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I/SMs are being conducted to mitigate a current or potential threat to human health and/or the environment. I/SMs are estimated to represent approximately 30 percent of the required actions at CSSA. The I/SMs include I/SM WP (7 percent of IM), I/SM Implementation (70 percent of IM), and Reports (23 percent of IM). Based on information currently available at the end of Quarter 22, the I/SMs are approximately 73 percent complete.
Task I: Interim/Stabilization Measures Work Plan
The I/SMs WP include:
A description of on‑going and planned I/SMs;
A statement of the objectives of each I/SM, including how the measure mitigates a potential threat to human health and the environment and is consistent with and integrated into any long‑term remedy for CSSA; and
Proposed locations, design plans and specifications, construction, and operation and maintenance (O&M) requirements of the I/SMs, including a sampling and analysis plan (SAP).
Existing plans, included in the CSSA’s Environmental Encyclopedia, are referenced to the extent possible.
I/SMs include initial sampling and analysis of groundwater from off‑post wells; sampling and analysis of groundwater in CSSA wells; identification of all off‑post water wells located within ¼‑mile of the facility boundary; evaluation of alternative measures and implementation of selected I/SMs at SWMU O‑1; closure of SWMU O‑1; characterization and determination of proper disposition of soil piles at SWMUs B‑8, B‑20, B‑24, B‑28, and the Demolition Dud (DD) Area; and implementation of the identified disposition method. Of the tasks listed, all have been completed with the exception of the soil pile work. In addition, continuation of on‑ and off‑post groundwater sampling and analysis is being performed under the RFI phase of this project.
The Final Soil Pile Disposition Assessment (SPDA) Report was submitted in August 2003. A proposed disposition method of phosphate stabilization and on‑ and off‑post disposal was identified in the assessment. A Treatability Study/field demonstration of the proposed remedy was completed in January 2004. However, implementation of the disposition is not fully funded. To date, the soil pile at SWMU DD (approximately 2,230 yd3) was removed and properly disposed of between December 2003 and May 2004 at Covel Gardens Landfill, San Antonio, Texas. Due to the volume of soil (estimated at approximately 6,700 yd3) remaining at the other four sites and the need to address other more urgent environmental concerns, it is anticipated that funding may be spread over several years.
No activities associated with the I/SM WP were conducted this quarter.
The I/SM WP task makes up approximately 7 percent of the I/SM phase and is 100 percent complete, based on the interim measures defined in the 3008(H) Administrative Order on Consent, located in Volume 1, Scoping Documents. Other investigation activities to be conducted are further discussed under RFI Activities, Investigation, Treatability Studies, etc., in the sections below. If further I/SM WPs are added to the scope of work (SOW) in the future, the percent complete as stated will be adjusted.
Task II: Interim/Stabilization Measures Implementation
SWMU O‑1 I/SMs and Closure (complete) – The Texas Commission on Environmental Quality (TCEQ) approved closure of the land‑based portion of SWMU O‑1 on December 3, 2001. Further investigation and possible remediation of the vadose zone and groundwater beneath SWMU O‑1 will be conducted in future quarters. This I/SM task is complete.
Initial On‑ and Off‑Post Groundwater Sampling (complete) – Periodic sampling of on‑post wells was initiated in 1991. Off‑post water sampling began in 1995. Quarterly sampling of both on‑ and off‑post wells began in 1999. This I/SM task is complete. Quarterly groundwater monitoring continues as part of the RFI task.
Off‑post Well Survey (complete) – The final report was issued in August 2001 and is located in Volume 5, Groundwater of the Environmental Encyclopedia. This task is complete.
SPDA and Implementation (in progress) - Soils from SWMU B-28 are scheduled for treatment and removal actions during the Quarter 23. The remaining soils will be addressed as funding permits and include material from SWMU B-24 and SWMU B-8. Soils from SWMU B‑20 are already being addressed under the PIMS Stabilization Treatability Study (Task VI, RCRA Facility Investigation) through ESTCP funding.
The I/SM Implementation task makes up approximately 70 percent of the I/SM phase. This task is considered 63 percent complete, based on the current projected activities listed in Task II, Task Description. If investigation results at other sites indicate an immediate threat to human health or the environment which warrant an IM, the percent complete will be adjusted accordingly.
No new findings this quarter.
No changes associated with I/SM implementation occurred this Quarter.
No contacts occurred during this Quarter.
No problems were encountered this Quarter.
No actions were taken to correct problems this Quarter.
CSSA will continue with O&M activities for SWMU O‑1 until a final remedy for the associated vadose and groundwater zone is complete. The continued O&M activities include maintaining the vegetative cover.
Monitoring of leachate generated at the test sites and maintenance of vegetative cover at the SWMU B‑20 test site will continue.
There were no reports provided during this quarter related to I/SM.
Task III: Reports
Reports associated with the I/SM include quarterly progress reports, environmental cleanup reports, groundwater monitoring reports from one sampling event, and an I/SM report. This quarterly progress report is submitted as part of this task.
Reports required under the I/SM section of the Order are submitted in three phases. The first phase is a baseline report, the second phase consists of progress reports, and the third phase is a final report upon completion of the project. This quarterly progress report fulfills the requirement for an I/SM progress report for activities including long‑term operation, maintenance, and monitoring at CSSA.
I/SM activities are reported in this quarterly progress report. There were no final reports for the I/SM portion of work generated this quarter.
This task makes up approximately 23 percent of the I/SM phase. This task is approximately 96 percent complete based on the current projected activities listed in Task III, Reports. If investigation results at other sites indicate an immediate threat to human health or the environment so that I/SM activities are required at additional sites, the percent complete will be adjusted accordingly.
No findings associated with progress reports or I/SM reports are submitted this Quarter.
No changes associated with progress reports or I/SM reports occurred this Quarter.
No contacts related to quarterly progress reports or I/SM Reports were made during this Quarter.
No problems were associated with I/SMs reporting this quarter.
No actions to correct problems associated with I/SM reporting were necessary this Quarter.
I/SM activities in Quarter 22 will be reported in the next Quarterly Progress Report.
No daily reports, inspection reports, or data related to the I/SM report were generated this Quarter.