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16th Final Quarterly Progress Report
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 to assess whether any additional IM 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 16, the RFI is approximately 45 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 USEPA and TCEQ 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.
Activities this Quarter
No activities associated with the Description of Current Conditions were conducted this period.
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 USEPA, CSSA’s Environmental Encyclopedia has been used to fulfill this requirement. The Environmental Encyclopedia includes all the information required by the Order. Completion of this task is funded for the planned RFI tasks.
Activities this Quarter
Planning for the next phase of work at several SWMUs and AOCs was conducted during this quarter. A new project, which is tentatively scheduled to begin during Quarter 17, will include field work and reporting with the overall goal of bringing additional SWMUs and AOCs to closure under the Risk Reduction Standards.
CSSA submitted its post-wide Quality Assurance Project Plan (QAPP) to TCEQ and EPA for approval. The post-wide QAPP will apply to all future task orders conducted at CSSA. TCEQ approved the QAPP on January 16, 2003, and the EPA approved it on January 31, 2003.
Percent Complete
The RFI work plan 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 16, work plans currently under scope are approximately 99 percent complete. The CSSA Environmental Encyclopedia will continue to be updated as documents are completed.
Summary of Findings
No new findings are associated with RFI WP preparation during this reporting period.
Summary of Changes
No changes to the RFI WP were made during this reporting period.
No contacts occurred during this reporting period.
Summary of Problems
No significant problems occurred during this reporting period.
No actions were taken for any problems during this reporting period.
Additional work plans are anticipated for the upcoming SWMU and AOCs closure project.
No daily reports, inspection reports, or data related to the RFI Work Plan task were generated during this reporting period.
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 WP.
Completion of this task is partially funded for the planned RFI tasks. Attachment 1 indicates the sites for which investigations have been funded and subsequently conducted. Funding for a new task order to conduct additional investigations at SWMUs B-29, B-25, Bldg 43, B-11, B-30, B-33, B-8, DD, B-23A, B-12, B-2, B-23, B-34, AOC-56, and AOC-50 is currently being negotiated. A future task order and/or modification will address investigations at remaining sites. Funding for on- and off-post groundwater monitoring is covered under TO 0042 through June 2003. Additional quarterly groundwater monitoring events will be conducted under a future 4P-AE contract currently being negotiated.
Activities this Quarter
The majority of current on-going environmental activities at CSSA are part of the RCRA Facility Investigation. Work on each of these tasks is described in the following paragraphs. The main areas of work this quarter include groundwater monitoring, maintenance of the off-post granular activated carbon (GAC) well head treatment systems, analytical data verification and validation, RCRA facility investigations of selected SWMUs and AOCs, well installations, Building 90/AOC-65, AOC-55 and SWMU B‑3 investigations.
Groundwater Monitoring
Sampling is conducted quarterly of all on-post and selected off-post wells. In March 2003, thirty-two wells were sampled, including seven post-GAC samples collected. Off-post groundwater sampling was performed during the week of March 10, 2003. Twenty-five private and public off-post wells were sampled, including DOM-2, FO-17, FO-8, FO-J1, HS-2, I10-2, I10-4, I10-7, JW-9, JW-14, JW-26, JW-30, LS-1, LS-2, LS-3, LS-4, LS-5, LS-6, LS-7, OFR-1, OFR-2, OFR-3, RFR-10, RFR-11, and RFR-12. All samples were collected from ports located near the well head. During the March event, three additional wells were sampled without purging (wells I10-7, JW-14, and LS-7) for comparison to purged sampling results. Seven post GAC samples were also collected as part of the March 2003 sampling event from wells equipped with GAC systems (LS-2/LS-3-A1, LS-2/LS-3-A2, LS-6, LS-7, OFR-3, RFR-10, and RFR-11). The locations of these wells are shown on Figure 1.0 in Attachment 2. Samples were analyzed for volatile organic compounds (VOCs) by APPL. Preliminary data on these samples were received by Parsons on April 16, 2003. Data validation and verification for these samples is ongoing for this groundwater event.
Quarterly groundwater monitoring of 34 on-post wells was performed the week of March 17, 2003. CSSA wells CS-1, CS-2, CS-9, CS-10, CS-11, CS-D, CS-MWG-LGR, CS-MWH-LGR, CS-MW1-BS, CS-MW1-CC, CS-MW1-LGR, CS-MW2-LGR, CS-MW3-LGR, CS-MW4-LGR, CS-MW5-LGR, CS-MW6-BS, CS-MW6-CC, CS-MW6-LGR, CS-MW7-CC, CS-MW7-LGR, CS-MW8-CC, CS-MW8-LGR, CS-MW9-BS, CS-MW9-CC, CS-MW9-LGR, CS-MW10-CC, CS-MW10-LGR, CS-MW12-BS, CS-MW12-CC, CS-MW12-LGR, CS-MW16-LGR, CS-MW17-LGR, CS-MW18-LGR, and CS-MW19-LGR were purged and sampled. In addition, the three drinking water wells (CS-1, CS-9, CS-10) were also sampled without purging for comparison of sampling results to purged samples. Locations of the on-post wells sampled are shown on Figure 1.0 in Attachment 2. Samples were analyzed by Severn Trent Laboratories (STL) with preliminary data received by Parsons from April 14-25, 2003. Data validation for VOCs, metals, and cations and anions is currently ongoing for this groundwater event.
The December 2002 Final On- and Off-Post Quarterly Groundwater Monitoring Reports were incorporated into the Environmental Encyclopedia in March 2003. The draft On- and Off-post Quarterly Groundwater Monitoring Reports for March 2003 will be submitted during Quarter 17 to CSSA and AFCEE for review.
In addition, preparation of an Annual Groundwater Monitoring Report was continued during Quarter 16, and the final report will be submitted during Quarter 17. This first annual report will include an analysis of all quarterly groundwater monitoring results, with a focus on the quarterly events conducted during 2002.
Off-Post GAC Systems
Based on previous sampling results that indicated VOC levels, above or approaching the MCL, GAC filtration systems have been installed at seven off-post wells. In accordance with the CSSA Off-post Monitoring Program Response Plan, June 2002 (the Plan), off-post GAC wellhead treatment systems were installed at these wells and are maintained by CSSA. Monthly O&M of the 5‑micron filters at the off-post residential GAC treatment systems was performed this quarter. 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. Carbon exchange for the GAC filtration system at wells LS-2 and LS-3 is to be performed every 180 days. This exchange was conducted by Carbonair in February 2003 and post-GAC confirmation sampling was conducted during the March 2003 quarterly off-post sampling event. Results from this event confirm that GAC treatment systems are working effectively. The next post–GAC confirmation sampling will be conducted in September 2003.
Data Validation and Verification
Laboratory results are validated and verified by Parsons’ chemists to ensure results are in compliance with AFCEE QAPP requirements. Data validation and verification continued during Quarter 16 under CSSA projects, TO 0042, TO 0058, RL17, RL83, and TO 0009.
Data packages related to quarterly groundwater monitoring activities consist of groundwater monitoring conducted on- and off-post during Quarter 16 (the March 2003 quarterly sampling event). Additional data packages related to IDW and screening samples during well installation, waste characterization during excavation, and investigations at SWMUs B-23A and B-34 were also generated. Verification of these data packages continued during Quarter 16. AFCEE chemists approved two groundwater data packages this quarter (TO42-J and TO42-K), on February 19 and 27, 2003. AFCEE chemists approved three other data packages (RL83#70, TO09-A and TO09-B) on February 19, 2003 and March 27, 2003. Nine data packages are being validated during this quarter for outfall discharge, IDW, SWMU investigations, and March 2003 groundwater monitoring samples by Parsons and for submittal to AFCEE during Quarter 17.
An O&M Manual was prepared for the GAC system located adjacent to CSSA Well CS-16. The manual provides a detailed description of the system and its layout, and documents sampling requirements. A copy of the GAC Manual will be kept in the GAC building for ready reference.
RCRA Facility Investigations of SWMUs and AOCs
A total of 84 SWMUs, AOCs, and Rifle Management Units (RMUs) have been identified at CSSA. Investigations have been conducted at 59 of those sites. A summary of the status of each site, including whether the site has been recommended for closure or if closure has been approved, is provided in Attachment 1. TCEQ approved closure of SWMU B-9, AOC-35, AOC-43, and AOC-61 during Quarter 16. CSSA has also submitted closure recommendations for SWMU B-32, which is pending comments from TCEQ.
In February 2003, surface soil samples and ampoules from SWMU B-23A were collected and submitted to APPL Laboratory for analysis. In March 2003, additional surface soil sampling was conducted at SWMUs B-8, B-34, and Building 43 in an effort to define the horizontal extent of surface soil contamination.
An RFP was received from AFCEE on April 15, 2003, for remediation of various SWMUs and AOCs, field investigations, and subsequent RFI/Closure reporting. The proposal was prepared and submitted for consideration on April 29, 2003. This work is projected for funding during Quarter 17. The current proposal includes SWMUs B-29, B-25, Bldg 43, B-11, B-30, B‑33, B-8, DD, B-23A, B-12, B-2, B-23, B-34, AOC-56, and AOC-50. A future task order and/or modification will address investigations at additional sites.
Well Installations
There are currently 37 drinking water, livestock, and monitoring wells at CSSA. TO 0042 funded the installation of 17 new monitoring wells: 10 wells to be completed in the Lower Glen Rose Formation, two in the Bexar Shale, and five in the Cow Creek Formation. In addition, five upgrades to existing wells were completed under TO 0042 (CS-16, CS-G, CS-H, CS‑MW1-LGR, and CS-MW2-LGR). At the end of Quarter 15, the well upgrades and the installation of eight new monitoring wells under TO 0042 were completed. New well installations are expected to continue through Quarter 17.
Parsons and the drilling subcontractor, Geoprojects International, Inc. (GPI) continued well installations during this period. Drilling was initiated at the CS-MW2-CC well location during the current quarter. The corehole was advanced to 361 feet below ground surface (bgs), and was geophysically logged. Reaming of the corehole to 12-inch diameter ensued to accommodate 8-inch surface casing to 357 feet. The Bexar Shale interval was cored, logged, and sampled during this reporting period. Groundwater from the Bexar Shale interval was sampled and found to contain low levels of toluene (1.9 µg/L). Based on this result, no additional surface casing was installed in this prior to drilling the Cow Creek portion of the aquifer.
Once the casing was installed, coring continued until 492 feet bgs. The Bexar Shale/Cow Creek Formation contact was encountered at 407 feet bgs, and the Hammet Shale was encountered at 479 feet bgs. Discrete interval groundwater sampling conducted within the Cow Creek interval indicates at this location that the Cow Creek is currently free of contaminants. The casing methodology appears to be successful in mitigating cross contamination from the upper zones. The selected screen interval for the Cow Creek well was 426 to 451 feet bgs.
Upon completion of CS-MW2-CC, the drilling rig was mobilized to the CS‑MW11A-LGR location in the southern portion of the base. Coring ensued until 414 feet bgs. By this point the on-site geologists had determined that a significant structural feature was present in the nearby subsurface. Borehole geophysics was used to verify the stratigraphic position of the most recent core. The geophysics supported the theory that the drilling location was within a downthrown block of a fault with significant displacement. Coring continued until 492 feet bgs. Further borehole geophysics and video logging were conducted. The Glen Rose/Bexar Shale contact was encountered at 448 feet bgs, some 40 feet below its anticipated depth. A screened interval from 420 to 445 feet bgs was selected for CS-MW11A-LGR. Since discrete interval sampling indicated the corehole was free of contamination, the well was installed as a single-cased completion.
Both the borehole geophysics and downhole video indicated the presents of a significant transmissive reef zone between 180 and 260 feet bgs. Reaming of the CS-MW11A-LGR borehole found that this zone was capable of producing over 300 gallons per minute. At this point it became technically impractical to contain and treat all produced groundwater. In accordance with the CSSA Waste Management Plan and based on findings of the discrete interval groundwater samples and various waste stream samples, the produced water was released to the ground surface near the drilling site.
Because this zone was so transmissive, it was decided by Parsons, AFCEE, and CSSA to further explore this interval. An offset well (CS-MW11B-LGR) was drilled to test the zone. Additional discrete interval groundwater samples and further geophysics were conducted during drilling. The borehole was advanced to 260 feet bgs, however, the most transmissive zone between 182 and 207 feet bgs was screened for monitoring.
During this reporting period, groundwater well development ensued at locations CS‑MWH-LGR, CS-MW1-BS, CS-MW1-CC, and CS-MW2-CC. After completion of development, low flow QED sampling pumps have been installed in each of these wells. Continued development at CS-MW12-CC was conducted in an effort to reduce the elevated pH condition that occurs when the well is allowed to equilabrate. The pH condition is suspected to be related groundwater being in contact with the annular grout sealant. Continual pumping has reduced the effect of the elevated pH.
Because testing indicates low levels of VOC contamination, groundwater and drilling fluids produced during drilling efforts at the CS-MW2-CC and the CS-MW11A-LGR locations were contained and treated at the CSSA GAC unit and discharged at TPDES-permitted Outfall 002. Parsons operated and maintained the GAC unit, and prepared a Discharge Monitoring Report (DMR) for each month to comply with TPDES requirements. Through the completion of CS-MW11A-LGR, nearly 120,000 gallons of water with VOCs was treated by GAC and discharged from Outfall 002. Sample results show that water discharged from the outfall contains less than the laboratory Method Detection Limit (MDL) of potential contaminants of concern (COCs).
At the end of the reporting period, eight new transducers with datalogging capability were installed at selected CSSA wells. Four standard transducers were installed in the CSSA water supply wells (CS-1, CS-9, CS-10, and CS-11). Transducers with the ability to measure pressure, temperature, and conductivity were installed in four of the six shallow piezometers near AOC-65 in support of the groundwater recharge study be conducted under TO58. Additional transducers will be installed as wells are completed.
Building 90/AOC-65 Investigation
The TO 0058 task order covers interim measures conducted at Building 90 and treatability studies at Building 90/AOC-65. The evaluation of soil vapor extraction as a treatment method is a subtask under TO 0058. Work continued during Quarter 16 on the Building 90/AOC-65 investigations, the soil vapor extraction (SVE) system, and vapor monitoring point (VMP) and vapor extraction well (VEW) installations and sampling.
Initial soil gas screening data was obtained from vapor extraction wells (VEWs) installed inside Building 90 on December 3, 2002. A second round of soil gas screening and pressure response readings were taken on December 4, 2002, shortly after the SVE system installed outside Building 90 was started. This was done to determine if there was any influence or response in the subslab VEWs. After these initial readings were taken, the subslab blower system inside Building 90 was started and soil gas changes were monitored over the initial hours following startup, and prior to system shut-down on December 11, 2002. Air emission samples were collected after one hour of operation, the following morning (December 5), and then periodically through December 11 (December 6, 9, and 11) for off-site VOC testing. The air emission results from the subslab system indicated that the subslab SVE system is operating within limits of the standard air exemption.
Parsons continued initial system checks and soil gas monitoring for the SVE system outside Building 90 in accordance with the Treatability Test Plan between January 14 and 16, 2003. Air emission samples were also collected from the SVE system over a period of six days from January 15th through 20th, 2003.
Results from air sampling were received on February 10, 2003. The air emission results indicated that the fully operational SVE system outside Building 90 appears to operate within the parameters of the standard air exemption submitted to TCEQ. Emissions from the system ranged from 0.03-0.10 tons per year compared to 0.06-0.35 tons per year of the subslab system. The SVE system was shut down on January 26 to await the data that verifies that it is operating within the air exemption limits. After an eight-week idle period, the soil gas from inside Building 90 was retested on April 12, 2003 to assess any changes and recovery of VOC levels in subslab VEWs, and to conduct a pressure response/radius of influence test of the VEWs on the SVE system outside Building 90. The recovery test results generally indicated oxygen and carbon dioxide returned to pre-extraction levels whereas the total volatile hydrocarbons (as measured by PID) were significantly lower (by 10 times in most cases). However, with the exception of VEW-1, which experienced a PCE reduction from 16,276 ppmv to 110 ppmv, all remaining tested VEWs indicated post-extraction levels almost identical to pre-extraction numbers. These findings suggest that accumulation of chlorinated hydrocarbons is likely to continue around those tested points emphasizing the need for mostly continuous SVE of the Building 90 subslab soils. It may be possible to shut off or significantly decrease SVE from several VEWs, in an attempt to improve PCE mass removal.
The Building 90 weather station and piezometer transducer recorders became operational on October 31, 2002. Parsons continued to troubleshoot the datalogger program after determining that minor discrepancies continued to remain with the collection of data. An on-site meeting was held with a technical representative from Campbell Scientific on February 7, 2003 and the program issues were resolved. The evaluation of recharge through the upper bedrock zones continues; however, no significant rainfall events have occurred since becoming operational.
CSSA procured four In-Situ Troll 9000 water quality probes that will be used under TO 0042. On April 10, 2003, these probes were installed in TO 0058 piezometers to begin collection of groundwater quality data and to monitor contaminant migration in the shallow epikarst zones that transmit groundwater. These transducers were installed to monitor fluctuations in conductivity experienced in the epikarst during significant rainfall events. Once in place, Parsons will conduct groundwater sampling per the approved DQOs as modified during TIM#6 following significant rainfall events.
Parsons restarted treatability testing on April 12 by turning on the subslab SVE system at Building 90 and performed weekly measurements of soil gas changes to evaluate the areal influence of the subslab system on the entire treatment zone around Building 90.
SWMU B-3 Excavation
Due to the unanticipated size of SWMU B-3 and the increase of estimated in-place waste, the anticipated project funding requirements have also increased. Additional work to remove soil from the west trench has been suspended pending the additional funding. In the interim, berms and plastic liners from the hazardous waste staging area (formerly SWMU B-10) were removed and re-graded.
SWMU B-3 SVE
Additional SVE pilot tests and removal actions are planned at SWMU B-3 under RL83. This work will focus on remediation of chlorinated hydrocarbons from vadose zone fractured bedrock underlying the B-3 trench. A modification to RL83 is required before proceeding with these activities.
AOC-55 Excavation
Removal actions were continued at AOC-55 in Quarter 16. The current findings at AOC-55 have included the discovery of more than 100 ordnance/explosive (O/E) scrap items, many of which were found at depths greater than two feet. The items include 75mm projectiles, 155mm projectiles, and Stokes mortars. Approximately 19 of the items unexploded ordnance may still have contained high explosive filler (UXO); however, none were found to be fused. Due to the current findings, identification and removal of UXO or O/E scrap by UXO specialists was recommended for the entire contents of AOC-55. The planned methodology for identifying and removing O/E scrap is inadequate for soil/waste material destined for an off-post landfill. The potential for “missing” an item using the planned method of visual identification is high due to the unanticipated number of O/E material and UXO items identified.
Parsons has recommended that the soil/waste media undergo mechanical sifting operations in order to effectively remove all O/E scrap items and ensure UXO material is properly identified. Use of a mechanical method of O/E removal will ensure that all items greater than 2 inches in size will be removed. The sifting operations were not anticipated for the project and resulted in a modification of the task order to include additional funding for the revised methodology. The funding has been provided and work is expected to continue in Quarter 17 and 18.
Miscellaneous
The request for approval of a revised short list of COCs for groundwater monitoring was submitted to the TCEQ and the USEPA on August 26, 2002. No response to the proposed short list of COCs was received during Quarter 16.
A draft karst survey report was prepared by George Veni and Associates and provided to CSSA for review in Quarter 14. Internal review of the report was completed in November 2002, and the report was forwarded to Wayne Mandell of the Army Environmental Center for additional review. Mr. Mandell is the Army’s resident expert on karst issues at their facilities. His review was completed in January 2003. CSSA began compiling all comments on the survey report during Quarter 15, and will issue the comments to George Veni and Associates during Quarter 17 for resolution.
Preparation of the hydrogeologic conceptual site model (CSM) funded under RL83, WBS 04, continued during Quarter 16. Work on the CSM during this reporting period focused on the AOC-65 area in preparation for the installation of multi-level monitoring points (Westbay) in the vicinity of Plume 2. Detailed cross-section stratigraphic analysis has been conducted to best determine the locations and zones to monitor. The geologic model is being prepared using the Rockworks software package to visualize the subsurface conditions. Preparation and submittal of the draft well installation report for cluster wells installed under RL83 was completed in Quarter 16.
Fact Sheets 12 and 13, summarizing the findings of the September 2002 and December 2002 Quarterly Groundwater Monitoring were finalized and mailed to area residents on February 17, 2003.
The Camp Stanley website was updated with documents added to the Environmental Encyclopedia through the end of March 2003. The website includes CSSA’s Administrative Record.
Planning for obtaining an updated color aerial photograph with a very high resolution was initiated this quarter. In addition, digital earth surface data will be obtained using Light Detection and Ranging (LIDAR) technology. The LIDAR data will be used to create a highly accurate digital terrain map of CSSA and its vicinity. This map and the updated aerial photograph will be helpful in developing/updating the Conceptual Site Model.
Percent Complete
The Facility Investigation task makes up approximately 45 percent of the RFI phase. As of the end of Quarter 16, this task is approximately 25 percent complete.
Summary of Findings
Groundwater Monitoring
Quarterly groundwater monitoring for both on- and off-post wells was performed at CSSA from March 10 to 25, 2003. A map of the well locations sampled is provided in Figure 1.0 of Attachment 2 of this report. This figure includes monitoring well installations completed through the end of March 2003.
On-post Wells, March 2003: Three on-post drinking water and 31 monitoring wells were sampled March 17 to 25, 2003. Samples were collected at wells CS-1, CS-2, CS-9, CS-10, CS-11, CS-D, CS-MWG-LGR, CS-MWH-LGR, CS-MW1-BS, CS-MW1-CC, CS-MW1-LGR, CS-MW2-LGR, CS-MW3-LGR, CS-MW4-LGR, CS-MW5-LGR, CS-MW6-BS, CS-MW6-CC, CS-MW6-LGR, CS-MW7-CC, CS-MW7-LGR, CS-MW8-CC, CS-MW8-LGR, CS-MW9-BS, CS-MW9-CC, CS-MW9-LGR, CS-MW10-CC, CS-MW10-LGR, CS-MW12-BS, CS-MW12-CC, CS-MW12-LGR, CS-MW16-LGR, CS-MW17-LGR, CS-MW18-LGR, and CS-MW19-LGR. Samples were analyzed by STL. Results of the March 2003 groundwater monitoring event will be formally reported in the draft March 2003 Quarterly Groundwater Monitoring Report to be submitted to CSSA and AFCEE during Quarter 17 for review and comments.
Off-post Wells, March 2003: Twenty-five off-post groundwater wells were sampled March 10-14, 2003. 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, JW-30, LS-1, LS-2, LS-3, LS-4, LS-5, LS-6, LS-7, OFR-1, OFR-2, OFR-3, RFR-10, RFR-11, and RFR-12. Post GAC samples were also collected as part of the March 2003 sampling event from wells equipped with GAC systems (LS-2, LS-3, LS-6, LS-7, OFR-3, RFR-10, and RFR-11). All samples were analyzed by APPL. Results of the off-post groundwater monitoring will be formally reported in a draft March 2003 Quarterly Groundwater Monitoring Report to be submitted to CSSA and AFCEE during Quarter 17.
Building 90/AOC-65 Investigation
On February 20, 2003 approximately 1.5 inches of rain occurred at the post. Review of the water level data from the piezometers following this rain event indicated that the levels in the shallow piezometers (AOC65-PZ02-LGR, AOC65-PZ04-LGR and AOC65-PZ06-LGR) did not change following the rain. The deep piezometers (AOC65-PZ01-LGR, AOC65-PZ03-LGR, and AOC65-PZ05-LGR) did show a response to the rain event, with AOC65-PZ05-LGR exhibiting the greatest amount of response. There had been less than 0.5-inches of rain for the month prior to the February 20 rain even and the lack of response in the shallow zone suggests that rain that recharged into the bedrock matrix was absorbed and the recharge to the bedrock conduits migrated directly to the water table without recharging this shallow zone. No significant rain events have occurred at the post since the February event and no significant recharge data has been collected.
Summary of Changes
No changes to the RFI were made during the reporting period.
Summary of Contacts
No significant contacts were made during the reporting period.
Summary of Problems
AFCEE approved 5 data packages during Quarter 16. Cumulatively, 198 data packages have been approved through the end of Quarter 16. Additional data packages are pending submittal to CSSA and AFCEE for comments and/or AFCEE approval.
No actions beyond those previously reported for the data package review and approval process have been taken to correct problems.
Fact Sheets
Fact Sheet 14, summarizing the findings of the March 2003 Quarterly Groundwater Monitoring will be prepared and submitted to CSSA and AFCEE.
Groundwater Monitoring
The next quarterly groundwater monitoring event will be conducted in June 2003. The upcoming event will include the existing CSSA drinking water and monitoring wells, approximately 25 off-post wells (VOCs only), and any newly completed and developed monitoring wells. On- and off-post quarterly sampling will be funded under TO 0042 in June 2003. O&M at the residential GAC filtration systems (LS-6, LS-7, OFR-3, RFR-10, and RFR-11) and on public water supply systems (LS-2/LS-3) will be conducted monthly during Quarter 17. In addition, the Annual Groundwater Monitoring Report will be submitted.
Building 90/AOC-65 Investigation
Additional data collection at AOC-65 will be conducted in Quarter 17. Based on discussions of data collection needs, data collection for the groundwater recharge study will begin in Quarter 17 (pending occurrence of significant rainfall events).
Well Installations
Work will continue with the on-post well installation funded under TO 0042. Installation of Westbay-equipped wells will proceed in the next quarter.
SWMU B-3
Phase 1 excavation activities at SWMU B-3, completed during Quarter 15, expended the original budget to dispose of the hazardous (metals) and non-hazardous waste excavated and stockpiled from the SWMU B‑3 east trench. Phase 2, when funded, will continue efforts for the remaining hazardous and non-hazardous material within the west trenches, which will complete the SWMU B-3 IRA. Additional excavation activities at SWMU B-3 were halted pending funding. However, planning of an SVE pilot test and continued soil vapor phase removal actions in the vadose zone at SWMU B-3 will continue in Quarter 17.
AOC-55 Excavation
The removal action will be re-initiated during Quarter 17. It is estimated that approximately 35,000 cubic yards of Class 2 Non-Hazardous waste will be excavated and disposed. Additionally, a low-water crossing will be completed near AOC-55 at Salado Creek. Prior to waste excavation work, confirmation sampling will be conducted in order to close AOC-55 under Risk Reduction Standard 1.
SWMU and AOC RFI/Closure Reports and Planned Closure Projects
Continued preparation and submittal of final RFI and Closure reports will be conducted in Quarter 17. Work will continue in Quarter 17 on the draft RFI report for SWMU B-23A, as well as, the Final RFI/Closure report for SWMU B-10 which will be submitted to the TCEQ. Addenda to the RFI Reports will be submitted to document results of additional surface soil sampling at SWMUs B-8, B-34, and Building 43. An addendum to the I-1 RFI report and the Final RFI/Closure report for SWMU Bldg 40 will be submitted after the recommended pressure washing activities are conducted. Pressure washing at I-1 and Bldg 40 will be conducted following pressure washing at Building 90. In addition, it is anticipated that closure work recommended in the RFI Reports will be initiated at several SWMUs and AOCs during Quarter 17.
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 and presented in the Introduction to the Quarterly Groundwater Monitoring Program, Volume 5 Groundwater. Reports for each previously conducted quarterly monitoring event are also located in Volume 5 Groundwater, behind the On-post Groundwater Monitoring and Off-post Groundwater Monitoring tabs. Copies of these reports and analytical data are presented separately to the USEPA by electronic version on CD Rom, at the request of the USEPA. The CD Rom has been delivered to the USEPA three weeks following the submittal of each quarterly progress report.
Preliminary groundwater data for the March 2003 sampling event (on- and off-post) were received by Parsons in Quarter 16. Various screening data packages were received under TO 0042 and TO 0009 delivery orders. SWMU investigation data packages were received under RL17 and RL83. These data packages were verified by Parsons’ chemists during this quarter and will be submitted to AFCEE for approval during Quarter 17.
In addition, an Annual Groundwater Monitoring report for 2002 was drafted during Quarter 16 and will be submitted to CSSA for review during Quarter 17. The Annual Report will provide a more detailed evaluation of historical groundwater trends and include information on the off-post GAC systems, preliminary findings from the recharge study and conceptual site model (CSM), and recommendations for additional work or scope modifications.
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 will depend 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 TCEQ, 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 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 69 percent complete.
Summary of Findings
As described in Task III, 45 draft and 44 Final RFI reports have been completed and submitted to CSSA. 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 final reports submitted through Quarter 16, 18 were recommended for closure while the remaining sites may require future investigation and or cleanup. Through April 30, 2003, a total of 17 SWMUs or AOCs have been approved by TCEQ for closure.
Summary of Changes
No changes associated with the Investigative Analysis were made during this reporting period.
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.
No actions to correct problems were necessary during this reporting period.
Continued work on comparison of investigation results to closure criteria will be performed.
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
Funded activities include bench-scale treatability studies for SWMU B-20 and SVE and other treatability studies for treatment of soils at AOC-65 if further contamination exists. Data collection activities were discontinued on the SWMU B-3 SVE treatability study, since the original system installed in 1996 was removed for the soil disposition activities.
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 16. O&M activities on the PIMS study site included leachate monitoring efforts (includes sampling of lysimeters in August, September, October and December 2002) and maintenance activities. Monitoring of the field treatment efforts is expected to continue through May 2003. Monitoring data are anticipated to support similar closure/remediation efforts at sites with similar contaminants of concern.
The SWMU B-3 SVE O&M assessment report was finalized in Quarter 16. Its recommendations formed the basis for additional SVE treatability testing of fractured bedrock underlying SWMU B-3. The Final SVE system assessment report was submitted in Quarter 16 for inclusion into the Environmental Encyclopedia.
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 33 percent complete.
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. The SVE system at SWMU B-3 was removed during the initial soil removal actions.
Summary of Changes
No changes associated with the treatability studies occurred during this reporting period.
Revisions to the scope of work proposed by University of Texas at San Antonio (UTSA) for characterization of contaminant migration near AOC-65 were presented to CSSA and Parsons TO 0058 project manager on August 23, 2002. CSSA continued to consider some of the studies proposed by UTSA during Quarter 16. CSSA and Parsons are awaiting additional proposals.
Summary of Problems
No problems related to the PIMS treatability studies occurred during this reporting period.
No actions to correct problems were necessary during this reporting period.
No additional O&M testing will occur at the SWMU B-3 SVE system since it was removed during this quarter as part of the site removal action. Data collection and O&M began at the AOC-65 SVE during quarter15 and will continue into the future.
Monitoring and bioassessments of SWMU B-20 PIMS-treated soils for the PIMS treatability study is expected to continue during Quarter 17. Additionally, field scale treatability studies of PIMS for the previously sifted soil piles will continue in Quarter 17 as part of the treatability activities for the soil pile disposition assessment.
No analytical data are 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 is partially funded. Five progress reports (January 2003 – January 2004) are currently funded under TO 0079.
Percent Complete
This task makes up approximately 5 percent of the RFI phase. The percent complete is unknown because the number of quarterly progress reports needed is currently unknown; however, it is estimated to be approximately 15 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.
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.
No actions to correct problems were necessary during this reporting period.
The Progress Report for Quarter 17 will be submitted.
No daily reports, inspection reports, or data related to the Progress Reports were generated during this reporting period.