Appendix A - Data Quality Objectives for the Removal Action - AOC 55

1.0 - State the Problem (Step 1)

1.1     History/Background

1.2     Previous Investigations

1.3     The Planning Team

2.0 - Identify the Decision

2.1     Key Decisions

2.1.1     Cover Soils

2.1.2     Trench Materials

2.1.3     Confirmation Samples

2.1.4     Borrow Soil

2.2     Future Decisions

2.3     Alternative Decisions

3.0 - Identify Inputs (Step 3)

3.1     Cover Soils

3.2     Trench Materials

3.3     Confirmation Samples

3.4     Borrow Soil

3.5     Construction of a New Water Crossing

4.0 - Define Study Boundaries (Step 4)

5.0 - Develop a Decision Rule (Step 5)

6.0 - Specify Tolerable Limits for Decision Errors (Step 6)

7.0 - Optimize the Design for Obtaining Data (Step 7) 

1.0 - State the Problem (Step 1)

1.1 - History/Background

Parsons has been contracted to remove the wastes from the land-based portion of the site.  Area of Concern No. 55 (AOC-55) is a disposal burial area that consists of one large trench area of unknown depth located along the banks of the ephemeral stream, Cibolo Creek.  During heavy rainfall, the thin soil cover adjacent to Cibolo Creek washed away and exposed the waste inside the landfill.  Prevention of the future erosion and potential release of debris from AOC-55 during future heavy rainfall events is the main reason that the removal action was deemed necessary and appropriate to complete at this time.

If necessary, the groundwater and vadose zone under the site will be evaluated by Camp Stanley Storage Activity (CSSA) under its’ groundwater investigation program.

1.2 - Previous Investigations

The following summary and associated AOC-55 maps can be found in CSSA Environmental Encyclopedia Volume 1-3. 

1.3 - The Planning Team

Camp Stanley Storage Activity

Mr. Brian K. Murphy, CSP, Environmental Officer

Mr. Jeff Aston, Environmental Specialist, U. S. Army Corps of Engineers

Mr. Chris Beal, Contract Geologist, Portage

Parsons

Mr. Ken Rice, Project Manager

Mr. Brian Vanderglas, Technical Support

Mr. Kyle Caskey, Field Team

Portage

Mr. Joe Fernando, Ph.D., Chemist

The Decision Makers

Lieutenant Colonel Jason D. Shirley, Installation Manager, CSSA

Mr. Brian Murphy, CSP, Environmental Officer, CSSA

Mr. Greg Lyssy, Region 6, EPA

Mr. Kirk Coulter, Corrective Action Section, TCEQ

2.0 - Identify the Decision “Prioritize and Logical Sequence for Actions” (Step 2)

2.1 - Key Decisions

2.1.1 - Cover Soils

Determine thickness of cover soil and evaluate whether surface soils are appropriate for reuse as cover material.  As necessary, sample cover soils for COCs at a frequency of one sample per 1,000 yds³ of soil.

2.1.2 - Trench Materials

Determine contents of trench, confirm that waste is non-hazardous, and estimate volume of excavated waste requiring off-post disposal.

2.1.3 - Confirmation Samples

Confirm all soils exceeding established background levels have been removed from the excavation.

2.1.4 - Borrow Soil

Some clean fill material may have to be imported to bring the excavation(s) up to final acceptable grade and to provide sufficient base for revegetation.

2.1.5 - Construction of a New Water Crossing

The existing low water crossing bridge will be removed and replaced with a new low water crossing ramp.  Determine appropriate engineering and construction specifications for ramp to withstand rapid stream flow and truck traffic.

2.2 - Future Decisions

Determine if vadose and groundwater zones require any future evaluation based on confirmation closure samples.

Determine if there is any further investigation or remediation work that should be completed prior to backfilling.

If estimated waste volumes exceed budgeted estimates (approx 1,500 CY hazardous, 33,000 CY non-hazardous wastes) hazardous waste will be given priority for disposal.  Disposal of hazardous wastes will require removal within 90-days.

If excavated material exceeds hazardous or non-hazardous waste levels for metals, Apatite II or another stabilization method will be considered for soil treatment.  If testing confirms stabilization has been effective, the treated soil may be taken to local landfill as not hazardous.  Prior approval for treatment of hazardous waste would be required from the TCEQ.

2.3 - Alternative Decisions

3.0 - Identify Inputs (Step 3)

3.1 - Cover Soils

Characterize surface soils after they have been stockpiled.  It is estimated that this work will generate approximately 2,000 in-place cubic yards of soil (2,400 CY loose).

3.2 - Trench Materials

EM surveys and investigation trenches into the landfill will be performed to collect data for estimating the thickness of the trench cover material, assess the contents of the trench, and determine the approximate volume of material in the trench. 

Characterize the soil after it is excavated and stockpiled.  It is estimated that there will be 35,000 CY of loose material.  Based on visual evidence, soils may be segregated for cover soil or debris soils for disposal. 

	Initial characterization of materials for COCs will require analyses for total VOCs (full list), metals, and SVOCs.
	Waste characterization will require analyses for TCLP of the COCs determined by previous totals analyses.
	Samples will be analyzed using a seven-day turnaround time.
	No field duplicate (FD), matrix spike (MS), or matrix spike duplicate (MSD), samples will be required.  However, trip blanks will be collected as necessary.
	Analytical case narratives will be reviewed for completeness, but formal verification/validation will not be required.
	If the material meets non-hazardous waste requirements, the soil will be taken off-post to a local landfill for disposal.  If testing indicates the waste materials are hazardous, the portion(s) of the stockpiles that exceeds non-hazardous requirements will be segregated and confirmation samples will be collected.
	Banding material and other metal debris will be segregated for potential recycling.

3.3 - Confirmation Samples

Confirmation samples will be collected from the soil portion of the excavation sidewalls.

3.4 - Borrow Soil

If borrow material is required from an off-site source, laboratory analyses of the material will be required to confirm it is free of contaminants.  One composite sample will be collected from the borrow soil source to confirm there are no contaminants. 

3.5 - Construction of a New Water Crossing

Construction quality assurance will be performed by construction inspector.  Efforts include engineering design of water crossing and final grade.  Final grade of excavation area will be determined after excavation is complete.  As-built engineering drawings will be prepared to document the post-remediation activities.

4.0 - Define Study Boundaries (Step 4)

The study boundary is limited to the confines of the installation, specifically AOC-55.  This study focuses on the soil unit, and will not extend into the underlying bedrock and groundwater if contamination is found to remain even after completing the removal of all readily accessible waste materials and contaminated soils

5.0 - Develop a Decision Rule (Step 5)

Refer to Step 2 of these DQOs for decision processes related to the interim removal action and treatability study.

6.0 - Specify Tolerable Limits for Decision Errors (Step 6)

Currently, the AFCEE QAPP Version 3.0 is being utilized by CSSA.  The QAPP specifies tolerable limits for errors.  Specific variances to the QAPP have been approved by the EPA or TCEQ and are located in the CSSA Environmental Encyclopedia, Volume 1-1, and Correspondence with Regulators.

7.0 - Optimize the Design for Obtaining Data (Step 7)

Refer to Step 2 of these DQOs for decision processes related to the removal action and associated investigation activities.