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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 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), Human Health and Ecological Risk Assessment (15 percent), Investigation Analysis (10 percent), Treatability Studies (10 percent), and Progress Reports (5 percent). As of the end of Quarter 12, the RFI is approximately 41 percent complete.
Task I - Preliminary Report: Description of Current Conditions
Task Description
This task includes preparation of the 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. 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 planned RFI tasks.
Activities this Quarter
Draft work plan addenda’s for the new TO 0042 task order were prepared and submitted during Quarter 11 for CSSA and AFCEE review. The addenda included a Work Plan, Sampling and Analysis Plan, and Health and Safety Plan to address upcoming field activities associated with the continued installation of groundwater wells and quarterly groundwater monitoring. The CSSA DQO document affecting both TO 0042 and TO 0058 continued to be drafted during Quarter 12. Changes to the DQOs impact the approach and methodology of the SOW under TO 0042. The results of the DQO process will need to be reflected in the Final version of the work plans. Final work plans under TO 0042 will be submitted in Quarter 13. During Quarter 12, CSSA revisions to the project DQOs resulted in changes to the TO 0042 SOW. The revised TO 0042 SOW is:
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Installation of nine monitoring wells forming Middle Trinity aquifer clusters at five locations, including one off-post location. |
Draft work plans for the TO 0058 task order were prepared and submitted for CSSA and AFCEE review during Quarter 12. The draft plans submitted include the Environmental Cleanup Plan which presents a summary of the treatability study and removal actions to be undertaken at AOC-65, and the AOC-65 Treatability Test Plan which presents detailed information regarding the Soil Vapor Extraction treatability tests to be implemented. Comments were received from AFCEE and CSSA, and a general technical approach described in the plans was presented to EPA and TNRCC on March 5, 2002. Upon receipt of concurrence on all changes, these plans were revised and submitted as final documents. The draft HSP and SAP addenda associated with the Task Order TO 0058 activities described in the Environmental Cleanup Plan were submitted during Quarter 12 to AFCEE and CSSA for review.
Discussions were held with Foster Wheeler and Kevric regarding interim measures and closure of the land based position of the SWMU B-3 disposal trenches. Work at this site is anticipated to begin in 2002, but no plans were initiated in Quarter 12 contract negotiations and discussions.
Under AETC DO 5084, Final Plan addenda (revision 2) were submitted to AFCEE and CSSA and incorporated during Quarter 12 into the Environmental Encyclopedia located in Volume 1-1.2, Work Plans, behind the DO 5084 Addendum tab.
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 12, work currently under scope is approximately 99 percent complete. The remaining 1 percent of this task is associated with the TO 0042 well installation and sampling, 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
Several meetings were conducted during Quarter 12 under TO 0042 and TO 0058. Meetings conducted under TO 0058 included TIM #2 conducted on February 21, 2002. Parsons personnel, the CSSA Environmental Officer and the WPI representative attended. The meeting covered results from the geophysical testing conducted through January 2002 and plans for implementation of the treatability and removal action activities. Discussion also covered the planned presentation and topics for the Regulatory Communication Meeting held March 5, 2002. The purpose of the meeting with regulators was to present a summary of the task order activities planned to the TNRCC and EPA and to obtain concurrence with the technical approach. Appropriate handling of anticipated IDW from both TO 0042 and TO 0058 activities was also discussed.
TIM #2 for TO 0042 was held on March 20-22, 2002. The Environmental Officer from CSSA and Informatics personnel attended. Parsons was represented by the TO 0042 Task Manager and other project team members involved in TO 0042. This meeting was held to discuss the decisions reached in the March 5, 2002, meeting regarding the IDW plan and management of drilling materials for scheduled CSSA work and the draft DQOs needed under TO 0042 and TO 0058. Final meeting minutes were submitted April 12, 2002. DQOs to be utilized for the CSSA project overall were also discussed during the meeting. Upon finalizing the draft DQOs based on comments discussed during the meeting, the DQOs were mailed on April 22, 2002, to EPA and TNRCC for regulatory approval, with the goal of implementing the DQOs for the June 2002 groundwater monitoring event.
A meeting was held with Parsons, CSSA, and TNRCC during Quarter 11, to discuss a revised approach to evaluation of CSSA’s background metals levels and the appropriate statistical methods. It was agreed at the meeting that Parsons would submit a revised background metals evaluation based on the one soil type approach for TNRCC review. This report was submitted to the TNRCC in Quarter 12 and is included in Volume 2, Background Metals Levels, Second Revision Evaluation of Background Metals Concentrations in Soils and Bedrock at Camp Stanley Storage Activity (February 2002). CSSA is currently awaiting the TNRCC’s response to the submitted report. Additional detail on the background metals levels meeting is provided in Task III, Activities this Quarter, SWMUs and AOCs, below. RFI report revisions based on revised background metals levels are discussed and summarized below in Task III, Facility Investigation and outlined in Attachment 2, Summary of SWMU/AOC Status.
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
With the close of Quarter 12, all plans and plan addenda are complete.
Copies of Daily Reports, Inspection Reports, Data, etc.
Preliminary groundwater data for the March 2002 sampling event (on-post and off-post) has been received by Parsons. The data packages for TO 0042 #1 through #3, RL83 #64 and DO5084 #24, #25, and #26 are currently being validated by Parsons, and the Data Validation Reports will be submitted in Quarter 13.
Task III - Facility Investigation
Task Description
An investigation of the facility is being conducted to:
Characterize the environmental setting of the facility;
Define the source(s) of contamination;
Define the nature and extent of contamination; and
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 and B-71, is funded, and investigation of all AOCs, except AOCs 44-46, 49, 51-55, 59, 60, 62-64, 67-70, and 72-73 is funded.
RFI work conducted during Quarter 12 included collection and analyses of groundwater samples from on- and off-post wells, electronic resistivity, and seismic geophysical surveys related to AOC-65, operation and maintenance of five previously installed off-post GAC filtration systems, and preparation of summary reports for various field investigation activities.
Sampling of 20 off-post wells for four quarters (VOCs only) is funded under AETC DO5084 through the June 2002 sampling event. This task was originally funded for six 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. Funding for off-post groundwater monitoring will be under TO 0042 beginning in September 2002 and will be funded through September 2003. On-post groundwater monitoring performed in March 2002 and continuing through March 2003 is funded under TO 0042.
Implementation of interim removal actions of contaminated material underlying Building 90 (AOC-65) was funded in Quarter 10 with an evaluation of alternative corrective measures and treatability studies (Task VI) under TO 0058. A modification (Mod 02) to TO 0058 was executed during Quarter 12 to fund expansion of the removal actions, increased geophysical testing and greatly increased the scope of the treatability testing activities through September 2003.
Activities this Quarter
Off-post groundwater sampling was performed the week of March 18, 2002. Twenty-four off-post wells were sampled and four post-GAC samples were collected. Private and public off-post wells sampled in March 2002 include DOM-2, FO-17, FO-8, FO-J1, HS-2, I10-2, I10-4, JW-9, JW-14, JW-26, LS-1, LS‑2, LS-3, LS-4, LS-5, LS-6, LS-7, RFR-10, RFR-11, RFR-12, OFR-1, OFR-2, OFR-3, and I10-7. This was the first sampling event for off-post wells FO-8, FO-17, I10-7, and JW-26 and the first sampling event since 1995 for OFR-2. The locations of these wells are shown on Figure 3.1 in Attachment 3. Samples were analyzed by APPL and preliminary data were received by Parsons on April 10, 2002. Analytical results remain unvalidated at the end of Quarter 12.
During Quarters 11 and 12, CSSA and the U.S. Army Corps of Engineers, Fort Worth District completed design work for installation of a GAC filtration system for two municipal supply water wells (LS-2 and LS-3) located adjacent to CSSA. The GAC filtration system was installed the week of April 1, 2002. Post GAC samples collected April 11, 2002, confirmed that the GAC system is removing VOCs from the groundwater.
Additional sampling of selected off-post drinking water wells with elevated VOC levels occurred during Quarter 12. Some of the wells sampled in the quarterly event are also sampled on a monthly basis for off-post groundwater monitoring. Wells sampled on a monthly schedule included LS-2, LS-3 and OFR-3 in February 2002 and only OFR-3 in April 2002. GAC systems have been installed at these wells and monthly sampling will be discontinued. These well locations are shown on Figure 3.1 in Attachment 3. In addition, a CSSA representative performed monthly operation and maintenance on the five-micron pre-and post-filters at the existing residential GAC treatment systems. This filter exchange maintenance is scheduled to be performed monthly on the wells with GAC filtration systems installed, specifically wells LS-6, LS-7, RFR-10, RFR-11, and OFR-3.
CSSA continued confirmation sampling of private well owners’ GAC wellhead treatment systems during Quarter 12. Sampling was conducted during the quarterly off-post sampling event in March 2002 to confirm that GAC treatment systems are working effectively. Preliminary results from the March 2002 event indicated no VOCs were detected in the post GAC water samples collected from wells LS-6, LS-7, RFR-10, and RFR-11. Validation of these results will be completed in Quarter 13.
Karst survey work was initiated at CSSA on April 11, 2002. The survey team will identify suspected karst features on-post. Additionally, approximately 200 acres will be surveyed to the west of CSSA. The karst features may include sinkholes, open fractures, and springs. An indepth review of the suspect areas will be investigated by Dr. Geroge Veni to determine if the site is worthy of additional investigations.
CSSA prepared Fact Sheet #6 in March 2002 to present results of the December 2001 off-post sampling event to the public. This fact sheet was mailed to the public on April 17, 2002 after receiving content approval from the U.S. Army and when final analytical data validation approval was received from AFCEE. The Data Validation Reports for the applicable December 2001 data have been approved by AFCEE. The distribution list for the mailout was updated in Quarter 12 and the list contained 2,695 addresses. Additional distribution to approximately 800 residents in the Dominion subdivision was coordinated through their homeowners association.
Parsons submitted a proposed list of interviewees and an updated set of interview questions to CSSA. Comments were received and incorporated and the questionnaire was approved. Telephone interviews of selected residents near CSSA were initiated in Quarter 12. The remaining interviews will be conducted and preparation of the Community Relations Plan update will begin in Quarter 13.
Quarterly groundwater monitoring of the on-post wells was performed the week of March 11, 2002. CSSA wells CS-1, CS-2, CS-9, CS-10, CS-11, CS-16, CS-D, CS-G, CS-H, CS-I, CS-MW1-LGR, CS-MW2-LGR, CS-MW3-LGR, CS-MW4-LGR, CS-MW5-LGR, CS-MW6-CC, CS-MW6-BS, CS-MW6-LGR, CS-MW7-CC, CS-MW7-LGR, CS-MW8-CC, CS-MW8-LGR, CS-MW9-CC, CS-MW9-BS, CS-MW9-LGR, CS-MW10-LGR, and CS-MW10-CC were sampled. Locations of the on-post wells sampled are shown on Figure 3.2 in Attachment 3. Samples were analyzed by STL with preliminary data received by Parsons on April 3 to 15, 2002. Analytical results remained unvalidated at the end of Quarter 12. The draft on-post quarterly groundwater monitoring report for December 2001 was submitted to CSSA and AFCEE for review during Quarter 12. Comments were received from CSSA and incorporated in the draft report. No comments were received from AFCEE in Quarter 12. Parsons will prepare the draft on-post quarterly groundwater monitoring report for March 2002 and submit the draft in Quarter 13 for CSSA and AFCEE review.
Preparations for fieldwork to be conducted under TO 0042 continued in Quarter 12. A drilling subcontract was awarded to Geoprojects, Inc. Procurement activities related to the management of IDW generated during drilling activities planned under TO 0042 also continued in Quarter 12. IDW issues included TNRCC concerns regarding the discharge of groundwater and cuttings generated during drilling operations. Parsons supported CSSA during negotiations with the TNRCC on this issue, including preparation of correspondence to the EPA and TNRCC regulators regarding the implementation of settling basins for containment of water and cuttings from drilling activities. A detailed draft plan/methodology for handling IDW was submitted to regulators on March 25, 2002. These issues continue to delay commencement of well installation fieldwork under TO 0042.
Preparations for field work were also initiated in early April upon award of Mod 02 to TO 0058. The Environmental Cleanup Plan and Treatability Test Plan were revised to incorporate CSSA and AFCEE comments and were issued as final in Quarter 12. Preparation of the draft SAP and HSP Addenda was also completed prior to initiating fieldwork and submitted to CSSA and AFCEE for comment. Geoprojects was awarded the drilling subcontract for installation of characterization borings and SVE wells inside Building 90 and in the paved area/ditches to the west of Building 90. GeoProjects will also install six piezometers, six VEWs, and six VMPs for the treatability study as described in the AFCEE/CSSA approved Treatability Test Plan. Analytical laboratories and geophysical equipment leases were also procured to support the activities planned under TO 0058. A seismic survey was conducted starting on April 15, 2002, and soil characterization sampling inside and around Building 90 was initiated on April 19, 2002. This drilling effort was performed during the weekend hours to prevent interruption of mission operations inside Building 90. Installation of a subslab ventilation system in Building 90 was initiated on April 26-28, 2002.
Data packages related to quarterly groundwater monitoring activities consist of groundwater monitoring conducted on- and off-post during Quarter 12 (the March 2002 quarterly sampling event). Verification of data packages continued during Quarter 12. AFCEE chemists approved six groundwater data packages during Quarter 12 (from February 1, 2002 through April 30, 2002). Parsons submitted 12 additional data packages during this Quarter. Through April 2002, approximately 24 groundwater data packages (of a total 206 data packages) were submitted and 17 data packages had been approved by AFCEE. The remaining 182 RFI data packages (of a total 206 data packages) relate to site-specific sampling and are discussed below. AFCEE/Informatics provided comments on two data packages, and Parsons will respond to these comments. Parsons is waiting for AFCEE comments/approvals on six groundwater data packages.
There are 182 data packages related to RFIs for site-specific soil and groundwater sampling conducted at various SWMUs and AOCs. Verification of additional RFI data packages was continued during Quarter 12. AFCEE chemists approved 35 data packages during Quarter 12. Parsons submitted three additional RFI data packages during this quarter. Through April 2002, approximately 182 RFI data packages (from a total 206 data packages) were submitted and 156 RFI data packages were approved by AFCEE. The remaining 24 data packages of the total 206 relate to quarterly groundwater sampling and are discussed above. AFCEE/Informatics/Portage provided comments on eight RFI data packages and Parsons’ comments are pending. Parsons is awaiting AFCEE comments/approvals on eight RFI data packages.
A laboratory audit of APPL, Inc. was conducted under AETC DO 5084 from February 25 to 28, 2002. The audit was conducted by Tammy Chang, Parsons Senior Chemist, Brian Murphy, Environmental Officer from CSSA, and Edward Brown, Environmental Consultant representing AFCEE/ERC. Areas of minor concern were identified during the audit. The specific items were communicated to APPL in the Laboratory Audit Report forwarded March 13, 2002. APPL submitted their response to AFCEE on April 12, 2002, for review.
Currently, the installation of 32 monitoring wells is funded. Fifteen of these wells have been completed. TO 0042 funds the installation of 17 new monitoring wells, 10 wells completed in the Lower Glen Rose, two wells in the Bexar Shale, and five wells in the Cow Creek. In addition, five well upgrades will also be completed (CS-16, CS-G, CS-H, CS-MW-1-LGR, and CS-MW-2-LGR).
Preparation of RFI/Closure Reports for CSSA SWMUs and AOCs continued during Quarter 12. A total of 47 reports are being prepared. To date, 38 draft reports have been completed. Parsons continued preparation of draft reports for SWMUs B-9, B-10, I-1; Building 43; and AOCs 35, 42, 43, and 50 during Quarter 12. In addition, responses to AFCEE and CSSA comments on draft reports were prepared. Sites that meet RRS1 closure requirements will be certified by a registered professional engineer. A summary of the status of each site is provided in Attachment 2.
On January 10, 2002, CSSA and Parsons met with TNRCC to discuss revisions to the CSSA Background Metals Evaluation. Revisions to this report included replacement of data generated by ITS Laboratory and combining data from eight soil types (as defined by the U.S. Department of Agriculture) into one group of data for the purposes of the statistical evaluation. The revised background report was submitted to TNRCC and EPA on February 11, 2002. On April 8, 2002, TNRCC gave verbal approval of the revised report. Written approval is anticipated during Quarter 13.
Work continued on RFI/Closure reports for AOC-65 and AOC-67, near Building 90, during Quarter 12. The AOC-67 RFI Report was submitted for AFCEE and CSSA review in December 2001, and comments received from CSSA on January 10, 2002. AFCEE comments were received on February 28, 2002. The final AOC-67 RFI was revised to incorporate AFCEE and CSSA comments as appropriate and submitted to CSSA and AFCEE in Quarter 12. The final AOC-67 RFI report will be incorporated into the Environmental Encyclopedia in the next quarter. The draft AOC-65 RFI was revised prior to submittal to reflect the changes necessitated by CSSA comments on the draft AOC-67 report. This report was submitted on February 28, 2002 to AFCEE/CSSA for review.
Between November 2001 and January 2002, geophysical surveys were conducted at the AOC-65/Building 90 site to identify faults, fractures, and dissolution features in the bedrock that may be controlling migration of contaminants in the area. The geophysical methods utilized include electrical resistivity imaging, microgravity, and very low frequency electromagnetics. Preliminary results from the electrical resistivity imaging data have identified several potential anomalies for further characterization. In a meeting with CSSA in February 2002, plans were made for additional geophysical testing to be initiated in Quarter 12 and completed during Quarter 13. The additional geophysical tests will include 2-D seismic reflection surveys, 3-D seismic surveys, and additional 2-D resistivity imaging surveys. The 2-D seismic reflection surveys started April 15, 2002 and concluded on April 22, 2002. The data will be evaluated for determinations to perform additional 2-D and/or 3-D testing.
Contractor procurement and technical planning activities associated with the removal action and treatability study at AOC-65 (under TO 0058) will be continued during Quarter 13. These duties include preparation of the final SAP and HSP and detailed statements of work for soliciting proposals for the planned treatability studies and removal/restoration activities. Performance of surface geophysical testing activities will also be continued during the next quarter near Building 90 and throughout the southwest portion of the post. Removal actions and installation of treatability test wells under TO 0058 is planned during Quarter 13. A memorandum was prepared and mailed to the TNRCC and EPA on April 22, 2002 regarding “F” listing of materials generated from soil borings and groundwater investigations at AOC-65. CSSA is awaiting a response from the regulatory agencies.
CSSA is planning an upgrade at RMU-1, our current active firing range, to remove the current backstop and replace it with a state-of-the-art bullet trap device. As part of this upgrade, some soil associated with the backstop may have to be removed. On April 15, 2002, five grab samples were collected from the surface soil from the backstop area. All samples were submitted for TCLP analyses for the 11 RCRA metals. This analyses found elevated levels of lead, antimony, and barium. Lead levels ranged from 8.93 to 95 mg/L, antimony from 0.129 to 3.78 mg/L, and barium from 1.0 to 1.8 mg/L. Based on these findings, the surface soil from the backstop area may be characterized as hazardous waste when excavated and have to be managed accordingly if removed for the project. Plans for soil removal and bullet trap installation may be undertaken during Quarter 13.
Percent Complete
This task makes up approximately 45 percent of the RFI phase. As of the end of Quarter 12, this task is approximately 26 percent complete.
Summary of Findings
Quarterly groundwater monitoring of the on-post and off-post wells was performed at CSSA during the period March 11 to 22, 2002. A revised map of the well locations is provided in Figure 3.1 and Figure 3.2 of Attachment 3 of this report. These figures include monitoring well installations completed through the end of Quarter 12.
On-post Wells, March 2002: Twenty-seven on-post drinking water and monitoring wells were sampled March 11-15, 2002. Samples were collected at wells CS-1, CS-2, CS-9, CS-10, CS-11, CS-16, CS-D, CS-G, CS-H, CS-I, CS-MW1-LGR, CS-MW2-LGR, CS-MW3-LGR, CS-MW4-LGR, CS-MW5-LGR, CS-MW6-CC, CS-MW6-BS, CS-MW6-LGR, CS-MW7-CC, CS-MW7-LGR, CS-MW8-CC, CS-MW8-LGR, CS-MW9-CC, CS-MW9-BS, CS-MW9-LGR, CS-MW10-LGR, and CS-MW10-CC were sampled during the March 2002 sampling event. Drinking water well samples were analyzed by APPL and monitoring well samples were analyzed by STL. Results of the March 2002 groundwater monitoring event will be formally reported in a draft March 2002 Quarterly Groundwater Monitoring Report that will be submitted to CSSA and AFCEE during Quarter 13 for review and comments. Locations of the on-post wells sampled are provided on Figure 3.2 in Attachment 3.
Off-post Wells, February to April 2002: Twenty-four off-post groundwater wells were sampled March 18 to 21, 2002. Samples were collected at wells DOM-2, FO-17, FO-8, FO-J1, HS-2, I10-2, I10-4, I10-7, JW-9, JW-14, JW-26, LS-1, LS-2, LS-3, LS-4, LS-5, LS-6, LS-7, RFR-10, RFR-11, RFR-12, OFR-1, OFR-2, and OFR-3. OFR-3, LS-2 and LS-3 were also sampled in February 2002. All samples were analyzed by APPL. Results of the off-post groundwater monitoring will be formally reported in a draft March 2002 Quarterly Groundwater Monitoring Report to be submitted to CSSA and AFCEE during Quarter 13. Laboratory results for the Quarter 12 sampling events are currently being verified and validated. Locations of the off-post wells sampled are provided on Figure 3.1 in Attachment 3.
Laboratory Audit: As reported previously, an audit of APPL, Inc. was conducted under RL83 from February 25 to 28, 2002. The audit report was sent to the laboratory on March 13, 2002. Response and comments from the laboratory were received April 13, 2002, and are being reviewed.
AOC-65: Data from soil borings drilled as part of the investigation effort at AOC-65 will not be received until Quarter 13. Seismic survey results were submitted for processing to a shallow seismic reflective survey firm. Findings from processing of the seismic data will be made available in early May 2002 to assist with location selections for VEWs and piezometers, as well as some wells planned under TO 0042.
Summary of Changes
No changes to the RFI were made during the reporting period.
Summary of Contacts
On March 26, 2002, the TNRCC conducted a Compliance Evaluation Inspection (CEI) at the CSSA facility. CSSA is awaiting a written report for issues raised during the CEI which included:
Updating selected waste codes listed in the CSSA NOR;
Modifying the NOR to reflect addition of new waste codes added since the previous CEI; and
Potential “F” listing of cuttings and drilling water generated during well installation operations.
Issues from the previous CEI (July 2001) were also discussed. These issues included:
Notifying the laundry service of the various chemicals that may come in contact with “red rags” used at various locations around CSSA;
TNRCC’s concerns regarding swipe versus chip samples for closure confirmation at the Building 40 site; and
HAZWOPER training for the CSSA Environmental Officer.
On April 16, 2002 the TNRCC conducted an inspection of the CSSA drinking water system. The inspection resulted in two violations:
Repairs to the fencing around the water reservoir due to vines and the barb-wire around the top of the fence needs to be tightened; and
Securing a hatch on top of the water reservoir which was removed allowing the possibility of wind-blown contaminants to entering the reservoir.
CSSA is addressing the deficiencies noted by the TNRCC and will provide the necessary documentation to them when the issues are rectified.
Through Quarter 12, discussions were held between CSSA, EPA, and TNRCC regarding the waste determination of groundwater withdrawn from CSSA wells. It was the TNRCC’s contention that CSSA’s groundwater is a contaminated water that requires a permitted discharge, whereas the EPA and CSSA maintained the groundwater is “media” that is suitable for discharge at levels below MCLs. On March 5, 2002, the TNRCC issued a letter supporting the definition of “contaminated media” given by CSSA, and that groundwater with contaminant levels below the MCL may be discharged to the ground. However, this discharge may not affect the water quality of any “waters of the state,” including pH, turbidity, and sediment loading (total suspended solids). Negotiations are continuing regarding the appropriate management of groundwater from CSSA wells. CSSA would like to manage the generated groundwater media within settling basins. Under this management method a lined settling basin would be constructed to allow input of generated groundwater during the Phase II drilling activities. The settling basins would be tested periodically to determine if the waters meet the criteria for discharge (i.e., the turbidity is lowered to an acceptable level and contaminant specific compounds are not above MCLs). CSSA/Parsons anticipates only a minimum of generated groundwater will be above the MCLs. It is proposed that the contaminated groundwater will be managed in roll-off containers, treated through the CSSA GAC system and discharged through their TPDES outfall. However, a large majority of the anticipated groundwater generated will be below MCLs and as such, ultimate discharge of the groundwater to the ground surface is planned. The TNRCC has yet to comment on CSSA’s plan for managing groundwater media. Until the situation is satisfactorily resolved, CSSA cannot proceed with planned Phase II drilling activities under TO 0042. However, it is anticipated that scope changes resulting from project DQO review, including a reduction in the number of wells requiring double and triple casing will significantly decrease the volume of the IDW generated. Significantly less waste is anticipated during drilling planned under TO 0058, such that drilling activities may be initiated prior to resolution of waste determination for drilling cuttings and well water.
Other contacts related to Facility Investigations included routine contacts with off-post private well owners to obtain access for sampling in March 2002. Four wells were sampled for the first time in the March event, including FO-8, FO-17, I10-7, and JW-26, which required negotiations for well access agreements with the well owners.
The CSSA Environmental Officer traveled to Pacific Environmental Services in Research Triangle Park, NC to discuss QA/QC of the environmental encyclopedia website data. CSSA and Pacific Environmental are planning to have the website operational during Quarter 13.
Summary of Problems
AFCEE approved 41 data packages during Quarter 12. Cumulatively, 172 data packages have been approved through the end of Quarter 12. Approximately 14 data packages were submitted and pending AFCEE comment/approval.
Initiation of well installation work under TO 0042 will be delayed in order to confirm procedures due to recent waste management issues raised by TNRCC regarding IDW management. The status of the TO 0058 activities will be evaluated prior to initiating any drilling activities.
Actions Taken to Correct Problems
CSSA’s Environmental Officer met with the project chemists and requested they approve data packages that have been under review for more than three months or prepare comments in the form of a memorandum for submittal to Parsons for assessment and correction, if appropriate.
CSSA and Parsons are currently weighing the costs, benefits, advantages, and disadvantages of the potential alternatives under consideration for management of drilling water and cuttings generated during future well installations.
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 13. Data from the drilling and pumping tests will also be used in the development of a Conceptual Site Model (CSM), to begin during Quarter 13.
Preparations for the second phase of well drilling will continue during Quarter 13. Drilling is expected to commence before June 2002.
The next quarterly groundwater monitoring event will be conducted in June 2002. This upcoming event will include the existing CSSA wells that are typically sampled, approximately 25 off-post wells (VOCs only), as well as newly completed and developed on-post monitoring wells. On-post quarterly sampling will be funded under TO 0042 in June 2002. Off-post quarterly and monthly sampling will be funded under both DO5084 and RL83 through September 2002. Additional off-post well sampling may be performed at selected wells to verify results from the quarterly sampling event, to test the wells prior to installation of the existing or any newly installed GAC treatment units, and to collect post-GAC water samples.
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 develop a needs and assessment for an Environmental Management System.
Operations and maintenance at the residential GAC filtration systems (LS-6, LS-7, RFR-10, and RFR-11) and on private water supply systems (LS-2/LS-3) will be conducted in Quarter 13.
Additional investigations at AOC-65 will be conducted in Quarter 13. Work will include karst surveys and other geophysical testing.
Work will continue in Quarter 13 on the 19 remaining RFI reports. RFI/Closure Reports will be submitted to the TNRCC once approval of the revised background numbers is received.
Copies of Daily Reports, Inspection Reports, Data, etc.
Reports summarizing the most recent groundwater findings are submitted to present the results from quarterly groundwater sampling events (on-post and off-post). The quarterly groundwater monitoring reports present the groundwater elevations recorded (on-post wells only) and the analytical results received for each well (on-post and off-post). The groundwater elevations are presented in the On-post Quarterly Groundwater Monitoring Reports on a potentiometric surface map and in tabular format. Analytical results from the most recent sampling events are compared to levels from the previous quarters, while comprehensive historical analytical results can be found in tables which are revised quarterly, presented in the Introduction to the Quarterly Groundwater Monitoring Program, Volume 5, Groundwater. The Final September On-post Quarterly Groundwater Monitoring Report was submitted for inclusion in the Environmental Encyclopedia April 10, 2002. The Final September Off-post Quarterly Groundwater Monitoring Report was submitted for inclusion in the Environmental Encyclopedia February 28, 2002. These reports are located in Volume 5, Groundwater, behind the On-post Groundwater Monitoring and Off-post Groundwater Monitoring tabs. The Draft December 2001 On-post and Off-post Groundwater Monitoring Reports were submitted in Quarter 12. Comments were received from CSSA and changes were incorporated. No comments were received from AFCEE, so the reports were not produced for distribution as Final as in Quarter 12.
Preliminary groundwater data from the March 2002 quarterly sampling event was received April 5-12, 2002, and data review and validation was initiated for both on-post and off-post groundwater monitoring. Parsons will submit the draft March 2002 Groundwater Monitoring Reports for on-post and off-post wells in Quarter 13, and will revise the reports based on comments/responses received from CSSA and AFCEE.
The Draft Technical Report for the Soil Gas Survey prepared under AETC DO5084 was revised for submittal after the final base map was corrected to depict accurate building locations relative to sample locations. The Final Soil Gas Survey Technical Report and encyclopedia update was submitted on April 10, 2002.
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:
Contaminant identification;
Exposure assessment;
Toxicity assessment; and
Risk characterization.
For ecological risks, the effort will include the following components:
Problem formulation;
Exposure assessment;
Ecological effects assessment and
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 RRS1. 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 RRS1 closure is not applicable. Due to the 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 RRS2 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 37 percent complete.
Summary of Findings
As described in Task III, 38 draft RFI reports have been completed and submitted. As part of preparation of these reports, investigation results were compared to closure criteria. A summary of recommendations is provided in Attachment 4. Comparisons for 16 other sites are currently underway. Based on the 38 sites for which draft reports have been submitted, 16 of these sites were recommended for closure and 22 sites may require future action.
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. Problems associated with re-evaluation of the background metals levels were presented in the Quarter 11 Progress Report.
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 SVE and other treatability studies for treatment of contaminated soils at AOC-65. Data collection activities were discontinued on the SWMU B-3 SVE treatability study.
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 12. O&M activities on the PIMS study site included leachate monitoring efforts and maintenance activities. Monitoring of the field treatment efforts are expected to continue for a minimum of one calendar year. The monitoring of treated stockpiled soils at SWMU B-20 will be compared to the treatability study efforts ongoing at the demonstration project test cell located at SWMU B-10. Approximately 10 cubic yards of untreated soil remain at SWMU B-20 for use in other treatability studies. Additionally, samples were taken from the SWMU B-20 site of PIMS treated and un-treated soils for a bioassessment. The assessment followed protocols established by Dr. Mike Ruby for determining the bioavailability of compounds to humans. Results of the assessment are expected during the next reporting quarter.
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 include the PIMS treatability study monitoring efforts in February 2002. The results will be reported in the treatability study report anticipated to be completed in September 2002.
No additional testing data were received from the SVE system continuing to be operated at SWMU B-3 during Quarter 12.
Summary of Changes
No changes associated with the treatability studies occurred during this reporting period.
Summary of Contacts
Dr. Bill Blanford communicated preliminary information concerning University of Texas at San Antonio (UTSA’s) proposal for remedial efforts at AOC-65 during the November 13, 2001, TIM #1 meeting held under TO 0058. Continued revisions to the scope of work proposed by UTSA for characterization of contaminant migration near AOC-65 are ongoing and will continue in Quarter 13.
Summary of Problems
No problems related to O&M activities at the SWMU B-3 or the PIMS treatability studies 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
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 14.
Monitoring of the PIMS treatability study is expected to continue during Quarter 13. Additionally, field scale treatability studies of soil density separation followed by phytoextraction for the previously sifted soil piles as part of the treatability activities are also expected to be continued during Quarter 13.
Under a new task order (TO 0058) issued on September 17, 2001, under AFCEE 3P/AE Contract F41624-00-8024, Parsons will continue procurement of subcontractors and equipment (weather station, data recorders, etc.) for treatability testing for cleanup of subsurface contamination in and around Building 90 (AOC-65) during Quarter 13. Current tasks include performance of surface geophysical testing to characterize and possibly identify fractures in the near surface formation ( up to 150 feet bgs) around Building 90 and to the southwest to identify appropriate locations for extraction wells, test wells, and multi-depth monitoring points. Sub-slab SVE and shallow groundwater containment/in-situ treatment technologies will also be evaluated as possible treatment alternatives under TO 0058.
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 the Quarterly Progress Report preparation 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.
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 10 percent complete.
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 relating to progress reports were made during this reporting period.
Summary of Problems
No problems relating to 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 12 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.