[Home] ]

[Table of Contents] [Next Section]

13th Final Quarterly Progress Report, May 1 - July 31, 2002

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 WP (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 13, the RFI is approximately 42 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 II: RFI Work Plan

Task Description

The Order requires that the RFI WP include a Project Management Plan, Data Collection Quality Assurance Plan, Health and Safety Plan (HSP), 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 planned RFI tasks. 

Activities this Quarter

Final WP addenda for task order (TO) 0042 (Groundwater Contract) were submitted during Quarter 13. The addenda included a WP, SAP, and HSP to address upcoming field activities associated with the continued installation of groundwater wells and quarterly groundwater monitoring. The Final Site Survey Report under TO 0042 was submitted during Quarter 13. The proposed overall CSSA groundwater data quality objectives (DQOs) for TO 0042 were prepared and submitted to the EPA and TNRCC on April 22, 2002. No comments to the proposed CSSA DQOs have been received from EPA or TNRCC.

Final WPs and plan addenda for the TO 0058 (AOC-65, Building 90 Contract) were submitted during Quarter 13. The TO 0058 WPs include the Environmental Cleanup Plan and the Treatability Test Plan for AOC-65. CSSA received notice of TNRCC approval on the Treatability Test plan on July 3, 2002. The CSSA DQO document for TO 0058 scope of work was drafted during Quarter 13. Internal reviews are continuing on these DQOs. The associated HSP and SAP addenda associated with the TO 0058 activities were finalized in July 2002 for eventual inclusion in the Environmental Encyclopedia.

DQOs were drafted for Foster Wheeler Corporation’s (FWC) delivery order (F41624-00-D-8025, DO23. This DO is currently set-up to cover excavation and disposal of trenched waste material and to evaluate potential remediation options for SWMU B-3. Fieldwork was scheduled to begin during July 2002, but was temporarily postponed due to heavy rainfall on site. FWC submitted a Field Sampling Plan (FSP), HSP, and a WP addendum on July 10, 2002. 

  1. 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 13, work currently under scope is approximately 99 percent complete. The remaining work under this task is associated with the TO 0042 well installation, sampling, treatability study at AOC-65, and the CSSA Environmental Encyclopedia hypertext document, which will continually be updated as documents are added. 

  1. Summary of Findings

No new findings are associated with RFI WP preparation during this reporting period. 

  1. Summary of Changes

No changes to the RFI WP were made during the reporting period.

  1. Summary of Contacts

Parsons technical staff were in contact with FWC representatives to assist in preparation of WPs concerning excavation to be conducted at SWMU B-3. CSSA, Parsons, and FWC met with EPA and TNRCC to discuss the removal action and potential treatability studies for SWMU B-3.

Parsons submitted its Second Revised Evaluation of Background Metals Concentrations in Soils and Bedrock at CSSA to the TNRCC in Quarter 12. On April 23, 2002, TNRCC issued approval of the proposed background metals concentrations. RFI report revisions based on revised background metals levels are discussed and summarized below in Task III, Facility Investigation, and outlined in Attachment 1, Summary of SWMU/AOC Status. 

  1. Summary of Problems

During floods in 2002, AOC-55, which is adjacent to Salado Creek, was uncovered due to erosion of surface soils.

  1. Actions Taken to Correct Problems

Additional funding was requested to address the AOC-55 site. The funding was provided. CSSA will initiate contracting activities to remove the site.

  1. Projected Work for the Next Quarter

Preparation of contract documentation for AOC-55 will be initiated.

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

Preliminary groundwater data for the March 2002 sampling event (on-post and off-post) were received by Parsons in Quarter 12. The data packages for TO 0042 #1 through #3, RL83 #64 and DO5084 #24, #25, and #26 were validated by Parsons chemists, and the Data Validation Reports were submitted to Air Force Center for Environmental Excellence (AFCEE) in May 2002. AFCEE approval of the data packages was received in Quarter 13. Preliminary groundwater data for the June 2002 sampling events were received in July 2002 and data validation is ongoing. 

Task III - Facility Investigation

Task Description

An investigation of the facility is being conducted to:

  1. Characterize the environmental setting of the facility;

  2. Define the source(s) of contamination;

  3. Define the nature and extent of contamination; and

  4. 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 WP. Any deviations are documented with WP addenda. 

Completion of this task is partially funded for the planned RFI tasks. Investigation of all SWMUs, except B-71, is funded, and investigation of all AOCs, except AOCs 44-46, 49, 51-54, 59, 60, 62-64, 67-70, and 72-73 is funded. 

RFI work conducted during Quarter 13 included collection and analyses of groundwater samples from on- and off-post wells; electronic resistivity and seismic geophysical surveys related to the investigation at AOC-65 (TO 0058); removal action of contaminated surface soil, drainage ditches, and culverts as part of the AOC-65 investigation and treatability study; installation of soil vapor extraction (SVE) vapor monitoring points, vent wells and piezometers related to the AOC-65 treatability study (TO 0058); O&M of seven previously installed off-post GAC filtration systems; and preparation of draft and final reports for various field investigation activities. 

Sampling of 20 off-post wells for four quarters (VOCs only) is funded under Air Education Training Command (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 (up to 40 off-post wells) will be under TO 0042 beginning in September 2002 and will be funded through July 2003. On-post groundwater monitoring performed in March 2002 and continuing through March 2003 is funded under TO 0042. 

Activities this Quarter

Groundwater Monitoring

Off-post groundwater sampling was performed during the week of June 10, 2002. Twenty-five off-post wells were sampled. Private and public off-post wells sampled in June 2002 included FO-J1, FO-J1 Entry Point (EP), HS-2, HS-3, I10-2, I10-4, JW-6, JW-9, JW-14, LS-1, LS-2, LS-3, LS-4, LS-5, LS-6, LS-7, OFR-1, OFR-2, OFR-3, RFR-7, RFR-8, RFR-9, RFR-10, RFR-11, and RFR-12. This was the first sampling event of the entry point for the FO-J1 public water supply well, sampled prior to the holding tanks for the distribution system. The locations of these wells are shown on Figure 2.1 in Attachment 2. Samples were analyzed by APPL, and preliminary data were received by Parsons on July 3, 2002. Analytical results were unvalidated during Quarter 13 and the Data Validation Report was submitted to AFCEE July 17, 2002. 

Quarterly groundwater monitoring of the on-post wells was performed the week of June 17, 2002. CSSA wells CS-1, CS-2, CS-9, CS-10, CS-11, CS-16, CS-D, CS-G, CS-H, 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. On-post wells CS-MW1-LGR, CS-MW2-LGR, CS-MW3-LGR, and CS-I, could not be sampled due to pump malfunctions or low water levels. Locations of the on-post wells sampled are shown on Figure 2.2 in Attachment 2. Samples were analyzed by Severn Trent Laboratories (STL) with preliminary data received by Parsons July 16, 2002. Analytical results remained unvalidated at the end of Quarter 13. 

The March 2002 draft On-post and Off-post Quarterly Groundwater Monitoring Reports were submitted to CSSA and AFCEE for review during Quarter 13. Comments were received from CSSA and AFCEE and incorporated into the draft reports. The final March 2002 On-post and Off-post Quarterly Groundwater Monitoring Reports were submitted in July 2002. Parsons submitted the Final On-post and Off-post Quarterly Groundwater Monitoring Reports for December 2001 in May 2002. The draft On-post and Off-post Quarterly Groundwater Monitoring Reports for June 2002 will be submitted in Quarter 14 for CSSA and AFCEE review. 

Off-Post GAC Systems

A CSSA representative performed monthly O&M on the 5‑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. Due to the flood of July 2002, filters were checked weekly and on request from residents. Many filters were found to be dirty due to sediment being stirred up from the flood. Filter exchange maintenance is also performed for the GAC treatment system at wells LS-2 and LS-3. CSSA will continue confirmation sampling of private well owners’ GAC wellhead treatment systems during Quarter 14. Post-GAC confirmation sampling was conducted during the quarterly off-post sampling event in March 2002 and confirmed that GAC treatment systems are working effectively. The next post–GAC confirmation sampling will be conducted in September 2002. 

During the week of June 3, 2002, Parsons was asked by CSSA to evaluate complaints of pressure drops and suspended particulates at offsite GAC locations maintained by CSSA. A civil engineer evaluated the problems and made recommendations to alleviate the concerns, particularly at location LS-7. During the week of June 24, 2002 GeoProjects International (GPI) under the supervision of Parsons, replaced the pump and check valve in the well. In addition, geophysical logging and installation of a gauging tube was completed. A diaphragm pressure switch was also replaced thereby increasing household water pressure. Recommendations also included incorporation of 1 micron filtration after the GAC treatment.

Data Validation and Verification

Data packages related to quarterly groundwater monitoring activities consist of groundwater monitoring conducted on- and off-post during Quarter 13 (the June 2002 quarterly sampling event). Verification of data packages continued during Quarter 13. AFCEE chemists approved 12 groundwater data packages during Quarter 13 (from May 1, 2002, through April 30, 2002). Parsons submitted 17 additional data packages during this quarter. Through April 2002, approximately 41 groundwater data packages (of a total 227 data packages) were submitted, and 36 data packages had been approved by AFCEE. The remaining 186 RFI data packages (of 227 total data packages) relate to site-specific sampling and are discussed below. AFCEE provided comments on four data packages, and Parsons will respond to these comments during Quarter 14. Parsons is waiting for AFCEE comments/approvals on five groundwater data packages. 

There are 186 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 12 data packages during Quarter 12. Parsons submitted four additional RFI data packages during this quarter. Through April 2002, approximately 186 RFI data packages (from a total 227 data packages) were submitted and 168 RFI data packages were approved by AFCEE. The remaining 41 data packages of the total 227 relate to quarterly groundwater sampling and are discussed above. AFCEE provided comments on two RFI data packages and Parsons’ comments are pending.

Community Relations

Parsons continued telephone interviews of selected residents and public officials near CSSA in Quarter 13 to gather data for the CRP Update funded under DO5084. In addition to telephone interviews, questionnaires for selected public officials were mailed to the interviewee, to be returned by mail or facsimile. Upon completion of the interviews, the draft CRP will be submitted in Quarter 14.

RCRA Facility Investigations of SWMUs and AOCs

Preparation of RFI/Closure Reports for CSSA SWMUs and AOCs continued during Quarter 13. A total of 47 reports are being prepared. To date, 39 draft reports have been completed. Parsons continued preparation of draft reports for SWMUs B-10, I-1, and Building 43 (funded under RL53); SWMU B-9, AOCs 35, 42, and 50 (funded under DO 5068); and SWMU Bldg 40 (funded under RL74) during Quarter 13. Additional sampling was conducted at SWMU Bldg 40 under RL74 in Quarter 13. 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. AFCEE and CSSA comments were incorporated and the revised background levels were compared to draft reports already submitted. Following the comparison to new background levels, final reports were issued for SWMUs B-2, B-4, B-5, B-6, B-7, B-8, B-13, B-19, B-20/21, B-23, B-24, B-25, and B-28; and AOCs 36, 38, 39, 40, 47, and 44; and the Demo Dud Area. A summary of the status of each site is provided in Attachment 1. 

Work continued during Quarter 13 on RFI/Closure reports for AOC-65 and AOC-67, funded under DO 5084. The draft AOC-67 RFI Report was submitted and comments were received from CSSA and AFCEE in Quarter 12. Responses to comments and the final AOC-67 RFI Report will be submitted in July 2002. The draft AOC-65 RFI report was submitted on February 28, 2002 to AFCEE and CSSA for review. CSSA comments were received April 19, 2002, and no AFCEE comments have been received. 

Well Installations

The final WPs for TO 0042 were submitted as Final during Quarter 13. The Contracting Officers Representative (COR) issued the Notice to Proceed (NTP) for field activities on May 9, 2002. Field activities funded under TO 0042 commenced in Quarter 13. Activities this quarter include preparation for the start of field activities June 24, 2002. Both Parsons and GPI mobilized to CSSA on June 24, 2002, to start well upgrades and installations funded under TO 42. Well upgrades were begun at wells LS-7, CS-MW1-LGR, CS-MW2-LGR, CS-16, CS-G, and CS-H. New surface completions were installed at CS-MW1-LGR and CS-G, and the pumping motor was removed from CS-H. At CS-16, the existing downhole equipment was removed and the Cow Creek and Bexar Shale intervals of the well were plugged. This procedure resulted in a Lower Glen Rose completion for CS-16 only. All downhole equipment was returned to CS-16. Existing wells CS-MW1-LGR and CS-MW2-LGR were converted from open borehole completions to 3-inch diameter PVC wells with 25 feet of stainless steel screen. The Bexar Shale portion of each well was plugged with bentonite so the wells monitor the Lower Glen Rose portion of the aquifer only. In addition, one new Lower Glen Rose well (MW18-LGR) will be completed by the end of Quarter 14.

Currently the installation of 32 monitoring wells is funded, and 15 of these wells have been completed. TO 0042 funds the installation of 17 new monitoring wells, 10 wells to be completed in the Lower Glen Rose, two in the Bexar Shale, and five in Cow Creek. In addition, five well upgrades were initiated for TO 0042 (CS-16, CS-G, CS-H, CS-MW1-LGR, and CS-MW2-LGR). 

Building 90/AOC-65 Investigation

Field activities for TO 0058 continued in Quarter 13. Additional geophysical surveys were completed around Building 90 to identify fractures, faults, and karst features that may be controlling contaminant migration. Drilling activities for installation of the AOC-65 SVE system and groundwater piezometers west of Building 90 were initiated during Quarter 13. Subcontractor selection for the removal action activities outside Building 90 was completed in June, with implementation initiated in July 2002. Also, the draft standard air exemption packages for the standard air exemptions for the SVE and subslab blower systems were prepared during Quarter 13.

Results of the 2D seismic reflection surveys conducted in Quarter 12 were finalized in Quarter 13. Based on these results, CSSA and Parsons believe the 3-D seismic survey would not add needed information regarding key geologic features affecting groundwater recharge to the AOC-65 treatability investigation. From May 20 through May 29, electrical resistivity, induced polarization (IP), and spontaneous potential (SP) surveys were performed near Building 90. Preliminary review of data suggested that results were not identifying key features of interest in the subsurface up to 100 feet below ground surface (bgs). Additional geophysical surveys were performed between June 3, 2002 and June 13, 2002. The additional surveys involved performing resistivity imaging surveys west of Building 90 to supplement previously collected data. The surveys were performed using the AGI SuperSting system with IP measurement capabilities. The surveys were performed with the SuperSting system to assess if higher-powered IP measurements would provide additional information regarding the location of fractures and faults. Interpretation of this data, combined with seismic (from deeper than 150 feet) and geologic cross-sections of AOC-65 boreholes was prepared based on lithologies and borehole geophysical data. This provided sufficient information to develop a conceptual model of groundwater and contaminant flow in the upper 100 feet of the Lower Glen Rose formation.

Drilling activities funded under TO 0058 at AOC-65 were initiated in May. Drilling outside Building 90 (maximum depth of 4 feet) to delineate the extent of shallow contamination was initiated May 6, 2002. From April 19 through 21, 2002, Parsons installed 12 VEWs inside Building 90 as subslab ventilation wells. From April 26 to 29, 2002, the 12 subslab ventilation wells were manifolded together for eventual hookup to the SVE blower system currently under construction outside Building 90 on the west dock. Soil gas samples were collected from the subslab ventilation wells (VEWs) on June 6, 2002, for screening analyses and five VEWs were selected for soil gas sample collection for off-post, compound-specific laboratory testing. On May 13, 2002, drilling was initiated for installation of the AOC-65 SVE vapor extraction wells (VEWs), vapor monitoring points (VMPs) and groundwater piezometers. CSSA decided to begin the drilling program outside Building 90 with installation of the VMPs to attempt to validate geophysical data collected and locate faulting/fracture features near the building so the piezometers for the groundwater recharge study could be set at the most useful locations and depths. Two angle borings were added to the drilling program to better define the location and orientation of faults and fractures at the site. By the end of Quarter 13, seven VMPs, six piezometers, two angle borings, and seven VEWs were completed. Borehole geophysics and video logging were conducted on all the VMPs, the two angle borings, and two of the piezometers. 

One SVE packer test was performed during Quarter 13 as part of TO 0058. The packer testing was performed on June 7 and 10, 2002 in the borehole for VMP 4. Eight discrete intervals were isolated in the 100-foot deep borehole and soil gas samples extracted. Six of the eight soil gas samples were submitted for laboratory analysis. Preliminary laboratory results were received on June 26, 2002 and the final data package is expected to be complete in Quarter 14. A second soil gas packer test is planned for one of the deep piezometers locations and will be completed in Quarter 14.

Soil gas sampling of the subslab VEWs under Building 90 was conducted. Five samples were sent to an off-post laboratory for analysis of oxygen, carbon dioxide (CO2), and total volatile hydrocarbons (TVH). The results indicated the highest tetrachloroethene (PCE) levels were near the former vat location in Building 90. Low oxygen levels and high CO2 levels were reported south of the vat. 

Contractor procurement and technical planning activities associated with the removal action and treatability study at AOC-65 (under TO 0058) continued during Quarter 13. Engineering specifications for site restoration and the complete procurement bid package were presented to CSSA May 20, 2002 and the bid package was distributed May 31, 2002. Subcontractor bids were received on June 17, 2002, and Total Remediation and Excavation Technology (TRET) was selected as the removal action subcontractor. Parsons and TRET initiated the removal action activities on July 8, 2002 and the removal action activities will continue in Quarter 14. Site restoration will occur after the SVE system is installed. 

Regulatory Issues

Resolution of issues related to classification of soil and groundwater media generated during completion of the AOC-65 treatability study activities continued in Quarter 13. During a regulatory meeting in Quarter 12, the TNRCC indicated that the investigation-derived media and excavation waste generated during the activities at AOC-65 would be classified as hazardous waste per the hazardous waste listing criteria (“F” listing). On April 22, 2002, CSSA submitted a memorandum to the TNRCC and EPA presenting justification that the “F” listing classification of this material was incorrect. The EPA concurred with CSSA’s position regarding classification of the materials. On May 3, 2002, the TNRCC issued a response to the memorandum but did not resolve the issue. In a meeting held May 8, 2002 to discuss the TNRCC response, CSSA, Parsons, EPA, and the TNRCC agreed that preparation of a Waste Management Plan for inclusion in the Order would resolve the classification issues for AOC-65 as well as for future activities at CSSA. Parsons prepared a draft Waste Management Plan detailing the procedures CSSA will follow for the characterization and management of wastes generated during the corrective action activities. The Plan was submitted to EPA on June 13, 2002 for review. On July 9, 2002, EPA provided comments from the TNRCC regarding the plan. On July 15, 2002, CSSA submitted a response to the TNRCC's concerns. Details of the May 8, 2002 meeting are discussed in more detail in Section D, Summary of Contacts.

Miscellaneous

Parsons and CSSA prepared cumulative analytical results tables in support of an updated list of contaminants of concern (COCs) for future groundwater sampling events. The comparison of historical results to trip blank results justifies reducing the list of analytes and preparing two separate analyte lists for both on- and off-post. The request for a new list will be submitted to regulatory agencies in the future. 

Georeferencing of historical aerial photographs was conducted. Some of the more recent photographs were reviewed by Parsons GIS technical staff for suitability. All 12 photographs scheduled for georeferencing will be used to update the CSSA GIS. 

CSSA and Parsons met with TNRCC to discuss revisions to the CSSA Background Metals Evaluation during Quarter 12. The revised background report was submitted to TNRCC and EPA on February 11, 2002. On April 23, 2002, TNRCC issued written approval of the revised report and the new background levels are being incorporated into RFI/Closure Reports during Quarter 13. 

A draft version of the CS-10 and CS-16 Pumping Test report was completed and submitted to CSSA and AFCEE for review on June 7, 2002. The report detailed events associated with the pumping tests, and provided estimated hydraulic parameters derived from extensive analysis using the AQTESOLV™ software package. CSSA provided comments to Parsons on July 24, 2002. 

Karst survey work initiated during Quarter 12 continued in Quarter 13. The Phase 1 survey covering the entire 4,000 acres at CSSA was completed. The survey team identified 90 potential karst features, 89 on CSSA property, and one on private property. The next phase of the karst survey activities will include detailed review of the potential karst features by Dr. George Veni to determine if additional investigations are warranted. The next phase of the karst study will be completed in Quarter 14.

CSSA is planning the removal of sand media in the Building 90 test firing room. It has initiated the procurement of bullet trap devices for the room. The removal action of sand and lead shot will be initiated next FY. 

Preparation of the hydrogeologic conceptual site model (CSM) funded under RL83, WBS 04, continued during Quarter 13. Preparation of well installation reports for cluster wells installed under RL83 also continued in Quarter 13. 

  1. Percent Complete

This task makes up approximately 45 percent of the RFI phase. As of the end of Quarter 13, this task is approximately 28 percent complete. 

  1. Summary of Findings

Quarterly groundwater monitoring for both on- and off-post wells was performed at CSSA from June 10-21, 2002. A revised map of the well locations is provided in Figure 2.1 and Figure 2.2 of Attachment 2 of this report. These figures include monitoring well installations completed through the end of Quarter 13.

On-post Wells, June 2002: Three on-post drinking water and 22 monitoring wells were sampled June 17-21, 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-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. On-post wells CS-MW1-LGR, CS-MW2-LGR, CS-MW3-LGR, and CS-I were unable to be sampled due to pump malfunctions and/or low water levels. Samples were analyzed by STL. Results of the June 2002 groundwater monitoring event will be formally reported in a draft June 2002 Quarterly Groundwater Monitoring Report that will be submitted to CSSA and AFCEE during Quarter 14 for review and comments. Locations of the on-post wells sampled are provided on Figure 2.2 in Attachment 2.

Off-post Wells, June 2002: Twenty-five off-post groundwater wells were sampled June 10-14, 2002. Samples were collected at wells FO-J1, FO-J1 EP, HS-2, HS-3, I10-2, I10-4, JW-6, JW-9, JW-14, LS-1, LS-2, LS-3, LS-4, LS-5, LS-6, LS-7, OFR-1, OFR-2, OFR-3, RFR-7, RFR-8, RFR-9, RFR-10, RFR-11, and RFR-12. All samples were analyzed by APPL. Results of the off-post groundwater monitoring will be formally reported in a draft June 2002 Quarterly Groundwater Monitoring Report to be submitted to CSSA and AFCEE during Quarter 14. Locations of the off-post wells sampled are provided on Figure 2.1 in Attachment 2. 

Laboratory Audit: As reported in the Quarter 12 progress report, an audit of APPL was conducted under RL83 from February 25-28, 2002. The audit report was completed jointly by AFCEE and Parsons and submitted to APPL May 6, 2002. A corrective action report was received from APPL in June 2002, and is being reviewed.

AOC-65: Data from soil borings drilled as part of the investigation effort at AOC-65 were received in Quarter 13. Findings of the geophysical surveys and the initial drilling results were presented to CSSA in a meeting held July 1-2, 2002. Two fault zones were identified in geophysical data, and locations for the remaining piezometers and VEWs were selected based on the results.

Preliminary laboratory results from the SVE packer test conducted at VMP-4 reveal that each of the samples submitted contained PCE. The highest concentration of PCE was detected in a sample collected from the 78 - 85 foot depth interval. The sample from the 78 - 85 foot interval was also the only sample that contained trichloroethene (TCE) above detection limits. Oxygen and CO2 levels detected in the 3 - 10 foot and the 9 - 16 foot intervals suggest that degradation of PCE is occurring in the shallow material. Cis-1,2-Dichloroethene, a degradation compound of PCE and TCE, was detected in the 3 - 10 foot, 9 - 16 foot and 78 - 85 foot samples.

Pumping Tests: At CS-10 the specific capacity was calculated as 1.13 gallons per minute per foot (gpm/ft) of drawdown. Response to pumping was identified within CS-9 and CS-10 during the pumping test. CS-11 did not respond to pumping. Parsons attributes the lack of response to pumping at CS-11 to an aquifer boundary condition located between CS-10 and CS-11 and between CS-9 and CS-11. The physical location of the boundary condition is apparently located closer to CS-10 than CS-9 with respect to CS-11. Transmissivity was calculated to be 2,400 gallons per day per foot (gpd/ft). Storativity was calculated as 0.0005. The Middle Trinity aquifer exhibits confined properties at CS-10. The hydraulic conductivity for the Middle Trinity aquifer at CS-10 was calculated to be 5.7 x 10‑4 centimeters per second (cm/s).

At CS-16, the specific capacity for CS-16 was calculated as 0.71 gpm/ft. of drawdown. Response to pumping was limited to CS-16 and CS-D during the pumping test. Transmissivity was calculated to be 1,600 gpd/ft. Storativity was calculated as 0.00008. The Middle Trinity aquifer also exhibits confined properties at CS-16. The hydraulic conductivity for CS-16 was calculated to be 4.2 x 10-4 cm/sec.

  1. Summary of Changes

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

  1. Summary of Contacts

On March 26, 2002, the TNRCC conducted a Compliance Evaluation Inspection (CEI) at the CSSA facility. CSSA received a verbal report for issues raised during the CEI:

  1. Updating selected waste codes listed in the CSSA Notice of Registration (NOR);

  2. Modifying the NOR to reflect new waste codes added since the previous CEI; and

  3. Potential “F” listing of cuttings and drilling water generated during well installation operations.

On May 28, 2002, the TNRCC forwarded a summary of unresolved areas of concern for the 2001 CEI that included:

  1. TNRCC’s concerns regarding swipe versus chip samples for closure confirmation at the Building 40 site; and 

  2. HAZWOPER training for the CSSA Environmental Officer.

On June 21, 2002, CSSA submitted a response to the CEI indicating that concrete chip samples were collected from Building 40 on June 13, 2002 and the CSSA environmental officer would receive HAZWOPER training on June 27, 2002. 

On July 3, 2002, CSSA provided the training documentation to the TNRCC

On April 16, 2002 the TNRCC conducted an inspection of the CSSA drinking water system. The inspection resulted in two violations:

  1. 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

  2. Replacing a previously removed hatch on the water reservoir to prohibit the possibility of wind-blown contaminants 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.

On May 2, 2002, a follow-up DQO meeting was held under TO 0058. Personnel from Parsons, CSSA, and Portage Environmental attended. Draft DQOs for TO 0058 were reviewed and revised during the meeting. The revised DQOs were distributed by CSSA on May 3, 2002. 

On May 8, 2002, CSSA and Parsons met to discuss the TNRCC response to the technical memorandum/position paper submitted by Parsons concerning the listed hazardous waste classification (“F” listed) of contaminated media generated at Building 90. CSSA received TNRCC’s response to the technical memorandum/position paper on May 3, 2002. At the May 8, 2002, meeting Parsons and CSSA contacted the EPA and the TNRCC directly to discuss responses to this technical memorandum. It was agreed that CSSA would prepare a Waste Management Plan detailing the procedures that CSSA will undertake to characterize and manage the contaminated media generated during the corrective action activities. It was agreed that the plan would be submitted to EPA for review and incorporation into the Order.

On May 28, 2002, a site visit was conducted by CSSA, Parsons, and GPI personnel. The purpose was to evaluate options available for well upgrades funded under TO 0042 for wells CS-G, CS-H, CS-16, CS-MW1-LGR, and CS-MW2-LGR. 

On May 21 and May 30, 2002, In-Situ, Inc., demonstrated its transducer/telemetry system at CSSA. A sample system utilizing a cellular telephone link from well CS-16 to the CSSA environmental office was installed. The system enabled CSSA to view, download, and manipulate the downhole transducer/datalogger. The system is being evaluated by Parsons and CSSA for costs of implementation and growth considerations. 

On May 31, 2002, CSSA forwarded results of the March 2002 sampling event to well owners. In response to a specific request from one well owner, CSSA forwarded a copy of pertinent pages from the laboratory data package. 

May 20-23, 2002, Parsons task order manager and CSSA personnel attended a technical conference regarding investigation and treatment of chlorinated hydrocarbons in fractured media. Case studies and innovative technologies were highlighted, including remediation and characterization of chlorinated solvents in fractured bedrock, cleanup of volatile organics underlying an industrial building, and regulatory issues related to chlorinated solvent cleanups. 

Other contacts related to Facility Investigations included routine contacts with off-post private well owners to obtain access for sampling in June 2002. A new sampling location, the FO-J1 entry point, required contact with a representative of Fair Oaks Ranch Utilities to coordinate the best point in the water system for sampling. 

Parsons’ technical staff attended meetings on June 6, 2002 with FWC to provide support for planning phases of work to be conducted at SWMU B-3. 

A pre-bid meeting was held at CSSA on June 6, 2002, under TO 0058. Parsons, CSSA, and prospective bidders for the removal action subcontract under TO 0058 attended. The pre-bid meeting was held to familiarize bidders with the project requirements and answer any questions pertaining to the removal action scope of work.

On June 20, 2002, a Data Management Procedures presentation was conducted under TO 0042. Parsons and CSSA personnel attended. Items discussed included electronic management of daily field data, including scanned images of field logbook entries and basic handwritten logbook procedures. The use of dataloggers and electronic notebooks for collection of field information was presented. Electronic notebooks can be used for recording field measurements that do not require validation (e.g. groundwater temperature, pH, conductivity, water levels, etc.). Future telemetry systems usage was discussed. The anticipated data management activities for the future resulted in a request by CSSA for Parsons Standard Operating Procedure (SOP) for management of electronic data. The SOP will be drafted during Quarter 14. 

On June 28, 2002, Parsons TO 0058 Removal Action Task Manager and technical staff visited the site to conduct an SVE permit by rule site visit and air compliance meeting for remediation and restoration work planned around Building 90.

July 1-2, 2002, a technical progress meeting was held to review field activities completed under TO 0058. CSSA and Parsons met to review results of the geophysical surveys and the preliminary data from the AOC-65 drilling activities. These data were reviewed and a preliminary conceptual model of contaminant transport was developed. The locations of the installed and proposed VMPS, VEWs, and piezometers were reviewed and modifications to future borehole locations were made based on the conceptual model. The TO 0058 DQOs were reviewed to determine if changes were warranted based on the newly developed configuration of VEWs, VMPs, and piezometers. Additionally, enhanced biodegradation using injections of lactate and/or vegetable oil was identified as a potential remedial technology for possible inclusion in the treatability study at AOC-65. Parsons prepared a technical summary paper to be included in discussion with regulators on June 23, 2002. 

A meeting was held on June 23 with EPA and TNRCC regulators to discuss the SWMU B-3 removal action and the possible application of innovative, passive approaches to enhance biological activity in the groundwater plume, et. al. 

On July 19, 2002, CSSA and Parsons met with TNRCC LPST Coordinator to clarify their request for additional monitoring at LPST Site No. 101264. CSSA provided the coordinator with a memorandum that was previously sent to them in 1996. The TNRCC will evaluate that data and provide either a closure memorandum or request that additional work be performed.

  1. Summary of Problems

AFCEE approved 24 data packages during Quarter 13. Cumulatively, 227 data packages have been approved through the end of Quarter 13. Approximately seven data packages were submitted and are pending AFCEE comment/approval. 

  1. Actions Taken to Correct Problems

CSSA’s Environmental Officer met with the AFCEE project chemists to request they approve data packages that have been under review for more than 3 months or prepare comments in the form of a memorandum for submittal to Parsons for assessment and correction, if appropriate. 

  1. Projected Work for the Next Quarter

A “Fact-Sheet” summarizing the findings of the June 2002 Quarterly Groundwater Monitoring event will be developed and mailed to area residents.

The next quarterly groundwater monitoring event will be conducted in September 2002. This upcoming event will include the existing CSSA wells that are typically sampled, approximately 25 off-post wells (VOCs only), and newly completed and developed on-post monitoring wells. On- and off-post quarterly sampling will be funded under TO 0042 in September 2002. Monthly sampling and post-GAC confirmation sampling will be funded under RL83 through September 2002. 

CSSA and AFCEE developed a Statement of Work (SOW) 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 an SOW to develop a needs and assessment for an Environmental Management System. Which is to be completed by FWC.

O&M at the residential GAC filtration systems (LS-6, LS-7, OFR-3, RFR-10, and RFR-11) and on private water supply systems (LS-2/LS-3) will be conducted in Quarter 14.

Additional investigations at AOC-65 will be conducted in Quarter 14. Investigation will include finalizing construction of VMP, VEW, and piezometers installation, karst surveys and other geophysical testing. The AOC-65 SVE system and weather station will be installed during Quarter 14. Delays in procurement of the removal action contractor postponed the startup, testing, and operation of the subslab ventilation system until Quarter 14. Startup and testing of the SVE system is also anticipated to begin in Quarter 14. 

Drainage diversion will also be constructed by the removal action contractor at Building 90 as described in the plan to reduce the volume of recharge through the shallow soils adjacent to CSSA. 

Work will continue in Quarter 14 on the six remaining RFI draft reports to be submitted as well as the remaining 22 RFI reports to be submitted as final. RFI/Closure reports ready to be made final will be submitted to the TNRCC as soon as comparison to the revised background numbers is performed. 

  1. 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- 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- 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 December On- and Off-post Quarterly Groundwater Monitoring Reports were submitted for inclusion in the Environmental Encyclopedia May 10, 2002. These reports are located in Volume 5, Groundwater, behind the On-post Groundwater Monitoring and Off-post Groundwater Monitoring tabs. The Draft March 2002 On- and Off-post Groundwater Monitoring Reports were submitted in Quarter 12. Comments were received from CSSA and AFCEE and changes were incorporated. The reports were submitted as Final on July 10, 2002.

Preliminary groundwater data from the June 2002 quarterly sampling event were received July 2002, and data review and validation was initiated for both on- and off-post groundwater monitoring. Parsons will submit the draft June 2002 Groundwater Monitoring Reports for on- and off-post wells in Quarter 14, and will revise the reports based on comments/responses received from CSSA and AFCEE.

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 (RRS), 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 an RRS1 closure is not applicable. Due to the promulgation (September 23, 1999) of the Texas Risk Reduction Program (TRRP) (30 Texas Administrative Code [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 in 2001 was continued as described previously in RFI Task III.

  1. Percent Complete

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

  1. Summary of Findings

As described in Task III, 38 draft RFI reports have been completed and submitted, and 15 final reports have been completed and submitted. As part of the preparation of these reports, investigation results were compared to closure criteria. A summary of recommendations is provided in Attachment 1. Based on the 38 sites for which draft reports have been submitted, 14 were recommended for closure and 24 sites may require future action. 

  1. Summary of Changes

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

  1. Summary of Contacts

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

  1. Summary of Problems

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

  1. Actions Taken to Correct Problems

No actions to correct problems were necessary during this reporting period.

  1. Projected Work for the Next Quarter

Continued work on comparison of investigation results to closure criteria will be performed. 

  1. 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 WP 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 include 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 13. 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. Monitoring data are anticipated to support closure/remediation efforts for sites with similar contaminants of concern. Preliminary results of the bioassessment performed on treated versus untreated soils indicate an approximate 80 percent reduction in bioavailability of lead-based on protocols established by Dr. Michael V. Ruby. Dr. Michael V. Ruby, PhD, is a leading authority in evaluating bioavailability of inorganics in soil for use in human health risk assessments. UFA Ventures is utilizing Dr. Ruby for conducting in vitro tests developed to assess the sorption amount of lead available to humans. During Quarter 13, additional funding was received to extend monitoring efforts at SWMU B-20 through May 2003 and to perform in vitro bioaccessability and additional bioavailability tests. Leachate monitoring of PIMS-treated soils at SWMU B-20 is anticipated to occur on a monthly basis. 

  1. 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, but is currently estimated to be 93 percent complete. 

  1. Summary of Findings

Analytical data continue to be received from the PIMS treatability study monitoring efforts. The results will be reported in the treatability study report anticipated to be completed in September 2003. 

No additional testing data were received from the SVE system continuing to be operated at SWMU B-3 during Quarter 13. 

  1. Summary of Changes

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

  1. 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 into Quarter 14. 

  1. 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. 

  1. Actions Taken to Correct Problems

No actions to correct problems were necessary during this reporting period. 

  1. Projected Work for the Next Quarter

No additional O&M testing is planned at the SWMU B-3 SVE system 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 and bioassessments of SWMU B-10 PIMS-treated soils for the PIMS treatability study is expected to continue during Quarter 14. Additionally, field scale treatability studies of soil density separation followed by phytoextraction for the previously sifted soil piles as part of the treatability activities will continue in Quarter 14.

Under TO 0058 issued on September 17, 2001, and modified in April 2002, under AFCEE 3P/AE Contract F41624-00-8024, Parsons will complete installation of equipment (weather station, data recorders, etc.) for treatability testing for cleanup of subsurface contamination in and around Building 90 (AOC-65) during Quarter 13. Sub-slab SVE and shallow groundwater containment/in-situ treatment technologies will be evaluated as possible treatment alternatives under TO 0058. 

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

No analytical data are submitted during this reporting period. 

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 the Quarterly Progress Report preparation task is partially funded. Progress reports for two years (August 1999 – May 2001) were funded under RL83 of the Air Mobility Command (AMC) contract. Another six progress reports (July 2001 – October 2002) are also funded under DO5084 of the AETC contract. 

  1. 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.

  1. Summary of Findings

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

  1. Summary of Changes

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

  1. Summary of Contacts

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

  1. Summary of Problems

No problems relating to progress reports occurred during this reporting period.

  1. Actions Taken to Correct Problems

No actions to correct problems were necessary during this reporting period.

  1. Projected Work for the Next Quarter

The Progress Report for Quarter 14 will be submitted.

  1. 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.

[Next Section]