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23rd 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 23, the RFI is approximately 50 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

Task Order (TO) 0006 was awarded during Quarter 22. TO0006 provides for construction of a wastewater outfall reuse system, aboveground storage tank upgrade, and continued remedial actions and studies at SWMU B‑3 and AOC-65. Preparation of WPs for TO0006, including WP addenda, SAP addenda, HSP addenda, and a construction quality plan were initiated during Quarter 23. WPs and draft data quality objectives (DQOs) for the push‑pull test at SWMU B-3, soil vapor extraction (SVE) system expansion at AOC-65 and SWMU B-3, and updates to the O&M plan were also prepared during Quarter 23. The kickoff meeting/DQO meeting for this TO was held on November 3, 2004.

The technical approach for the integrated remedy planned at SWMU B-3, the plans for performing an associated push-pull test and construction of a multi-level monitoring system were presented to the TCEQ and USEPA during a DQO meeting for TO0006 held Thursday, January 20, 2005 in Austin, Texas.

  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 23, WPs currently under scope are 85 percent complete. The CSSA Environmental Encyclopedia will continue to be updated as WPs for the new TOs 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 regulatory correspondence, 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 shallow wells and piezometers near Building 90 are monitored in conjunction with the AOC‑65 treatability investigation and recharge study. Remediation studies monitoring associated with TO0058 was completed during Quarter 23.

Sampling of all on‑post and selected off‑post wells is conducted quarterly. Off‑post wells were sampled from December 13 to 16, 2004. Thirty-one 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. Samples were analyzed by Agriculture & Priority Pollutants Laboratories, Inc. (APPL) for the EPA‑approved short list of volatile organic compounds (VOCs) from the project DQOs. 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. Parsons received preliminary data on these samples on December 15 – 17, 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 January 13, 2005. A newly installed privately owned drinking water well-designated RFR-13 was sampled for the first time in December 2004. Due to chloroform detections, a confirmation sample was collected from off-post drinking water well RFR-13 on January 11, 2005, and the preliminary data was received January 24, 2005. The off-post well owner indicated in personal communication with sampling personnel that he had treated the well with household chlorine beach. Data validation for the confirmation sample is being conducted.

Quarterly groundwater monitoring of on‑post monitoring and drinking water wells was performed on November 29 to December 7, 2004. The on-post monitoring wells and CSSA drinking water wells were sampled. Locations of the on‑post wells sampled are shown on Attachment 1. Samples were analyzed by Severn Trent Laboratories (STL) for the short list of VOCs. Parsons receive the preliminary data from December 16 to 21, 2004. Data validation for VOCs and metals was performed this Quarter and Parsons’ chemists submitted these data packages to AFCEE and Portage Environmental on January 21, 2005.

The draft On‑ and Off-Post Quarterly Groundwater Monitoring Report for September 2004 were submitted to CSSA and AFCEE for review. CSSA comments were received and responses to comments were provided. CSSA concurred to the responses to comments on the September 2004 on-post and off-post reports. The reports were issued as Final on January 24 and 25, 2005 and will be added to Volume 5 of the Environmental Encyclopedia this Quarter.

Westbay®‑equipped Well Sampling Events

Formation pressures in each sample zone were profiled and zones with groundwater were sampled during Quarter 23. Sampling was conducted for the Westbay® multi‑level wells from November 15 to 18, November 30 to December 2, and December 28 to 29, 2004, and from January 25 to 26, 2005, from CS‑WB‑01, WB02, CS‑WB03, and CS‑WB04. Each well zone was hydraulically profiled and discrete samples were collected from groundwater‑bearing intervals. The samples were submitted to DHL Analytical for VOC analysis. Wells were profiled only on November 22, 24, and December 10, 2004. UGR zones that had not been previously made water were sampled following over 10” of cumulative precipitation in November 2004. Results are presented in the December 2004 Quarterly Groundwater Monitoring Report.

Off‑Post GAC Systems

Based on sampling results received in 2001 and 2002 indicating VOC levels above or approaching the maximum contaminant level (MCL), granular activated carbon (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 (municipal supply wells) 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 September 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 23. 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 on-post GAC unit, and prepared a Discharge Monitoring Report (DMR) each month to comply with TPDES permit requirements. Through December 31, 2004, approximately 593,138 gallons of water containing VOCs were treated by GAC and discharged from Outfall 002.

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 23 under CSSA projects TO0098, TO0008, and TO0019.

Parsons received seven data packages related to quarterly groundwater monitoring activities during Quarter 23. These packages covered a confirmation sample and all samples for the December 2004 sampling event. Nine additional data packages were received related to outfall monitoring, eight data packages related to Westbay sampling, two data packages related to SWMU B-2 and AOC-53, and one data packages related to the TPDES permit renewal. The Westbay multi‑port groundwater sampling and outfall monitoring samples are verified as screening‑level data. All other data packages were validated and verified in accordance with specific project DQOs and the CSSA QAPP. Parsons submitted data packages for TO0008 #89, #90, #91, #92, #101 and #102 this Quarter to AFCEE for review. AFCEE chemists approved those data packages 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 23 sites has been approved by TCEQ. Additional closure reports are currently being prepared for submittal to TCEQ. A no-cost modification to the project was approved in December 2004, which added nine sites to the original SOW.

During Quarter 23, soil/waste investigations and/or excavations were conducted at SWMUs B‑25, B‑27, B‑28, Bldg 43, and AOC‑53. A brief summary of site progress follows:

B‑25: Sampling was conducted during this Quarter. Additional excavation is planned for one sampling point.

B‑27: Delineation of the site extent and determination of the nature of site waste was conducted during this Quarter. Waste characterization samples were collected and submitted for analysis.

B‑28: Soil pile waste characterization samples were collected and submitted for analysis. Results indicated the waste is hazardous. Due to the nature of the waste, a treatability study was being performed so that the waste can be reclassified as Class 2 material. Phosphate treatment reduced the soil to Class 2 levels and treated soils will be disposed in the next Quarter.

Bldg 43: Building was demolished following the Texas Historical Commission (THC) approval of the Memorandum of Agreement (MOA). Building debris and Class 2 soils that were generated at the site to date were disposed at a local landfill. In all, 455 tons of Class 2 waste was disposed of from this site in Quarter 23. Hazardous soil waste still remains at the site and was treated with PIMS to reduce to Class 2. Disposal of the treated hazardous waste will occur during the next Quarter.

AOC‑53: Concrete foundation was demolished during this Quarter. Concrete debris was disposed as construction waste at Covel Gardens Landfill. VOC, SVOC, and pesticide/herbicide samples showed no contamination. Metals samples will be collected next Quarter. In all, 570.45 tons of Class 2 debris was removed to Covel Gardens during Quarter 23.

A separate waste disposal project was conducted under TO0006 involving waste asphalt and soil generated during road paving activities at CSSA during Quarter 23. In all, 2,098.55 tons of asphalt-related waste was transported to Waste Management Inc., - Covel Gardens disposal facility under the WMI profile number CG-29058-C-2.

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 Final CSM report will be submitted during Quarter 24. The Final TO0042 Well Installation Report was submitted to CSSA and AFCEE during Quarter 22.

Building 90/AOC‑65 Investigation

Groundwater sampling can be performed following significant rainfall event, depending on whether it addresses a current DQO related to the recharge study performed at the site. This sampling is no longer covered under TO0058, and was performed under TO0008 in November following an extended period of rainfall where over 10 inches of precipitation was measured in a 22-day period, with 3.34” of precipitation occurring during 24 hours on November 22, 2004.

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’s first comments was submitted during Quarter 22. TCEQ provided additional comments on November 18, 2004. CSSA responded to TCEQ’s letter on December 28, 2004.

Miscellaneous

Two minor spills recently occurred at CSSA causing 15 yd3 of soil contamination. One spill was caused by a transformer exploding and the other spill by a broken hydraulic line. All impacted soil was excavated, sampled, and profiled as Class 2 waste. Disposal of this soil will occur in Quarter 24.

Letters summarizing the results of the September 2004 off‑post groundwater monitoring event were mailed to the owners of the off‑post wells on November 12, 2004. Fact Sheet 20 covering the sampling conducted in September 2004 was mailed to all recipients on the CSSA mailing list during Quarter 23. Draft letters to well owners and a draft Fact Sheet 21 summarizing the December 2004 groundwater monitoring results will be submitted to CSSA and AFCEE for review during Quarter 24.

The CSSA website was updated with documents added to the Environmental Encyclopedia through the end of October 2004. Additional updates are planned to the website design and sample website designs were prepared during Quarter 23. 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 with all final reports through January 2005. In January 2005, Parsons personnel met with IT personnel at Fort Sam Houston to revise the dtSearch capabilities on the www.stanley.army.mil website server and update the website.

  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 30 percent complete.

  1. Summary of Findings

Groundwater Monitoring

Quarterly groundwater monitoring for both on‑ and off‑post wells was performed at CSSA from November 29 to December 16, 2004. A map of the well locations sampled is provided on Attachment 1 of this report. CSSA sampled twenty-seven private and four public off‑post wells, thirty-seven on‑post monitoring wells, and three on-post drinking water wells during Quarter 23. Results of the December 2004 groundwater monitoring event will be formally reported in the draft December 2004 Quarterly Groundwater Monitoring Reports to be submitted to CSSA and AFCEE for review and comments during Quarter 24.

Building 90/AOC‑65 Investigation

Observations and data collected during the groundwater recharge study activities were performed under TO0008. The results from MW2A, a shallow monitoring well screened from 9 to 19 ft sampled near AOC-65 in November/December 2004 after the significant precipitation indicated that PCE concentrations fluctuated from 556 to 3,490 ppb over five weekly sampling events.

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 confirmation sampling continues at each site until Risk Reduction Standard 1 (RRS1) criteria are met. Closure reports are drafted as site investigations are concluded.

  1. Summary of Changes

No changes to the RFI were made during this Quarter.

  1. Summary of Contacts

Results from the September 2004 quarterly groundwater monitoring event were mailed to each off‑post well owner November 12, 2004. In addition, CSSA received several letters from the TCEQ during Quarter 23. The following correspondence was submitted to and/or received from TCEQ:

January 7, 2005

CSSA response to TCEQ request for additional information on the Final Well Installation Report for TO0042;

December 28, 2004

CSSA response to TCEQ comments on the RFI and Interim Measures Waste Management Plan;

December 28, 2004

CSSA response to TCEQ request for additional information on AOC-55 Closure Report;

December 27, 2004

CSSA response to TCEQ letter of November 17, 2004, requesting additional information on SWMU B-23A Closure Report;

December 2, 2004

TCEQ approval of the Final June 2003 Off-Post Quarterly Groundwater Monitoring Report;

November 18, 2004

TCEQ request for additional information for AOC-55 Closure Report;

November 17, 2004

TCEQ request for additional information for SWMU B-23A Closure report;

November 16, 2004

TCEQ approval to delist AOC-54 from the closure sites;

November 16, 2004

TCEQ approval of closure for SWMU B-33;

November 15, 2004

TCEQ approval to delist AOC-48 from AOC;

November 15, 2004

TCEQ approval to delist SWMU B-26 from the SWMUs;

November 5, 2004

TCEQ request for additional information concerning the Final Well Installation Report for TO0042 dated August 2004; and

October 28, 2004

TCEQ comments to RFI and Interim Measures Waste Management Plan dated August 2002.

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

On November 1, 2004, CSSA and Parsons personnel met for the kick‑off meeting for TO0006, which will focus primarily on SWMU B-3 and AOC-65. Discussions of the SOW under TO0006 were held, including an overview of the DQOs for each of the tasks planned, including the push-pull test, the SVE system expansion and continued O&M, and expansion of the West-bay monitoring network to include the SWMU B-3 area.

A technical interchange meeting (TIM) under TO0008 was conducted November 12, 2004, at CSSA. A Long-Term Monitoring Optimization (LTMO) presentation was given by Dr. Carolyn Nobel of Parsons (Denver). The purpose of the study is to statistically evaluate the number of wells that are currently being sampled to streamline CSSA’s current groundwater monitoring program. The three-tiered approach for LTMO has been developed by Parsons and 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 determine the degree to which a monitoring program addresses the monitoring program objectives, and a decision algorithm is applied to assess the optimal frequency of monitoring and spatial distribution of the components of the monitoring well network. Ultimately, application of the three-tiered method can be used to identify potential modifications in sampling locations and sampling frequency that will optimally meet monitoring objectives.

On January 20, 2005, CSSA and Parsons personnel met with EPA and TCEQ personnel to discuss the technical approach and specific requirements for the integrated remedy being tested at SWMU B-3. Discussions of the project scope, objectives, schedule, and other topics or implications related to implementation of this TO0006 were also held. An introduction to the LTMO study was also presented to regulatory personnel at this time.

  1. Summary of Problems

No significant problems were encountered during this Quarter.

  1. Actions Taken to Correct Problems

No actions to correct problems necessary.

  1. Projected Work for the Next Quarter

Fact Sheets

Fact Sheet 21, drafted in Quarter 23, will be distributed to area residents reporting on the December 2004 groundwater monitoring in Quarter 24. 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 2004 On- and Off-Post Groundwater Monitoring Reports will be submitted in Quarter 24. 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 after the results of the LTMO study are made final and presented to CSSA and the regulators. Future sampling events will be planned upon the recommendations of the LTMO and the retention or removal of wells from the groundwater monitoring program. 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 24.

The Westbay® wells will be profiled and sampled once per month for the foreseeable future, including Quarter 24. Monitoring frequencies may be modified in the future based on the recommendations made in the LTMO study and the concurrence of regulators.

SWMU and AOC RFI/Closure Reports and Planned Closure Projects

Closure work will be continued for several SWMUs and AOCs during Quarter 24. During Quarter 23, a no‑cost modification to the SOW for TO0019 resulted in 11 additional sites being added to the TO. Additional investigation and closure report efforts will be performed for sites SWMUs B-2, B‑25, B-27, B-28, Bldg 43, AOC-44, AOC-46, AOC-49, AOC-53, AOC-58, and AOC-60.

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

Reports summarizing the most recent groundwater findings are periodically submitted after all data has been reviewed and verified 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.

  1. Summary of Findings

As described in Task III, final RFI reports recommending closure are being completed for several sites. 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 23, 29 sites are recommended for closure while other sites may require future investigation and/or cleanup to TRRP standards. Through December 2004, a total of 23 SWMUs or AOCs have been approved by TCEQ for closure.

  1. Summary of Changes

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

  1. Summary of Contacts

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

  1. Summary of Problems

No problems related to the Investigative Analysis occurred during this Quarter.

  1. Actions Taken to Correct Problems

No actions to correct problems were necessary during this Quarter.

  1. Projected Work for the Next Quarter

Continued work on comparison of investigation results to closure criteria will be performed in Quarter 24.

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

No daily reports, inspection reports, or data related to investigation analysis/risk assessment were generated during this Quarter.

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 on June 25, 2004, per the O&M plan. O&M consisted 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 during Quarter 23. The final report will be issued during Quarter 24. 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 March 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.

  1. 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.

  1. Summary of Changes

A 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.

  1. 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 proposed studies, but no plans are currently ongoing to conduct any of the proposed work during the next Quarter.

  1. Summary of Problems

No problems related to the treatability studies occurred during this Quarter.

  1. Actions Taken to Correct Problems

No actions to correct problems were necessary during this Quarter.

  1. 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 March 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 SPDA. 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.

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

No analytical data were submitted during this Quarter. Closure work will be continued for several SWMUs and AOCs during Quarter 24.

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.

  1. Summary of Findings

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

  1. Summary of Changes

No changes associated with the progress reports occurred during this Quarter.

  1. Summary of Contacts

No contacts relating to progress reports were made during this Quarter.

  1. Summary of Problems

No problems relating to progress reports occurred during this Quarter.

  1. Actions Taken to Correct Problems

No actions to correct problems were necessary during this Quarter.

  1. Projected Work for the Next Quarter

The Progress Report for Quarter 24 will be submitted.

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

No daily reports, inspection reports, or data related to the Progress Reports were generated during this Quarter.

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