18th 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, identify actual or potential receptors, and to assess whether any additional I/SM 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 18, the RFI is approximately 41 percent complete.

Task I - Preliminary Report: Description of Current Conditions

Task Description

This task included preparation of the DCC Report. The DCC Report included 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 was 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 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 DCC were conducted this period.

Task II - RFI Work Plan

Task Description

The Order requires that the RFI WP task 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 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 continued during this quarter. A new task order (TO 0019) which includes field work and reporting with the overall goal of bringing several additional SWMUs and AOCs to closure under the Risk Reduction Standards (RRS) was awarded and initiated in June 2003. A modification to the TO to include additional sites was awarded during Quarter 18. TO 0019 includes SWMUs B-2, B-11, B-12, B-23, B-23A, B-25, B-26, B-29, B-30, B-33, B-34, Building 43, DD Area, AOC-37, AOC-38, AOC-41, AOC-48, AOC-50, AOC-54, AOC-56, AOC-66, and AOC-67. The Environmental Cleanup Plan (ECP) is currently being prepared.

The TO 0058 draft O&M WP for the two SVE systems (subslab and treatability study) installed at AOC-65 was submitted for review in October 2003. O&M activities of the SVE system under TO 0058 are planned to begin during the first week in November upon final approval of the O&M WP.

Draft WP and SAP addenda for the SVE deep pilot study and associated geologic investigations at SWMU B-3 were prepared under RL 83 and submitted to AFCEE and CSSA for review on June 27, 2003. Comments from CSSA were received on August 18, 2003, and the WP addenda were finalized on August 20, 2003.

The TO 0008 draft WPs (WP, HSP and SAP) for continued quarterly groundwater monitoring were submitted September 26, 2003. CSSA comments were received October 14, 2003. These WPs will be submitted as Final during Quarter 19.

1. Percent Complete

The RFI WP 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 new TOs are added. As of the end of Quarter 18, WPs currently under scope are approximately 90 percent complete. The CSSA Environmental Encyclopedia will continue to be updated as WPs are completed and made Final.

2. Summary of Findings

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

3. Summary of Changes

No changes other than those described above in Activities this Quarter to existing RFI WP were made during this reporting period.

4. Summary of Contacts

No contacts occurred during this reporting period.

5. Summary of Problems

No significant problems occurred during this reporting period.

6. Actions Taken to Correct Problems

No actions were taken for any problems during this reporting period.

7. Projected Work for the Next Quarter

WPs for TO 0008, TO 0019 and TO 0058 (SVE O&M WP at AOC-65) will be finalized for submittal in Quarter 19.

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

No daily reports, inspection reports, or data related to the RFI WP task were generated during this reporting period.

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 investigational phases may be necessary. The investigation results will be used to develop and evaluate alternatives during the CSM. 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 3 indicates the sites for which investigations have been funded and subsequently conducted as well as sites that have been identified, but not yet investigated. TO 0019 was modified to fund additional investigations, which will now include SWMUs B-2, B-8, B-11, B-12, B-23, B-23A, B-25, B-26, B-29, B-30, B-33, B-34, Building 43, DD Area, AOC-37, AOC-38, AOC-41, AOC-48, AOC-50, AOC-54, AOC-56, AOC-66, and AOC-67. Future TOs and/or modifications will address investigations at remaining sites. The scope under RL83 was modified to conduct an additional SVE pilot test at SWMU B-3.

Activities this Quarter

The majority of current ongoing environmental activities at CSSA are part of the RFI task. 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) wellhead treatment systems, analytical data verification and validation, RFIs and closures of selected SWMUs and AOCs, well installations, Building 90/AOC-65 investigations, SWMU B-3 SVE system, AOC-55 remediation activities and various miscellaneous tasks.

Groundwater Monitoring

Sampling of all on-post and selected off-post wells is conducted quarterly. Off-post wells were sampled from September 8-11, 2003. Twenty-seven private and public off-post drinking water wells were sampled, including FO-J1, HS-2, I10-2, I10-4, JW-7, JW-8, JW-9, JW-14, JW-26, JW-28, JW-29, JW-30, LS-1, LS-2, LS-3, LS-4, LS-5, LS-6, LS-7, OFR-1, OFR-2, OFR-3, OFR-4, RFR-9, RFR-10, RFR-11, and RFR-12. All samples were collected from ports located near the wellhead. Eight samples were collected after treatment by the well’s GAC filtration system. These post-GAC samples were collected from wells LS-2, LS-3, LS-6, LS-7, OFR-3, RFR-10 (two GAC units), and RFR-11. The locations of these wells are shown on Figure 1.0 in Attachment 2. Samples were analyzed for the approved short list of VOCs by Agriculture & Priority Pollutants Laboratories, Inc. (APPL). The VOC short list includes 1,1-dichloroethene, bromodichloromethane, bromoform, chloroform, cis-1,2-dichloroethene (DCE), dibromochloromethane, dichlorodifluoromethane, methylene chloride, naphthalene, tetrachloroethene (PCE), trichloroethene (TCE), toluene, trans-1,2-dichloroethene, and vinyl chloride. Preliminary data on these samples were received on October 1 and 3, 2003 by Parsons. Data validation and verification for these samples were initiated this Quarter.

Quarterly groundwater monitoring of 40 on-post monitoring and/or drinking water wells was performed from September 15-25, 2003. CSSA wells CS-MW1-LGR, CS-MW1-BS, CS-MW1-CC, CS-MW2-LGR, CS-MW2-CC, CS-MW3-LGR, CS-MW4-LGR, CS-MW5-LGR, CS-MW6-LGR, CS-MW6-BS, CS-MW6-CC, CS-MW7-LGR, CS-MW7-CC, CS-MW8-LGR, CS-MW8-CC, CS-MW9-LGR, CS-MW9-BS, CS-MW9-CC, CS-MW10-LGR, CS-MW10-CC, CS-MW11A-LGR, CS-MW11B-LGR, CS-MW12-LGR, CS-MW12-BS, CS-MW12-CC, CS-MW16-LGR, CS-MW16-CC, CS-MW17-LGR, CS-MW18-LGR, CS-MW19-LGR, CS-1, CS-2, CS-4, CS-9, CS-10, CS-11, CS-D, CS-MWG-LGR, CS-MWH-LGR, and CS-I were sampled. Locations of the on-post wells sampled are shown on Figure 1.0 in Attachment 2. Samples were analyzed by Severn Trent Laboratories (STL) for the approved short list of VOCs. One newly installed monitoring well (CS-MW16-CC) was sampled for the full list of VOCs, the metals barium, chromium, copper, nickel, zinc, mercury, arsenic, cadmium and lead, and cations, anions, carbonate and alkalinity. The preliminary data were received by Parsons October 17 - 20, 2003. Data validation for VOCs, metals, and cations and anions was initiated this Quarter.

The Final Off-post Quarterly Groundwater Monitoring and Final On-post Quarterly Groundwater Monitoring Reports for June 2003 were added to the Environmental Encyclopedia this Quarter. The Draft September Quarterly Groundwater Monitoring Reports were prepared during Quarter 18.

In addition, preparation of an Annual Groundwater Monitoring Report was continued during Quarter 18. This first annual report will include an analysis of all quarterly groundwater monitoring results, with a focus on the quarterly events conducted through June 2003.

Data Quality Objectives (DQOs) for the Groundwater Investigation are currently being reviewed internally and will be revised. The revised DQOs will replace the previous version dated April 2002.

Off-Post GAC Systems

Based on previous sampling results indicating VOC levels above or approaching the maximum contaminant level (MCL), GAC filtration systems were installed at seven off-post wells. In accordance with the CSSA Off-post Monitoring Program Response Plan dated June 2002 (the Plan), the off-post GAC wellhead treatment systems installed at these wells are maintained by CSSA. Monthly O&M activities for the off-post residential GAC treatment systems were performed this quarter. Work included inspection and replacement, as needed, of the pre- and post-GAC micron filters at wells LS-6, LS-7, RFR-10, RFR‑11, and OFR‑3. Confirmation post-GAC samples were collected from these wells and LS-2/LS-3 during September 2003. No post-GAC samples had concentrations above the method detection limit (MDL) for PCE, TCE, or cis-1,2-DCE during the September event.

Carbonair reviewed contaminant levels entering the LS-2/LS-3 GAC system and the volume of water treated to date. Based on the data reviewed and the low-levels of VOCs that are generally found in these wells, it was determined that the 10-month change out at this GAC, which was due October 2003, could be postponed to a later date.

Data Validation and Verification

Laboratory results from sampling efforts and investigations are validated and verified by Parsons’ chemists to ensure results are in compliance with CSSA QAPP requirements. Data validation and verification continued during Quarter 18 under CSSA projects, TO 0008, 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 18 (the September 2003 quarterly sampling event). Additional data packages related to Westbay^® equipped wells groundwater sampling, investigation derived waste (IDW), screening samples, waste characterization, and investigations at SWMUs BLDG 43 and B-34 were also generated. Verification of these data packages continued during Quarter 18. AFCEE chemists approved data package groups TO42 Groups S and U and RL74 Group L this Quarter.

RCRA Facility Investigations of SWMUs and AOCs

A total of 84 SWMUs, AOCs, and Rifle Management Units (RMUs) have been identified at CSSA and investigations have been conducted at 59 of those sites. A summary of the status of each site, including whether the site is recommended for closure or if closure is approved, is provided in Attachment 3. The Closure Report for SWMU Building 40 was also submitted during this quarter.

CSSA received comments from TCEQ on the closure report for SWMU B-10 during Quarter 18. CSSA and Parsons met with the TCEQ to discuss the comments on June 17, 2003. Formal responses to the comments were submitted on October 17, 2003. The TCEQ comments concerned confirmation sample results at two sample locations, groundwater investigations near SWMU B-10, confirmation samples from the bedrock/soil contact below an excavated solvent drum, and pertinent laboratory analytical reports. After field and analytical work is complete, a revised closure report for SWMU B-10 will be submitted.

Identification of possible unexploded ordnance (UXO) was conducted at SWMUs B-2 and B-8 during this quarter. At B-2, all soil that had been previously excavated from two trenches on site was sifted to remove any ordnance-related material, as well as other metal scrap. UXO specialists oversaw the sifting operation. In addition, a third trench was identified during the field work. The material in this trench was also excavated and sifted for UXO removal. At B-8, numerous anomalies were identified in the area surrounding the B-8 boundary during the spring 2003 geophysical surveys of the area. Three ordnance items were identified on the ground surface at that time. In September 2003, several remaining anomalies were investigated to determine if any were ordnance-related. No additional ordnance items were identified during the September 2003 excavations at SWMU B-8.

Well Installations

There are currently 37 drinking water, livestock, and monitoring wells at CSSA. TO 0042 funded the installation of 16 new monitoring wells: 10 wells to be completed in the Upper and Lower Glen Rose Formation (including four Westbay^®-equipped wells), two in the Bexar Shale, and four 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 18, the well upgrades and the installation of the 16 new monitoring wells under TO 0042 were complete.

Installation of Westbay^®-equipped wells continued this Quarter. Westbay^® Instruments mobilized field personnel to CSSA August 18, 2003, after the final component design of the modular systems was finalized by CSSA, Parsons and Westbay^®. A total of one Upper and ten Lower Glen Rose zones each were selected for CS-WB01-LGR, CS-WB02-LGR, and CS-WB03-LGR. Sixteen zones (one Upper Glen Rose, ten Lower Glen Rose, two Bexar Shale, and three Cow Creek) were selected for monitoring within CS-WB04-LGR, which penetrates the entire thickness of the Middle Trinity aquifer. The actual well installations were started on August 19, 2003, and were completed August 27, 2003. At each location a FLUTe liner was installed after drilling was complete to decrease or reduce the potential for vertical migration of contaminants. These liners were removed to allow geophysical logging and well development prior to installation of the Westbay^® completions. Training for the use of the Westbay^® monitoring equipment was given to CSSA, Parsons, and Portage Environmental staff on August 28-29, 2003.

The first three rounds of sampling from the Westbay^® multi-level wells were conducted during the weeks of September 8, October 6, and October 20, 2003. Each well was hydraulically profiled by zone and discrete samples were collected from groundwater-bearing intervals. The samples were submitted to DHL Analytical for VOC analysis.

The upgrade of well CS-I was performed during this reporting period. The existing windmill mechanism had failed, resulting in the inability to obtain samples from this well. The downhole windmill mechanism was removed by GeoProjects International, and replaced with an electric submersible pump. The well was also geophysically logged by GeoCam, Inc. Since the well is in a remote location without electrical service, a solar panel array was installed to power the pump. This renewable energy source allows the pump to run continuously during the daylight hours, filling both a water trough and an earthen stock pond.

Additional well development was performed at CS-MW18-LGR and CS-MW2-LGR after the quarterly sampling efforts indicated that pH levels were elevated in those wells. The wells were purged with a high-capacity submersible pump until natural groundwater conditions were restored. The purged groundwater at CS-MW2-LGR was contained and treated at the Outfall 002 GAC unit.

Because testing indicated low levels of VOC contamination, groundwater and drilling fluids produced during drilling efforts at the Westbay^® locations were contained and treated at the CSSA GAC unit and discharged at Texas Pollutant Discharge Elimination System (TPDES)-permitted Outfall 002. Parsons operated and maintained the GAC unit, and prepared a Discharge Monitoring Report (DMR) each month to comply with TPDES requirements. Through October 2003, nearly 100,000 gallons of water containing VOCs was treated by GAC and discharged from Outfall 002 during Quarter 17. Since the drilling project is drawing to a close, Parsons is currently coordinating for the testing, disposal, and replacement of the activated carbon canisters located at the GAC unit.

Building 90/AOC-65 Investigation

Parsons completed the update of the permit by rule (standard air exemption) and submitted the update to TCEQ during Quarter 18.

The groundwater recharge study was continued under TO 0058 during Quarter 18, but no groundwater samples were collected because no rainfall events of sufficient magnitude triggered the need to collect samples. Parsons continued to perform maintenance on the dessicators for the transducers, and conducted a site visit on September 23 - 24, 2003, to purge the six piezometers to assess the origin of the water present. Based on observations, it was apparent that the deep piezometers (screened at approximate depths of 90-130 feet below grade) are screened in a perched formation that recovers quickly with formation water, whereas the shallow piezometers (upper 40 feet of formation) contain little formation water as evidenced by poor recoveries. All purge water from the piezometers development effort was treated at the CSSA GAC system prior to discharge.

Parsons completed preparation of the SVE O&M Manual for the two systems currently operating at AOC-65, and prepared to initiate the six-month O&M period funded under TO 0058 in early November 2003.

Removal actions at AOC-55 were continued during Quarter 18. Approximately 35,000 cubic yards of soil were sifted for removal of ordnance and explosive scrap material, which is expected to be demilled and sent as scrap metal for recycling. The class 2 non-hazardous soil is being transported and disposed of at the Waste Management, Inc., Covel Gardens facility. The removal effort at AOC-55 is expected to be completed during Quarter 19.

Removal actions were continued at AOC-55 in Quarter 18. Approximately 649 ordnance/explosive (O/E) scrap items have been discovered at AOC-55, many found at depths greater than two feet. The O/E items include 75mm projectiles, 155mm projectiles, rocket propelled grenades and Stokes mortars. Approximately 20 of the items of UXO may still contain high explosive filler; however, none were found to be fused.

Removal actions were conducted by mechanical sifting to effectively remove all O/E scrap items and ensure UXO material is properly identified. Use of a mechanical sifting method of O/E removal will insure that all items greater than two inches in size will be removed.

Miscellaneous

Preparation of the hydrogeologic conceptual site model (CSM) funded under RL83 continued during Quarter 18. Work on the CSM focused on the AOC-65 area in preparation for the installation of multi-level monitoring points (Westbay^®-equipped wells) in the vicinity of Plume 2. Detailed cross-section stratigraphic analysis was 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 Final Well Installation Report for cluster wells installed under RL83 was completed during Quarter 17.

Fact Sheet 15, summarizing the findings of the June 2003 quarterly groundwater monitoring event, was mailed to area residents in September 2003. Letters summarizing the results of the June 2003 off-post groundwater monitoring were mailed to the owners of the off-post wells on September 12, 2003. Preparation of Fact Sheet 16, summarizing the findings of the September 2003 quarterly groundwater monitoring event were initiated this Quarter. The draft Fact Sheet 16 and draft letters to the well owners will be submitted to CSSA for review during Quarter 19.

The CSSA website was updated with documents added to the Environmental Encyclopedia through the end of September 2003. The website includes CSSA’s Administrative Record.

Parsons personnel provided LAN support during Quarter 18. Parsons personnel performed general LAN maintenance including service and security patch installations. Parsons upgraded the proxy server from Microsoft Proxy Server 2.0 to Microsoft ISA. An upgrade of the firmware of the Cisco PIX 515E firewall to version 6.3(3) was conducted. Parsons installed two new workstations and re-located essential software applications, documents and settings to the new workstations within the CSSA Environmental Office. Parsons GIS and LAN personnel assisted with produced of poster sized aerial photographs as requested by CSSA. Parsons additionally provided support for creation of a presentation on the CSSA Environmental GIS Program. Parsons also provided support for GSA pricing quotes for additional software to be purchased.

1. Percent Complete

The Facility Investigation task makes up approximately 45 percent of the RFI phase. As of the end of Quarter 18, this task is approximately 25 percent complete.

2. Summary of Findings

Groundwater Monitoring

Quarterly groundwater monitoring for both on- and off-post wells was performed at CSSA from September 8-25, 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 September 2003.

On-post Wells, September 2003: Forty on-post monitoring and/or drinking water wells were sampled, including CS-MW1-LGR, CS-MW1-BS, CS-MW1-CC, CS-MW2-LGR, CS-MW2-CC, CS-MW3-LGR, CS-MW4-LGR, CS-MW5-LGR, CS-MW6-LGR, CS-MW6-BS, CS-MW6-CC, CS-MW7-LGR, CS-MW7-CC, CS-MW8-LGR, CS-MW8-CC, CS-MW9-LGR, CS-MW9-BS, CS-MW9-CC, CS-MW10-LGR, CS-MW10-CC, CS-MW11A-LGR, CS-MW11B-LGR, CS-MW12-LGR, CS-MW12-BS, CS-MW12-CC, CS-MW16-LGR, CS-MW16-CC, CS-MW17-LGR, CS-MW18-LGR, CS-MW19-LGR, CS-1, CS-2, CS-4, CS-9, CS-10, CS-11, CS-D, CS-MWG-LGR, CS-MWH-LGR, and CS-I. Samples were analyzed by STL. Results of the September 2003 groundwater monitoring event will be formally reported in the draft September 2003 Quarterly Groundwater Monitoring Report to be submitted to CSSA and AFCEE for review and comments during Quarter 19.

Off-post Wells, September 2003: Twenty-seven private and public off-post drinking water wells were sampled, including FO-J1, HS-2, I10-2, I10-4, JW-7, JW-8, JW-9, JW-14, JW-26, JW-28, JW-29, JW-30, LS-1, LS-2, LS-3, LS-4, LS-5, LS-6, LS-7, OFR-1, OFR-2, OFR-3, OFR-4, 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 the draft September 2003 Quarterly Groundwater Monitoring Report to be submitted to CSSA and AFCEE during Quarter 19.

Building 90/AOC-65 Investigation

Results from well purging activities indicated that the deeper piezometers installed for the shallow groundwater study are screened in a more stable “perched” water zone, whereas the shallower piezometers act as sumps for transient recharge water. Any future accumulations in the shallow piezometers can be directly attributable to rainwater recharge. No significant rainfall events occurred during Quarter 18 that would trigger sample collection for the groundwater recharge study. There is no new analytical data available for review for Quarter 18. Observations from the purging activities will be presented in the Treatability Evaluation Report prepared under TO 0058.

3. Summary of Changes

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

4. Summary of Contacts

A technology demonstration was held on August 22, 2003, at the CSSA Environmental Offices. Parsons and Westbay^® personnel assisted in preparation for the technology demonstration, conducted to showcase work performed to date at CSSA by the U.S. Government, CSSA, Parsons, GeoProjects, COLOG, and Westbay^®. Attendees at the technology demonstration included local aquifer authority representatives, local groundwater purveyors, AFCEE representatives and consulting firms. Parsons and Westbay^® personnel assisted with slide presentations and field demonstrations.

Results from the June 2003 quarterly groundwater monitoring event were mailed to each off-post well owner. In addition, CSSA received various letters from the TCEQ during Quarter 18. On July 30, 2003, the TCEQ requested additional information regarding the off-post analyte list being sampled. CSSA provided a response on September 24, 2003. On August 15, 2003, TCEQ requested additional information regarding the SWMU B-32 Closure Report. A response was sent on September 5, 2003. On August 20, 2003, TCEQ requested additional information regarding the SWMU B-10 report; a response was sent on October 17, 2003. Finally, on August 21, 2003, TCEQ sent a letter regarding perchlorate analyses. Copies of all correspondence are included in Volume 1-1 of the Environmental Encyclopedia.

5. Summary of Problems

No significant problems were encountered during the reporting period.

6. Actions Taken to Correct Problems

No actions beyond those previously reported for the data package review and approval process have been taken to correct problems.

7. Projected Work for the Next Quarter

Fact Sheets

Fact Sheet 16, summarizing the findings of the September 2003 Quarterly Groundwater Monitoring will be prepared and submitted to CSSA and AFCEE. After approval, the fact sheet will be distributed to area residents.

Groundwater Monitoring

The next quarterly groundwater monitoring event will be conducted in December 2003. The upcoming event will include the existing CSSA drinking water and monitoring wells, approximately 25 off-post wells (VOCs only). On- and off-post quarterly sampling will be funded under TO 0008 in December 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 19.

The Westbay^® wells will be profiled twice a month and sampled once per month for the foreseeable future monitoring frequencies may be modified based on the occurrence of significant rainfall.

Building 90/AOC-65 Investigation

SVE and shallow groundwater recharge data collection at AOC-65 will be continued in Quarter 19. Implementation of the AOC-65 SVE O&M Plan will be initiated upon approval, and consists of data collection activities specified in the plan. These activities include quarterly soil gas monitoring of individual well-head contributions, monthly soil gas and pressure monitoring of vapor monitoring points, and twice monthly system checks to ensure that the system operation is functioning as designed. Maintenance activities consist of checking that the blower is operational, managing accumulated water in the moisture knockout pots, and monitoring system performance parameters.

Parsons will continue to coordinate with CSSA following significant rainfall events as to the necessity to initiate additional shallow groundwater sampling from the study’s six piezometers. Water level and conductivity data for four of the six piezometers will continue to be downloaded on a monthly basis.

Well Installations

Finalization of well surface completions funded under TO 0042 will continue next Quarter. Installation of TO 0042 wells will be complete in the next quarter.

AOC-55 Excavation

The removal action will continue during Quarter 19. It is estimated that approximately 35,000 cubic yards of Class 2 Non-Hazardous waste will be excavated and disposed. Confirmation sampling will be conducted in order to close AOC-55 under RRS1.

SWMU and AOC RFI/Closure Reports and Planned Closure Projects

Closure work recommended in previous RFI Reports will be initiated at several SWMUs and AOCs during Quarter 19.

8. 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 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 EPA by electronic version on CD Rom, at the request of the EPA. The CD Rom has been delivered to the EPA three weeks following the submittal of each quarterly progress report.

Preliminary groundwater data for the September 2003 sampling event (on- and off-post) were received by Parsons during Quarter 18. Various screening data packages were received under TO 0042, TO 0058 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 19.

The Annual Groundwater Monitoring report for 2002 continued to be drafted during Quarter 18 and will be submitted to CSSA for review during Quarter 19. 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 CSM, and recommendations for additional work or scope modifications.

The laboratory audit findings were forwarded to APPL on July 17, 2003, and APPL’s responses were received on September 5, 2003. CSSA/AFCEE/Parsons comments were forwarded to APPL on September 26, 2003 with request for further information and/or documentation to be submitted by October 31, 2003.

Task IV - Human Health and Ecological Risk Assessment

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 the 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 post-wide 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 and is currently estimated at 30 percent.

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 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. New TO 0019 seeks closure of SWMUs and AOCs under the RRS.

Activities this Quarter

No activities related to Investigation Analysis this quarter.

1. Percent Complete

The Investigation Analysis task makes up approximately 10 percent of the RFI phase, and is approximately 69 percent complete.

2. Summary of Findings

As described in Task III, 49 final RFI reports have been completed and submitted to CSSA and TCEQ. As part of the preparation of these reports, investigation results were compared to closure criteria. A summary of recommendations for each site is provided in Attachment 3. Based on the final reports submitted through Quarter 18, 20 sites were recommended for closure while the remaining sites may require future investigation and/or cleanup. Through October 31, 2003, a total of 17 SWMUs or AOCs have been approved by TCEQ for closure and SWMUs Building 40, B-10, and B-32 are pending TCEQ approval for closure.

3. Summary of Changes

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

4. Summary of Contacts

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

5. Summary of Problems

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

6. Actions Taken to Correct Problems

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

7. Projected Work for the Next Quarter

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

8. 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

Funded activities include bench-scale treatability studies for SWMU B-20, SVE, and other treatability studies for treatment of the subsurface soils and bedrock at AOC-65 and SWMU B-3 if further contamination exists.

Activities this Quarter

As part of the Task II I/SM, a treatability study for stabilization of the excavated soils was continued during Quarter 18. O&M activities on the PIMS study site included leachate monitoring efforts (includes sampling of lysimeters in July 2003) and maintenance activities. Monitoring of the field treatment efforts is expected to continue through September 2003. Monitoring data are anticipated to support similar closure/remediation efforts at sites with similar contaminants of concern.

Soil Gas Sampling

Parsons conducted a soil gas survey of the trenches at SWMU B-3 and SWMU O-1 on September 4 - 5, 2003, under RL83 as part of the SVE pilot study and geologic evaluation. The purpose of the soil gas sampling was to help identify portions of the subsurface where extraction wells and vapor monitoring points should be located for the pilot study. A total of 15 soil gas samples were collected and screened for total volatile hydrocarbons (TVH), oxygen, and carbon dioxide from the two adjacent SWMUs, and four samples were collected for off-site laboratory testing based on the screening results. Only low levels of VOCs were encountered in the sample collected in the vicinity of SWMU O-1, but it was located farther from the pond than desired due to wet soil conditions at the time of the sampling. Significantly higher levels of TCE at concentrations of 168 parts per million volume (ppmv) were encountered at SWMU B-3 with the highest contaminant levels located on the eastern edge of the western trenches. Based on these results, the locations for two extraction wells and two vapor monitoring wells were determined. Results from the soil gas testing will be presented in the SVE Pilot Study and Preliminary Geologic Investigation Report for SWMU B-3.

SWMU B-3 SVE System

Additional subsurface investigations at SWMUs B-3 and O-1 and an SVE Pilot Study at SWMU B-3 were initiated under RL83. This work will focus on remediation of chlorinated hydrocarbons from vadose zone fractured bedrock underlying the SWMU B-3 trench. The soil gas investigation for this study was completed in September as described above. Drilling of the initial extraction well and soil gas/groundwater packer test sampling was initiated on October 22, 2003, and should be completed in early November.

1. Percent Complete

The Treatability Studies 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 38 percent complete.

2. 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.

SWMU B3 Preliminary Geologic and SVE Pilot Study Investigation

Soil gas sample results from the preliminary investigation will be presented in the SVE pilot study report prepared under RL83. The soil gas data provided excellent information that was utilized for selecting extraction and vapor monitoring points for the SVE pilot test based on contaminant concentration data. Essentially, very low oxygen levels (less than 1.0%) and high TVH levels (91-446 ppm) were indicated in all four soil gas samples collected from the eastern trench, somewhat higher oxygen levels in the samples collected from the western SWMU B-3 trench that is not yet excavated. The highest TCE reading was measured in one of the soil gas points located on the east of the western trench at 168.367 ppmv, whereas the highest cis-1,2-DCE reading was measured in one of the eastern trench soil gas points at 517.645 ppmv.

3. Summary of Changes

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

4. Summary of Contacts

Revisions to the scope of work proposed by University of Texas at San Antonio (UTSA) for characterization of contaminant migration near AOC-65 were submitted in a previous Quarter. CSSA continues to consider the studies proposed, but no plans are currently ongoing to conduct any of the proposed work during the next Quarter.

5. Summary of Problems

No problems related to the PIMS treatability studies occurred during this reporting period.

6. Actions Taken to Correct Problems

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

7. Projected Work for the Next Quarter

Data collection and O&M at the AOC-65 and SWMU B-3 SVE systems will continue into the future.

Field scale treatability studies of PIMS for the previously sifted soil piles will continue in Quarter 19 as part of the treatability activities for the soil pile disposition assessment. Because this work is associated with the soil piles, it is included in the Interim Measures description.

SWMU B-3 SVE System

Parsons will complete the construction of the SVE pilot test system and the subsurface geologic investigation at SWMU B-3 in Quarter 19. Following completion of the construction, initial pilot testing activities will be performed, and a report of the findings will be issued for AFCEE and CSSA review.

8. 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. Four progress reports (January 2003 – November 2003) are currently funded under TO 0079, and five (December 2003 – January 2005) are funded under task order TO 0005.

1. Percent Complete

The Progress Reports 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 14 percent complete.

2. Summary of Findings

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

3. Summary of Changes

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

4. Summary of Contacts

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

5. Summary of Problems

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

6. Actions Taken to Correct Problems

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

7. Projected Work for the Next Quarter

The Progress Report for Quarter 19 will be submitted.

8. 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.

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