CC.
At CS-MW10-CC, concentrations up to 0.74 micrograms per liter (μg/L) PCE were detected in two discrete interval grab samples collected between 325 to 336 feet and 357 to 368 feet below grade. A grab sample collected from the open borehole between the water table (205 feet) and the interim total depth of the drilling (411 feet) yielded a result of 1.51 μg/L of PCE. One occurrence of toluene was reported at a concentration of 0.47 μg/L between 357 to 368 feet. A concentration of 45 μg/L of acetone was reported within the Bexar Shale interval between 436 and 447 feet, but can be attributed to the drilling foam which adhered to a poor-yielding interval; the grab water sample was visibly foamy.
The baseline off-post well sampling conducted on August 1, 2001 reported PCE concentrations between 0.28 μg/L (LS-5) and 6.00 μg/L (LS-6) in all wells sampled. TCE was detected in all off-post wells at concentrations ranging between 0.26 μg/L (LS-2) and 0.90 μg/L (LS-3). A GAC water treatment system was installed at LS-6 shortly after the results of the initial round of sampling. The second round collected on August 30, 2001 reported that slightly lower levels of PCE ranging from 0.16 μg/L (RFR-12) to 5.70 μg/L (LS-6) were present in all wells sampled. TCE concentrations between 0.57 μg/L (LS-6) and 1.20 μg/L (LS‑3) were present in only two off-post wells. These concentrations are not yet validated or verified. No acetone was detected in any of the samples, indicating that drilling foam has not impacted the aquifer. Results from the final sampling round on September 27, 2001 were not available for review by the end of Quarter 10. Attachment 2 presents summary figures with the respective concentrations of contaminants detected during the first two rounds of sampling.
The CS-10 pumping test maintained 80 gallons per minute (gpm) with 71 feet of drawdown. Ten feet of drawdown were observed at CS-9 located approximately 700 feet southwest of the pumping well. Less than 2 feet of drawdown were observed in CS-11 located approximately 750 feet northwest of the pumping well. During data analysis, it was noted that the apparent drawdown at CS-11 was more directly related to regional decline of the aquifer rather than by pumping effects. At CS-10, the transmissivity was calculated as 2,400 gallons per day per foot (gpd/ft), with a storativity of 0.00048, and a specific capacity of 1.13 gallons per foot (gal/ft).
The CS-16 pumping test maintained 45 gpm with 68 feet of drawdown. Twelve feet of drawdown were observed at CS-D located approximately 350 feet west of the pumping well. At CS-16, the transmissivity was calculated as 1,600 gpd/ft, with a storativity of 0.00007, and a specific capacity of 0.71gal/ft. Drawdown was not documented in any of the other observation wells surrounding Well CS-16.
SWMUs and AOCs
No RFI data or other investigation activities were completed at AOC 65 and AOC 67 during Quarter 10.
Summary of Changes
Fifteen new monitoring wells were being installed to evaluate groundwater conditions in the Middle Trinity Aquifer at CSSA. 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 October 31, 2001, 15 wells were completed: eight Glen Rose completions (CS-MW9-LGR, CS-MW3-LGR, CS-MW4-LGR, CS-MW5-LGR, CS-MW6-LGR, CS-MW7-LGR, CS-MW8-LGR, and CS-MW10-LGR), five Cow Creek completions (CS‑MW6‑CC, CS-MW7-CC, CS-MW8-CC, CS-MW9-CC, and CS‑MW10‑CC), and two Bexar Shale completions (CS-MW6-BS and CS-MW9-BS).
Summary of Contacts
Throughout Quarter 10, owners of off-post wells LS-1 through LS-7 were contacted to gain permission to sample their wells 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 was underway. Additionally, Bexar Metropolitan Water District, the owner of wells LS-1 through LS-4, cooperated during the drilling process to monitor potential changes in groundwater during the drilling process.
Summary of Problems
Continued slow submittal and approval of the large number of analytical data packages has hindered progress on completion of closure/investigation reports. There are numerous laboratories, chemists, and analytical methods involved. Through October 31, 2001, approximately 124 data packages were submitted and waiting for AFCEE comments/approvals.
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.
Projected Work for the Next Quarter
Data from the pumping tests will be evaluated, and a letter report documenting results of the tests will be issued. Data from the recently completed drilling program will be incorporated into a technical report during Quarter 11. Data from the drilling and pumping tests will also be used in the development of a Conceptual Site Model (CSM), to begin during Quarter 11.
Preparations for the second phase of well drilling will begin during Quarter 11. Drilling is expected to commence before January 2002. Preparation of the CSSA Background Report will continue during Quarter 11.
Under AETC DO5084, comments were received during Quarter 10 from AFCEE and CSSA on the Draft Technical Report for the Soil Gas Survey. The response to comments and revised report will be prepared during the next quarter. The draft RFI report for AOC 65 and AOC 67 will be submitted to AFCEE and CSSA for review during the next quarter. In addition, work will continue on the 19 remaining RFI reports.
Copies of Daily Reports, Inspection Reports, Data, etc.
Data relating to well cluster installations, off-post well sampling, and well pumping tests will be submitted in the future following verification and additional evaluation.
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 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.
This task makes up approximately 15 percent of the RFI phase. The amount of effort needed to accomplish this task is not yet known because analytical data have not yet been fully evaluated. The percent complete depends on the number of sites requiring risk assessment.
Task V - Investigation Analysis
Task Description
This task includes preparation of an Investigation Analysis to support the selection of protection standards for CSSA. For sites closing under the State of Texas Risk Reduction Standards, this analysis will be included as part of the RFI Report. For sites closing to a risk-based standard, the analysis will be submitted along with the Risk Assessment Report. 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. Site by site decisions 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 last year was continued as described previously in RFI Task III.
Percent Complete
This task makes up approximately 10 percent of the RFI phase, and is approximately 53 percent complete.
Summary of Findings
As described in Task III, a total of 22 draft RFI reports have been completed. As part of preparation of these reports, investigation results were compared to closure criteria. A summary of recommendations is provided in Attachment 1. Comparisons for 19 other sites are currently underway.
Summary of Changes
No changes associated with the Investigative Analysis were made during this reporting period.
Summary of Contacts
No contacts related to the Investigative Analysis were made during this reporting period.
Summary of Problems
No problems related to the Investigative Analysis occurred during this reporting period.
Actions Taken to Correct Problems
No actions to correct problems were necessary during this reporting period.
Projected Work for the Next Quarter
Continued work on comparison of investigation results to closure criteria will be performed.
Copies of Daily Reports, Inspection Reports, Data, etc.
No daily reports, inspection reports, or data related to investigation analysis/risk assessment were generated during this reporting period.
Task VI - Treatability Studies
Task Description
This task may include a Treatability Study Program, if so directed by the 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 10. O&M activities on the PIMS study site included leachate monitoring efforts and test cell sump maintenance activities. 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. The stockpiled soils were covered with approximately one foot of topsoil, and samples were collected for TCLP lead analysis. The stockpiled soils at SWMU B-20 will be compared to the planned treatability study efforts at the test cell. Data are expected to be received during the next quarter. Approximately 10 cubic yards of untreated soil remain at SWMU B-20 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. Data from this resampling event were approved during Quarter 10, and were incorporated into the draft final SVE Test Report for SWMU B-3. This revised report was submitted to CSSA and AFCEE for additional review during Quarter 10. Preparation of the draft SVE O&M Assessment Report for O&M testing completed in Quarter 8 was also continued during Quarter 10. The draft Operations and Maintenance Assessment Report for the entire year of testing will be completed upon AFCEE approval of the data packages. The treatability test system is continuing to be operated and periodically maintained at SWMU B-3, but no additional testing has been performed.
Treatability testing of potential treatment technologies was funded under AFCEE 3P‑AE TO 0058 for contaminated material underlying Building 90 (AOC 65) and evaluation of alternative corrective measures and treatability studies.
Percent Complete
This task makes up approximately 10 percent 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.
Summary of Findings
Analytical data received the PIMS treatability study monitoring efforts in August. The results will be reported in the Soil Pile Disposition Report, the draft of which will be submitted in Quarter 11.
No additional testing data were received from the SVE system continuing to be operated at SWMU B-3 during Quarter 10.
Summary of Changes
No changes associated with the treatability studies occurred 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 O&M activities at the SWMU B-3 treatability study occurred during this reporting period. The PIMS treatability study test cell sump failed to operate correctly due to microbial growth which congested leachate flow into the sump.
Actions Taken to Correct Problems
The PIMS study test cell sump was removed and additional drainage material added to promote sufficient leachate recovery.
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 Quarter 11.
Monitoring of the PIMS treatability study is expected to continue during Quarter 11. Additionally, field scale treatability studies of soil density separation followed by phytoextraction for the previously sifted soil piles as part of the IM activities are also expected to be initiated during Quarter 11.
CSSA and AFCEE are in the process of developing a Scope of Work that will include excavation and disposal of contaminated soil and other waste debris located at SWMU B-3. CSSA and AFCEE are also conducting preliminary discussions of a Scope of Work to implement an Environmental Management System.
Under a new task order (TO-0058) issued on September 17, 2001, under AFCEE 3P‑AE Contract F41624-00-8024, Parsons will prepare plans for treatability testing for cleanup of subsurface contamination in and around Building 90 (AOC 65) during Quarter 11. The current tasks include performance of surface geophysical testing to characterize and possibly identify fractures in the near surface formation (upper 50-100 feet) around Building 90 and to the southwest to identify appropriate locations for extraction wells, test wells, and multi-depth monitoring points. Sub-slab soil vapor extraction and shallow pump and treat technologies are currently being evaluated as possible treatment alternatives as part of the TO-0058. Additional treatment alternatives will be researched, and those technologies that may be effective will be included in the study for further evaluation.
Copies of Daily Reports, Inspection Reports, Data, etc.
No analytical data is submitted 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 (June 2001 - October 2002) are funded under DO5084 of the AETC contract.
Percent Complete
This task makes up approximately 5 percent of the RFI phase. The percent complete is unknown because the number of treatability studies necessary is currently unknown; however, it is estimated to be approximately 8 percent.
Summary of Findings
No findings associated with the progress reports were made during this reporting period.
Summary of Changes
No changes associated with the progress reports occurred 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 occurred during this reporting period.
Actions Taken to Correct Problems
No actions to correct problems were necessary during this reporting period.
Projected Work for the Next Quarter
The Progress Report for Quarter 11 will be submitted.
Copies of Daily Reports, Inspection Reports, Data, etc.
No daily reports, inspection reports, or data related to the Progress Reports were generated during this reporting period.