Volume 1 - Workplan Section 11

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Section 11 - RCRA Facility Investigation (RFI) Work Plan

11.1 - Statement of Objective

This addendum to the work plan describes activities in support of and in compliance with the EPA Administrative Order on Consent, EPA identification number TX2210020739, proceeding under Section 3008(h) of RCRA, as amended, 42 U.S.C. Section 6928(h).

The objectives of the RFI include:

	Identifying possible releases;
	Investigating and preventing the further spread of identified releases of hazardous waste and /or hazardous constituents to the environment at and/or from the facility; and
	Ensuring that corrective actions protect human health and environment.

In addition to this addendum to the work plan, the Quality Program Plans (QPP), are included in Volume 1-4 and Volume 1-5, respectively. The QPP includes the Sampling and Analysis Plan (SAP) and the Health and Safety Plan (HASP). The SAP consists of the Quality Assurance Project Plan (QAPP) and the Field Sampling Plan (FSP). The SAP is included in Volume 1-4 and the HASP is included in Volume 1-5.

A detailed description of the RFI measures for each SWMU is provided in Volume 1-2 and Volume 1-3. Work plans that had been prepared previously but have not been carried out (those prepared under projects RL33, RL53, RL74, RL83, and DO23) are considered to be the RFI Work Plans for those sites. In addition, work plans prepared for several sites at which resampling is necessary due to questionable practices by ITS laboratory are also considered to be RFI Work Plans. All of these plans for work are included in Volume 1-2 and Volume 1-3.

Table 11.1 includes a list of workplan requirements as specified in the RFI Scope of Work, Section B.2. (Task II) of the Order, and the locations in the encyclopedia where the required information may be found.

Table 11.1 - Location in CSSA Encyclopedia for RFI Workplan Requirements

Order Citation	RFI Workplan Requirement	Location in CSSA Encyclopedia¹
B.2.A	Project Management Plan (Work Plan)
B.2.A	The respondent shall prepare a Project Management Plan, which will include a discussion of the technical approach, schedules, budget, and necessary personnel. The technical approach shall include the rationale for investigation of each media (soil, groundwater, surface water, soil gas, and air) and a description of each area of concern which may have contamination from Facility activities. The technical approach shall address all the requirements set forth in Task III of this Corrective Action Plan. The Project Management Plan shall also document the overall management approach to the RFI.	The technical approach for investigation of each SWMU and AOC at CSSA is provided in Volume 1-2 and Volume 1-3. The anticipated schedule, subject to government budget constraints, and a general description of necessary personnel are provided in the RFI Work Plan addendum, *Volume 1-1*.
B.2.B	Data Collection Quality Assurance Plan (Field Sampling Plan)
B.2.B.	The Respondent shall prepare a Data Collection Quality Assurance Plan to document all monitoring procedures, including: sampling, field measurements, and sample analysis performed during the investigation to characterize the environmental setting, source, and contamination, so as to ensure that all information, data and resulting decisions are technically sound, statistically valid, and properly documented.	Generally, this information is provided in the existing Field Sampling Plan and the Quality Assurance Project Plan, Volume 1-4. Specific locations of the required information are provided below.
B.2.B.1	Data Collection Strategy
B.2.B.1.a	Description for intended uses of data collected, and precision and accuracy for these uses.	Intended use is described in Section 2.1 of the work plan overview. Precision and accuracy is defined in the Quality Assurance Project Plan and Variances. Precision and accuracy are method-specific. This is an outside link to the AFCEE web site.
B.2.B.1.b	Description of methods and procedures used to assess the precision, accuracy and completeness of measurement data.	Quality Assurance Project Plan Section 4. This is an outside link to the AFCEE web site.
B.2.B.1.c	Description of methodologies used to assure the data represent the characteristics of a population, parameter variations at a sampling point, and process conditions or environmental conditions, including environmental conditions at time of sampling, number of sample points, representativeness of selected media and analytical parameters.	Quality Assurance Project Plan Section 4. This is an outside link to the AFCEE web site.
B.2.B.1.d	Description of measures taken to assure that the following data sets can be compared to each other: (1) RFI data generated by the Respondent; (2) RFI data generated by parties other than the Respondent; (3) Data previously generated by Respondent or Respondent’s agents; and (4) Data previously generated by parties other than the Respondent.	Quality Assurance Project Plan Section 1 (QAPP was created to assure that all data sets are comparable, and all contractors and subcontractors adhere to the same procedures); Section 4.2.5, page 4-4 discusses comparability; Sections 8.1 and 8.2, pages 8-1 through 8-7 discusses requirements that must be followed to ensure comparability; and Section 9.1, pages 9-1 through 9-3 discusses evaluation programs, audits and training to ensure these items listed. This is an outside link to the AFCEE web site.
B.2.B.1.e	Details relating to the schedule and information to be provided in quality assurance reports. The reports shall include but not be limited to: (1) Periodic assessment of measurement data accuracy, precision and completeness;	Quality Assurance Project Plan Section 8. This is an outside link to the AFCEE web site.
	(2) Results of performance audits, including corrective actions necessary as a result of audits and re-audits.	Volume 1-4, Laboratory Audits.
	(3) Results of system audits.	Volume 1-4, Laboratory Audits.
	(4) Significant quality assurance problems and recommended solutions.	Information related to quality assurance problems will be included in the Informal Technical Information Report. In addition, if significant quality assurance problems are found, a follow-up audit may be performed at the laboratory. Laboratory audit reports and follow-up correspondence will be included in Volume 1-4, Laboratory Audits.

B.2.B.2.a	Strategy for selecting appropriate sampling locations, depths, etc.	Items B.2.B.2.a-i address data quality objectives (DQOs). DQOs for CSSA were developed using EPA’s three-stage process. First decision types were identified. Data from the RFI will be used to determine if sites are contaminated or if they can be closed. Standards established in the Risk Reduction Rules will be used as comparison criteria. Secondly, data uses and needs were identified. Data uses may include closure, risk assessment, or identification of potential treatment options, as appropriate. Data needs for each site are listed in the RFI Work Plan Addenda for each site. The final step in the DQO process is to design the data collection program. The data collection program for each site is included in Volume 1-2 and Volume 1-3. The strategy for selecting appropriate sampling locations and depths at SWMUs and AOCs is site-specific. In general, a minimum of three samples is collected at each site. If there is evidence of buried waste or trenches (through records or geophysical surveys), subsurface soil samples will be collected at a depth approximately two feet deeper than the depth of the waste management unit. Otherwise, only surface soil samples will be collected. Locations are selected based on known data (such as geophysical survey results) or observations (stained soil, exposed waste, etc) made at the site.
B.2.B.2.b	Strategy for determining a statistically sufficient number of samples.	Because each site is relatively small and if contamination exists or not is not known at many sites, statistical sampling strategies are not currently planned.
B.2.B.2.c	Strategy for measuring all necessary ancillary data.	Volume 1-4 includes strategy and methodology for collecting ancillary data.
B.2.B.2.d	Strategy for determining conditions under which sampling will be conducted.	The strategy for sampling described above will be used at any site identified as a potential waste management unit. Sites can be identified through base records, historic aerial photographs, interviews with former personnel.
B.2.B.2.e	Strategy for determining which media are to be sampled (e.g. ground water, air, soil, sediment, etc.)	Media present at a site, with the exception of air, will generally be sampled. In general, the only media typically present are soil and occasionally shallow groundwater. Surface water occurs very sporadically on the base, typically only after a precipitation event.
B.2.B.2.f	Strategy for determining which parameters are to be measured and where.	All sites will initially be sampled for VOCs, SVOCs, and metals. These methods will detect compounds and contaminants potentially present at the facility based on CSSA’s known past and current industrial processes. Some sites where ordnance disposal is suspected will also be sampled for explosives. In general, the potential waste management practices at the site will be considered when determining the appropriate analytical parameters. The analyte list for groundwater has been developed through evaluation of over 8 years of historic data.
B.2.B.2.g	Strategy for selecting the frequency of sampling and length of sampling period.	All sampling currently planned at SWMUs and AOCs will be one-time grab sampling. Groundwater monitoring will occur quarterly.
B.2.B.2.h	Strategy for selecting the types of samples (composites or grabs) and number of samples to be collected.	See above B.2.B.2.a and B.2.B.2.g.
B.2.B.2.i	Strategy for documenting field sampling operations and procedures, including: (1) Documentation of procedures for preparation of reagents or supplies which become an integral part of the sample (e.g., filters and adsorbing agents);	Section 2.2 of the Field Sampling Plan.
	(2) Procedures and forms for recording the exact location and specific considerations associated with sample acquisition;	Procedures are described in Volume 1-2 and Volume 1-3, behind the site-specific tabs. Standard forms to be used can be found in Volume 1-4, Field Sampling Plan, Appendix A.
	(3) Documentation of specific sample preservation;	Quality Assurance Project Plan Section 5. This is an outside link to the AFCEE web site.
	(4) Calibration of field devices;	Section 3 of Field Sampling Plan
	(5) Collection of replicate samples;	Section 2 of Field Sampling Plan
	(6) Potential interferences present at the Facility;	Section 1 of Field Sampling Plan
	(7) Construction materials and techniques associated with monitoring wells and piezometers;	Construction materials and techniques for shallow wells are provided in Section 1 of Field Sampling Plan
	(8) Field equipment listing and sample containers;	Field equipment is listed in Section 3 of Field Sampling Plan. Sample containers required are listed in Quality Assurance Project Plan Section 5. This is an outside link to the AFCEE web site.
	(9) Sampling order; and	Section 2.1.5 of Field Sampling Plan
	(10) Decontamination procedures.	Section 1 of Field Sampling Plan
B.2.B.2.j	Strategy for selection of appropriate sample containers.	Quality Assurance Project Plan Section 5. This is an outside link to the AFCEE web site.
B.2.B.2.k	Strategy for sample preservation.	Quality Assurance Project Plan Section 5. This is an outside link to the AFCEE web site.
B.2.B.2.l	Strategy for chain-of-custody, including: (2) Standardized field tracking reporting forms to establish sample custody in the field prior to shipment; and (3) Pre-prepared sample labels containing all information necessary for effective sample tracking.	Quality Assurance Project Plan Section 5. This is an outside link to the AFCEE web site.
B.2.B.3	Field Measurements
B.2.B.3.a	Strategy for selecting appropriate field measurement locations, depths, etc.	Field Sampling Plan, Sections 3.1 through 3.5
B.2.B.3.b	Strategy for providing a statistically sufficient number of field measurements.	Field Sampling Plan, Sections 3.1 through 3.5
B.2.B.3.c	Strategy for measuring all necessary ancillary data.	Field Sampling Plan, Sections 3.1 through 3.5
B.2.B.3.d	Strategy for determining conditions under which field measurements should be conducted.	Field Sampling Plan, Sections 3.1 through 3.5
B.2.B.3.e	Strategy for determining which media are to be addressed by appropriate field measurements (e.g. groundwater, air, soil, sediment, etc.).	Field Sampling Plan, Sections 3.1 through 3.5
B.2.B.3.f	Strategy for determining which parameters are to be measured and where.	Field Sampling Plan, Sections 3.1 through 3.5
B.2.B.3.g	Strategy for selecting the frequency of field measurement and length of field measurements period.	Field Sampling Plan, Sections 3.1 through 3.5
B.2.B.3.h	Strategy for documenting field measurements operations and procedures, including: (1) Procedures and forms for recording raw data, exact location, time and Facility-specific considerations associated with the data acquisition;	Field Sampling Plan, Section 1.1.5
	(2) Calibration of field devices;	Field Sampling Plan, Section 3.6
	(3) Collection of replicate measurements;	Field Sampling Plan, Section 4.1
	(4) Potential interferences present at the facility;	Field Sampling Plan, Section 1.1.1 discusses site reconnaissance, preparation and restoration procedures. Since a large portion of potential interferences are present when soil boring is taking place, Section 1.1.4 and Section 1.1.5 discusses drilling and soil sampling. Evaluation of underground utilities is discussed in Health and Safety Plan, Section 2.3.2.
	(5) Construction materials and techniques associated with monitoring wells and piezometers used to collect field data;	Field Sampling Plan, Section 1
	(6) Field equipment listing	Field Sampling Plan, Section 3
	(7) Order in which field measurements were made; and	Field Sampling Plan, Sections 3.1 through 3.5
	(8) Decontamination procedures.	Field Sampling Plan, Section 1.5
B.2.B.4	Disposal of waste material contaminated with hazardous constituents in accordance with all State and Federal regulations.	RL33 Addendum, Addendum 2.

B.2.B.5.a	Chain-of-custody procedures, including: (1) Identification of a responsible party to act as sample custodian at the laboratory facility authorized to sign for incoming field samples, obtain documents of shipment, and verify the data is entered onto the sample custody records; (2) Provision for a laboratory sample custody log consisting of serially numbered standard lab-tracking report sheets; and (3) Specification of laboratory sample custody procedures for sample handling, storage and disbursement for analysis.	Field Sampling Plan, Section 2.3 gives and overview of sample custody procedures; Quality Assurance Project Plan Sections 5 and 8 (this is an outside link to the AFCEE web site) discuss sample custody procedures in more detail.
B.2.B.5.b	Sample storage procedures and holding times.	Quality Assurance Project Plan Section 5.1.2 (this is an outside link to the AFCEE web site)
B.2.B.5.c	Sample preparation methods.	Quality Assurance Project Plan Section 7.1 (this is an outside link to the AFCEE web site)
B.2.B.5.d	Analytical procedures, including: (1) Scope and application of procedure;	Quality Assurance Project Plan Section 7.2 (this is an outside link to the AFCEE web site)
	(2) Sample matrix;	Quality Assurance Project Plan Section 7.2 (this is an outside link to the AFCEE web site)
	(3) Potential interferences;	Quality Assurance Project Plan Section 7.2 (this is an outside link to the AFCEE web site)
	(4) Precision and accuracy of the methodology	Quality Assurance Project Plan Section 7.2 (this is an outside link to the AFCEE web site)
	(5) Method detection limits	Quality Assurance Project Plan Section 7.2 (this is an outside link to the AFCEE web site)
	(6) Calibration procedures and frequency	Quality Assurance Project Plan Section 7.2 (this is an outside link to the AFCEE web site)
	(7) Data reduction, validation and reporting	Quality Assurance Project Plan Sections 8.1 and 8.2 (this is an outside link to the AFCEE web site)
	(8) Internal quality control checks, laboratory performance and systems audits and frequency, to be conducted annually during the life of an analytical services subcontract by Parsons ES or other contractor working for CSSA, including: (i) Method blank(s); (ii) Laboratory control sample(s); (iii) Calibration check sample(s); (iv) Replicate sample(s); (v) Matrix-spiked sample(s); and (vi) "Blind" quality control sample(s).	Quality control checks are discussed in Quality Assurance Project Plan Section 8.3 (this is an outside link to the AFCEE web site). Laboratory performance and systems audits and frequency are discussed in Quality Assurance Project Plan Sections 9.0 (this is an outside link to the AFCEE web site). Method blanks, laboratory control samples, calibration check samples, replicate samples, matrix-spiked samples and "blind" quality control samples are discussed in Quality Assurance Project Plan Sections 4.4.1 through 4.4.12 (this is an outside link to the AFCEE web site).
	(9) Preventive maintenance procedures and schedules;	Quality Assurance Project Plan Section 10.0 (this is an outside link to the AFCEE web site)
	(10) Corrective action for laboratory problems; and	Quality Assurance Project Plan Section 11.0 (this is an outside link to the AFCEE web site)
	(11) Turnaround time.	Turnaround times are addressed in the format of holding times for each analysis and matrix. Quality Assurance Project Plan Section 4.1.2 (this is an outside link to the AFCEE web site), Table 5.1.2-1, and Section 5.2 all address holding times for different methods, analyses and matrices.
B.2.C	Data Management Plan
B.2.C	The Respondent shall develop and implement a Data Management Plan to Document and track investigation data and results. This plan shall identify and set up data documentation materials and procedures, project file requirements, and project-related progress reporting procedures and documents. The plan shall also provide the format to be used to present the raw data and conclusions of the RFI.	Data generated during the RFI will be submitted to EPA and TNRCC in reports which will be inserted into Volume 3-1 (SWMUs), Volume 3-2 (AOCs), and Volume 5 (Groundwater). The SWMU and AOC investigation reports will include all data and information required by the TNRCC Risk Reduction Rules, as well as information specified to be included in RCRA Facility Investigation Guidance (OSWER Directive 9502.00-6D). All reporting will be in a format compatible with the Environmental Encyclopedia. Where appropriate, updates to the Background Information Report will be made.
		Data from investigation activities are stored in CSSA’s GIS, which includes the Tri-Services Spatial Data System (TSSDS, version 1.8) database in Microsoft SQL Server. The TSSDS database was established by the U.S. Army Corps of Engineers for storing environmental and infrastructure information. Project files are stored and maintained by the Austin office of Parsons Engineering Science. Files are generally project-specific; however, information pertaining to each site is also maintained in a separate set of files. Progress reports will be submitted quarterly, as specified in the order and in the first Quarterly Progress Report (included in Volume 1-1). A generalized list of report requirements is provided in Workplan Overview, Section 2.5.
B.2.C.1	Data Record
B.2.C.1.a	Unique sample of field measurement code;	Field Sampling Plan, Section 2.2.1.
B.2.C.1.b	Sampling or field measurement location and sample or measurement type;	Sampling locations for each SWMU and AOC are provided in Volume 1-2 and Volume 1-3.
B.2.C.1.c	Sampling or field measurement raw data;	Field Sampling Plan, Section 4.4
B.2.C.1.d	Laboratory analysis ID number;	Quality Assurance Project Plan Section 5.2 (this is an outside link to the AFCEE web site)
B.2.C.1.e	Property or component measured; and	Field Sampling Plan, Section 2.2.1
B.2.C.1.f	Result of analysis (e.g., concentration).	Quality Assurance Project Plan Section 8.0 (this is an outside link to the AFCEE web site)
B.2.C.2	Tabular Displays
B.2.C.2.a	Unsorted (raw) data;	Raw data, in addition to AFCEE forms, will be provided by the laboratory to the data validation team. Hard copies of this information will be provided to EPA upon request. This information will not be included in the Encyclopedia.

B.2.C.2.b	Results for each medium, or for each constituent monitored	Summary results for each medium will be provided in the reporting information behind each SWMU or AOC in Volume 3-1 (SWMUs), Volume 3-2 (AOCs), and Volume 5 (Groundwater), after a sampling event or delivery order action. Data related to groundwater chemistry will be provided in Volume 5. The summary tables will be set up like this example.
B.2.C.2.c	Data reduction for statistical analysis;	Data reduction for statistical analysis, if necessary, will included in the appropriate investigation report, which will be in Volume 3-1 (SWMUs), Volume 3-2 (AOCs), and Volume 5 (Groundwater).
B.2.C.2.d	Sorting of data by potential stratification factors (e.g. location, soil layer, topography); and	Sorting of data by potential stratification factors will be performed for each SWMU or AOC if it is appropriate. If needed for a site, the resulting information will be provided in Volume 3-1 (SWMUs), Volume 3-2 (AOCs), and Volume 5 (Groundwater). Sorted data will also be provided in Volume 5.
B.2.C.2.e	Summary data.	A summary of data results for each SWMU or AOC will be provided behind the corresponding tab in Volume 3-1 and Volume 3-2. Summary data for groundwater will be provided in Volume 5. Data summary will be appropriate after field efforts or delivery order actions.
B.2.C.3	Graphical Displays (e.g. bar graphs, line graphs, area or plan maps, isopleth plots, cross-sectional plots or transects, three dimensional graphs, etc.)
B.2.C.3.a	Sampling locations and sampling grids;	Sampling locations for each SWMU and AOC will be provided in Volume 3-1 and Volume 3-2. Groundwater sampling locations will be provided in Volume 5.
B.2.C.3.b	Boundaries of sampling areas, and areas where more sampling is required;	Boundaries for each SWMU and AOC will be provided in Volume 3-1 and Volume 3-2.
B.2.C.3.c	Levels of contamination at each sampling location;	Levels of contamination at each SWMU and AOC sampling point will be provided in Volume 1-2 and Volume 1-3. Groundwater contamination maps will be provided in Volume 5.

B.2.C.3.d	Geographical extent of contamination;	Defining the geographical extent of contamination for most CSSA sites may not be applicable (i.e. a trench where metal particles exist and are excavated and removed). Where applicable, site maps showing the extent of contamination may be found behind the corresponding tab in Volume 3-1 and Volume 3-2. Maps showing the extent of groundwater contamination will be provided in Volume 5. This information may also be viewed utilizing the CSSA GIS database, which is available through CSSA or Parsons ES..
B.2.C.3.e	Display contamination levels, averages, and maxima;	Contamination levels, where applicable, may be found in site maps behind the corresponding tab in Volume 3-1 and Volume 3-2. Contamination averages and maxima may be derived with information from the data summary tables. This information may also be viewed utilizing the CSSA GIS database.
B.2.C.3.f	Illustrate changes in concentration in relation to distance from the source, time, depth or other parameters;	Changes in contamination concentration levels, where applicable, may be found in site maps behind the corresponding tab in Volume 1-2 and Volume 1-3. This information may also be viewed utilizing the CSSA GIS database.
B.2.C.3.g	Indicate features affecting intramedia transport and potential receptors; and	Potential receptors and intramedia transport features may be viewed utilizing the CSSA GIS database.
B.2.C.3.h	Illustrate the structural geology in the area of CSSA, including detailed structural geology of CSSA.	Soils and Geology, Background Information Report
B.2.D	Health and Safety Plan
B.2.D.1.a	Health and Safety Plan (HSP) that includes facility description, including availability of roads, water supply, electricity and telephone service.	Health and Safety Plan, Section 1.2 gives a facility description. The route to the hospital depicts the availability of roads; Section 3.4.4 states that the field team will have potable water with them, should the base-wide water supply be unavailable, electric service is provided by CSSA or through generators, and Emergency Contacts lists telephone service instructions for CSSA, page 6.
B.2.D.1.b	HSP that describes the known hazards and evaluates the risks associated with each activity conducted, including exposure to contaminants during the implementation of interim measures at CSSA.	Health and Safety Plan, Section 2.3.
B.2.D.1.c	HSP that lists key personnel and alternates responsible for site safety, response operations, and protection of public health.	Health and Safety Plan, Section 1.4
B.2.D.1.d	HSP that delineates work areas.	Health and Safety Plan, Section 1.2
B.2.D.1.e	HSP that describes levels of protection to be worn by personnel in work areas.	Health and Safety Plan, Section 3.4
B.2.D.1.f	HSP that establishes procedures to control site access.	Health and Safety Plan, Section 4.1
B.2.D.1.g	HSP that describes decontamination procedures for personnel and equipment.	Health and Safety Plan, Section 3.4.3 and Section 3.4.4
B.2.D.1.h	HSP that establishes site emergency procedures.	Health and Safety Plan, Section 4.7
B.2.D.1.i	HSP that addresses emergency medical procedures for injuries and toxicological problems.	Health and Safety Plan, Section 2
B.2.D.1.j	HSP that describes requirements for an environmental surveillance program.	Health and Safety Plan, Section 3.2
B.2.D.1.k	HSP that specifies any routine and special training required for responders.	Health and Safety Plan, Section 3.1.
B.2.D.1.l	HSP that establishes procedures for protecting workers from weather-related problems.	Health and Safety Plan, Section 2.2.1 and Section 2.2.2
B.2.D.2.a	HSP shall be consistent with NIOSH Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities (1985).	Health and Safety Plan, Section 1
B.2.D.2.b	HSP shall be consistent with EPA Order 1440.1 – Respiratory Protection.	Health and Safety Plan, Section 1
B.2.D.2.c	HSP shall be consistent with EPA Order 1440.3 – Health and Safety Requirements for Employees engaged in Field Activities.	Health and Safety Plan, Section 1
B.2.D.2.d	HSP shall be consistent with Facility Contingency Plan.	Health and Safety Plan, Section 1
B.2.D.2.e	HSP shall be consistent with EPA Standard Operating Safety Guide (1984).	Health and Safety Plan, Section 1

B.2.D.2.f	HSP shall be consistent with OSHA regulations, particularly in 29 CFR 1910 and 1926.	Health and Safety Plan, Section 1
B.2.D.2.g	HSP shall be consistent with state and local regulations.	Health and Safety Plan, Section 1
B.2.D.2.h	HSP shall be consistent with other EPA guidance as provided.	Health and Safety Plan, Section 1
B.2.E	Community Relations Plan
B.2.E	Respondent shall prepare a Community Relations Plan which includes description of site background, history of community involvement at the site, community relations strategies, schedule of community relations activities, list of contact, local officials and interested parties.	Please see Community Relations Plan
^{1 CSSA Environmental Encyclopedia locations are accurate at the original date of publication, and may vary at later dates.}

The descriptions of all activities included behind the individual site tabs provides for a phased approach to meet the requirements of the Order and the RFI Workplan.

11.2 Closure Methodology

Planned RFI activities for closure of the SWMUs have been developed to comply with all appropriate regulatory requirements for closure of solid waste management units as stated in 40 CFR, part 265 and 30 TAC 335, subchapters A, E, and S. A discussion of these closure requirements may be found in Section 2 of the Work Plan Overview.

11.3 - Scheduling

A detailed schedule including work specified in projects which have recently been awarded is currently being prepared and will be included in the second Quarterly Progress Report which will be submitted on November 10, 1999.

A project organization chart is included in the first Quarterly Progress Report.

11.4 - Reporting Requirements

Reporting requirements for the RFI, outlined in the 3008 Order, will be met and have a format similar to that described in Section 3 of the Work Plan Overview.

The RFI Report shall include all of the requirements stated in Table 1 above, and will be formatted to fit into the CSSA Environmental Encyclopedia: Reports for each site will be included in Volume 3-1 and Volume 3-2, behind the appropriate site-specific tab. Reports related to groundwater monitoring, deep groundwater well installations, and other groundwater investigation activities will be included in Volume 5 of the Environmental Encyclopedia.