22nd Quarter - 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 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 22, the RFI is approximately 43 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 on the report were received. 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 Quarter.

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 information required by the Order. Completion of this task is funded for the planned RFI tasks.

Activities this Quarter

TO 0011, including installation and programming of the Supervisory Control and Data Acquisition (SCADA) system at CSSA, was awarded in September 2004. Preparation of WPs for completion of the SCADA installation was initiated this period, including a WP addenda, a HSP addenda (for construction services), a construction quality assurance plan, and an implementation WP. A proposed schedule for project activities was also prepared during the subject‑reporting period. Most of the WP preparation activities were performed following the project kick‑off meeting held on October 20, 2004. The primary purpose of TO0011 is to complete the design and installation of a SCADA system to provide real‑time remote monitoring of buildings, meteorological monitoring facilities, other miscellaneous infrastructure locations, environmental monitoring locations, such as monitoring wells, and to monitor and control drinking water pumping and treatment facilities.

A new task order, TO 0006, was also awarded during this Quarter. TO0006 provides for construction of an outfall reuse system, aboveground storage tank upgrade, and continued remedial actions and studies at SWMU B‑3 and AOC-65. Preparation of WPs for TO 0006, including WP addenda, SAP addenda, HSP addenda, and a construction quality plan were initiated this Quarter. Preparation of draft data quality objectives (DQOs) for the push‑pull test, soil vapor extraction (SVE) O&M, and SVE system expansion at both SWMU B‑3 and AOC‑65 was initiated in the subject quarter in anticipation of a kickoff meeting/DQO meeting scheduled for November 3, 2004.

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 projects are planned. As of the end of Quarter 22, WPs currently under scope are 80 percent complete. The CSSA Environmental Encyclopedia will continue to be updated as WPs are finalized.

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 Corrective Measures Study (CMS). 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 2 indicates the sites for which investigations have been initiated and subsequently conducted as well as sites that have been identified, but not yet investigated.

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 included groundwater monitoring, analytical data verification and validation, closure activities at several SWMUs and AOCs, Building 90/AOC‑65 investigations, SWMU B‑3 and AOC‑65 SVE system operation and expansion, AOC‑55 remediation activities, and various miscellaneous tasks.

Groundwater Monitoring

There are currently 41 drinking water, livestock, and monitoring wells at CSSA that are monitored as set out in the DQOs for the Groundwater Contamination Investigation. In addition, there are four Westbay^® multi‑port wells that are sampled on a monthly basis, and 10 shallow wells and piezometers near Building 90 were monitored in conjunction with the AOC‑65 treatability investigation and recharge study. Monitoring activities associated were discontinued on TO0058 so that the recharge study results to date could be compiled into the Technology Evaluation Report being prepared as a comprehensive assessment of remedial options for AOC‑65.

Sampling of all on‑post and selected off‑post wells is conducted quarterly. Off‑post wells were sampled from September 20 ‑ 23, 2004. Twenty-six private and public off‑post drinking water wells were sampled. The locations of these wells are shown on Attachment 1. All samples were collected from ports located near the wellhead. If necessary, ports were installed near the wellhead. Seven off‑post wells are equipped with granular activated carbon (GAC) filtration systems and water was sampled from the system before and after treatment of the groundwater has occurred. Samples were analyzed by Agriculture & Priority Pollutants Laboratories, Inc. (APPL) for the EPA‑approved short list of volatile organic compounds (VOCs). The VOC short list includes 1,1‑dichloroethene (1,1‑DCE), bromodichloromethane, bromoform, chloroform, cis‑1,2‑dichloroethene (cis‑1,2‑DCE), dibromochloromethane, dichlorodifluoromethane, methylene chloride, naphthalene, tetrachloroethene (PCE), trichloroethene (TCE), toluene, trans‑1,2‑dichloroethene (trans‑1,2‑DCE), and vinyl chloride. Preliminary data on these samples were received by Parsons on October 13, 2004. Data validation and verification for these samples were initiated this quarter and Parsons’ chemists submitted these data packages to AFCEE and Portage Environmental on October 13, 2004.

Quarterly groundwater monitoring of on‑post monitoring and/or drinking water wells was performed on September 6 ‑ 17, 2004. CSSA wells CS‑1, CS‑2, CS‑4, CS‑9, CS‑10, CS‑11, CS‑D, CS‑I, CS‑MWG‑LGR, CS‑MWH‑LGR, CS‑MW1‑BS, CS‑MW1‑CC, CS‑MW1‑LGR, CS‑MW2‑LGR, CS‑MW2‑CC, 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‑MW11A‑LGR, CS‑MW11B‑LGR, CS‑MW12‑BS, CS‑MW12‑CC, CS‑MW12‑LGR, CS‑MW16‑CC, CS‑MW16‑LGR, CS‑MW17‑LGR, CS‑MW18‑LGR, and CS‑MW19‑LGR were sampled. Locations of the on‑post wells sampled are shown on Attachment 1. Samples were analyzed by Severn Trent Laboratories (STL) for the EPA‑approved short list of VOCs. The preliminary data were received by Parsons on October 4 ‑ 7, 2004. Data validation for VOCs and metals was performed this quarter and Parsons’ chemists submitted these data packages to AFCEE and Portage Environmental on October 13, 2004.

The Final On‑post Quarterly Groundwater Monitoring Report for March 2004 and the Final On‑ and off‑post Quarterly Groundwater Monitoring Reports for June 2004 were added to Volume 5 of the Environmental Encyclopedia this quarter.

Westbay^®‑equipped Well Sampling Events

Formation pressures in each sample zone were profiled seven times during Quarter 22. Two rounds of sampling from the Westbay^® multi‑level wells were conducted during the weeks of September 3 and October 6, 2004 from CS‑WB‑01, WB02, CS‑WB03, and CS‑WB04. 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.

Off‑Post GAC Systems

Based on sampling results received in 2001 and 2002 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 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 2004. Based on the preliminary results, no post‑GAC samples had concentrations above the MCL for PCE, TCE, or cis‑1,2‑DCE during the March event. The next post‑GAC sampling event will be conducted in March 2005.

On‑Post GAC Systems

A long‑term pilot study to measure the effectiveness and capacity of well CS‑MW16‑CC was initiated at the end of February 2004 and continued through Quarter 22. Discharge rate, drawdown, and contaminant concentrations have been monitored throughout the duration of the pilot study. The system is currently operating at approximately 12.5 gallons per minute (gpm) (18,000 gallons per day [gpd]), which is 60 percent of the permitted discharge limit.

Parsons operated and maintained the GAC unit, and prepared a Discharge Monitoring Report (DMR) each month to comply with TPDES permit requirements. Through October 31, 2004, approximately 543,660 gallons of water containing VOCs were treated by GAC and discharged from Outfall 002 during Quarter 22.

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 Quality Assurance Program Plan (QAPP) requirements. Data validation and verification continued during Quarter 22 under CSSA projects TO 0008 and TO 0019.

Six data packages related to quarterly groundwater monitoring activities were received by Parsons during Quarter 22. These packages covered a confirmation sample for the June 2004 quarterly sampling event and all samples for the September 2004 sampling event. Seventeen additional data packages were received related to outfall monitoring, Building 43, DD and Building 40 sampling, Westbay sampling, and a drinking water sample analyzed for lead (in response to a private well owner request). The Westbay multi‑port groundwater sampling and outfall monitoring samples are verified as screening‑level data. All discrete level data packages were validated and verified in accordance with specific project DQOs and the CSSA QAPP. Parsons submitted data packages for TO0008 Group O and Group P this Quarter to AFCEE for review. AFCEE chemists approved data package groups TO 0008 #27-32, #45, #55 and #48-62 during this Quarter.

RCRA Facility Investigations/Closures 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 64 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 2. To‑date, closure of 21 sites has been approved by TCEQ. In addition, closure reports have been submitted for six additional sites and closure reports are currently being prepared for nineteen sites.

During Quarter 22, soil/waste investigations and/or excavations were conducted at SWMUs B‑8 and DD. A brief summary of site progress follows:

Hydrogeologic Conceptual Site Model Preparation and Well Installation Report

A draft version of the CSSA Hydrogeologic Conceptual Site Model (CSM) was submitted to AFCEE and CSSA for internal review on January 27, 2004. CSSA provided comments during Quarter 21 and responses to comments are currently being prepared. The Draft TO0042 Well Installation Report was submitted to CSSA and AFCEE during Quarter 20. CSSA provided comments on May 28, 2004. Parsons response to comments was prepared during Quarter 21 and the final report will be produced in Quarter 22.

Building 90/AOC‑65 Investigation

Under TO0058, groundwater sampling is performed following each significant rainfall event. After a large rainfall event (>2 inches) in August 2004 sampling results from PZ‑1 and PZ‑2 showed increases in PCE concentrations.

AOC‑55 Excavation

Removal actions at AOC‑55 were completed during Quarter 20. Comments to the closure report were received July 8, 2004 from the TCEQ. A response to the TCEQ was submitted to during Quarter 22. Closure of AOC-55 is expected during Quarter 23.

Miscellaneous

Letters summarizing the results of the June 2004 off‑post groundwater monitoring event were mailed to the owners of the off‑post wells on August 11, 2004. Fact Sheet 19 covering the sampling conducted in June 2004 was mailed to all recipients on the CSSA mailing list during Quarter 22. Draft letters to well owners and a draft Fact Sheet 20 summarizing the September 2004 groundwater monitoring results were submitted to CSSA and AFCEE for review during Quarter 22.

The CSSA website was updated with documents added to the Environmental Encyclopedia through the end of October 2004. Additional updates are pending due to revisions to the website style and search capabilities to be conducted in October and November 2004. The website includes CSSA’s Administrative Record as required under the Order. Parsons continued to update the internal version of the electronic encyclopedia and hard‑copy by updating it with all final reports through October 2004.

Parsons personnel conducted various LAN and GIS support activities during Quarter 22. GIS support was provided during Quarter 22, including continuous updates to GIS files, overall maintenance to GIS data. Periodic GIS support was provided to CSSA personnel on an as‑needed basis. Software installations were performed in preparation to migrate to ArcGIS 9, the next version of GIS software. Updates to the SDS database were also conducted to include sampling location coordinates and other electronic data. Parsons personnel provided LAN support this Quarter, including LAN system maintenance, preparation of system diagrams, documentation for backup LAN administration, assisting network users with virus alerts, updates to ESRI software and using virtual private network (VPN) for access to the CSSA LAN.

1. Percent Complete

The Facility Investigation task makes up approximately 45 percent of the RFI phase. As of the end of Quarter 21, this task is approximately 26 percent complete.

2. Summary of Findings

Groundwater Monitoring

Quarterly groundwater monitoring for both on‑ and off‑post wells was performed at CSSA from September 6 ‑ 22, 2004. A map of the well locations sampled is provided on Attachment 1 of this report. CSSA sampled 21 private and five public off‑post wells, 36 on‑post monitoring wells, and 3 drinking water wells during Quarter 22. Results of the September 2004 groundwater monitoring event will be formally reported in the draft September 2004 Quarterly Groundwater Monitoring Reports to be submitted to CSSA and AFCEE for review and comments during Quarter 23.

Building 90/AOC‑65 Investigation

Observations and data collected during the groundwater recharge study activities were performed under TO0042 for inclusion into in the Technology Evaluation Report being prepared under TO0058 during Quarter 22. The results indicate that PCE concentrations increased in PZ‑1 and PZ‑2 after a large rainfall event in August 2004.

RCRA Facility Investigations/Closures of SWMUs and AOCs

Findings of current investigations and closures at SWMUs and AOCs were described previously in this section. In general, excavation and subsequent sampling continues at each site until RRS1 criteria are met.

3. Summary of Changes

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

4. Summary of Contacts

Results from the June 2004 quarterly groundwater monitoring event were mailed to each off‑post well owner August 11, 2004. In addition, CSSA received several letters from the TCEQ during Quarter 22. The following correspondence was submitted to and/or received from TCEQ:

Copies of all correspondence are included in Volume 1‑1 of the Environmental Encyclopedia.

On September 21, 2004, CSSA and Parsons personnel met for the kick‑off meeting for TO0098. Discussions of the SOW under TO0098 were held, including preparation of the TPDES permit update, natural resources and cultural resources plans, environmental noise management plan, community relations plan and air permit update.

On October 20, 2004, CSSA and Parsons personnel met for the kick‑off meeting for TO 0011. Discussions of the project scope, objectives, schedule, and other topics or implications related to implementation of SCADA design, installation, and training of CSSA/Parsons staff for optimizing the use of the SCADA system. Also discussed was the on-going public works GIS project for infrastructure maintenance and monitoring.

5. Summary of Problems

No significant problems were encountered during the reporting period.

6. Actions Taken to Correct Problems

No actions to correct problems necessary.

7. Projected Work for the Next Quarter

Fact Sheets

Fact Sheet 20, drafted in Quarter 22, was submitted to CSSA for review and comment. After CSSA approval, the Fact Sheet will be distributed to area residents. Draft letters to the well owners summarizing the September Quarterly results will be submitted to CSSA for review during Quarter 22. Fact Sheet 21 will be prepared from results of the December 2004 sampling event.

Upon completion of the Technology Evaluation Report, a new Fact Sheet will also be prepared for distribution to the neighborhood covering the topic of investigation and remedial action progress at AOC‑65 under TO0058.

Groundwater Monitoring

Final September Groundwater Monitoring Reports for on‑ and off‑post will be submitted in Quarter 23. Preparation of a summary report for 2004 will be initiated in Quarter 23, and submitted with the December 2004 Groundwater Monitoring Reports.

The next quarterly groundwater monitoring event will be conducted in December 2004. The upcoming event will include the existing CSSA drinking water and monitoring wells, approximately 30 off‑post wells and seven post‑GAC samples from off‑post wells. O&M at the residential GAC filtration systems (LS‑6, LS‑7, OFR‑3, RFR‑10, and RFR‑11) and public water supply systems (LS‑2/LS‑3) will be conducted monthly during Quarter 23. Preparation of a long term monitoring optimization (LTMO) study will begin next Quarter. Parsons personnel will visit CSSA for a site survey to initiate preparation of the study. The study will involve a three‑tiered approach that combines a qualitative evaluation with an evaluation of temporal trends in contaminant concentrations, and a spatial statistical analysis. The results of the three evaluations are combined to assess the optimal frequency and spatial distribution of monitoring. The results will be used to identify modifications in sampling locations and sampling frequency that will optimally meet monitoring objectives at reduced cost.

The Westbay^® wells will be profiled twice a month and sampled once per month for the foreseeable future, including Quarter 23. Monitoring frequencies may be modified based on the occurrence of significant rainfall.

SWMU and AOC RFI/Closure Reports and Planned Closure Projects

Closure work will be continued for several SWMUs and AOCs during Quarter 23. A no‑cost modification to the SOW for TO0019 resulted in additional sites being added to the task order. Additional investigation and closure report efforts will be performed for sites SWMU B‑25, Bldg 43, AOC-44, AOC-46, AOC-49, AOC-51, AOC-53, AOC-58, AOC-60, SWMU B-27, and SWMU B-28 scoped in the no-cost modification.

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.

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 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 RRSs, 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. TO0019 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, seven final RFI reports recommending closure have been completed and submitted to TCEQ and are pending approval (SWMU B-30, SWMU B-33, AOC-37, AOC-38, AOC-54, AOC-55 and AOC-66). As part of the preparation of these reports, investigation results were compared to closure criteria. A summary of recommendations made for each site is provided in Attachment 2. Based on the closure reports currently in preparation and those submitted through Quarter 22, 36 sites are recommended for closure while other sites may require future investigation and/or cleanup. Through October 2004, a total of 21 SWMUs or AOCs have been approved by TCEQ 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

Parsons discontinued O&M of the AOC‑65 SVE system per the O&M plan schedule on June 25, 2004. O&M consists of twice monthly system checks to assess and document the system performance, manage water in the knock‑out pot, and perform miscellaneous maintenance. Pressure measurements, flow, and contaminant flux screening levels were measured during the associated system check once per month. The estimated emissions measured during the 6‑month O&M period were well within allowable emission limits established in the Permit By Rule (PBR). The final quarterly O&M sampling event of the AOC‑65 SVE system was performed on June 25, 2004, and included screening of vapor extraction wells (VEWs) inside Building 90. The draft O&M assessment report for the six-month operating period was prepared during the subject‑reporting period and was submitted for CSSA and AFCEE review. The final report will be issued during Quarter 23. One year of continued O&M at both AOC‑65 and SWMU B‑3 is included in the new TO006. Upon approval of the recommendations, the O&M plan will be prepared for CSSA and AFCEE review with the objective of re‑initiating system operation by January 2005.

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

AOC‑65 SVE System

No data was collected from the AOC‑65 SVE system during the subject‑reporting period. The SVE systems are continuing to be intermittently operated, but no data collection is being performed until O&M recommendations are approved and the new O&M plan is completed.

SWMU B‑3 Preliminary Geologic and SVE Pilot Study Investigation

No data was collected from the SWMU B‑3 SVE system during the subject reporting period.

3. Summary of Changes

A Technical Interchange Meeting (TIM) was held September 8‑9, 2004. Discussions included report content and detailed findings from treatability studies conducted on TO0058 and recommendations for future work. Personnel from CSSA and Parsons attended Tim #9.

4. Summary of Contacts

Revisions to the SOW 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 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

O&M of the SVE systems at AOC‑65 and SWMU B‑3 will begin following approval of the recommendations in the O&M Assessment Report and completion of revised O&M plan for AOC‑65 and SWMU B‑3. Tentative start of the O&M period for both SVE systems is January 2005.

Field scale treatability studies of PIMS for the previously sifted soil piles will continue in Quarter 23 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.

Additional site investigations are subject to funding in current contracts.

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

No analytical data were submitted during this reporting period. Closure work will be continued for several SWMUs and AOCs during Quarter 22.

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. Seven progress reports (December 2003 – July 2005) are funded under TO0005.

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 18 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 22 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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