SWMU B-13 RFI Report Appendix D

Activity	Objectives	Action	Objective Attained?	Recommendations
Objective 1: Meet TNRCC Requirements for Site Closure
Attainment of Risk Reduction Standard Number 1: Closure/Remediation to Background
	Remove all hazardous and nonhazardous waste and waste residues and contaminated design and operating system components such as liners, leachate collection systems, and dikes from the unit or area of the unauthorized discharge. For remediation of media that have become contaminated by releases from a waste management unit or by other unauthorized discharge of hazardous or nonhazardous waste, the contaminated media must be removed or decontaminated to cleanup levels specified in this section (30 TAC 335.554(b) and (c)).	Geophysical survey, surface and subsurface sampling were conducted to determine if there is evidence of buried waste at the site. The geophysical survey indicated three anomalies which may be locations of buried waste. Analytical results for surface samples collected from around the three anomalies indicate exceedances of RRS1 closure criteria.	No. Since there is evidence that waste may be buried at the site, this objective has not been attained.	Excavate in areas of anomalies. Remove waste materials and recycle or properly dispose of them. Sample excavated soil and remediate or properly dispose.
	Determine compliance with RRS1 closure requirements by comparing to background as represented by results of analyses of samples taken from media that are unaffected by waste management or industrial activities. If the practical quantitation limit (PQL) is greater than background, then the PQL rather than background shall be used as the cleanup level provided that the person satisfactorily demonstrates to the executive director that lower levels of quantitation of a contaminant are not possible (30 TAC 335.554(d)).	Contaminant concentrations were compared to the second revised background levels (Parsons, February 2002) or RLs, which are equivalent to PQLs.	Surface soil samples exceeded background.	Extent of contamination should be determined through excavation and additional surface soil sampling.

Activity	Objectives	Action	Objective Attained?	Recommendations
	Attainment of cleanup levels shall be demonstrated by collection and analysis of samples from the media of concern (30 TAC 335.554(e)).	Surface and subsurface soil samples were collected at the site.	No. Since results of the sampling and geophysical survey indicate that there is buried waste at the site, further subsurface investigation and sampling is necessary.	Waste material should be excavated to determine if there is buried waste at the site. Surface and subsurface sampling should be conducted to verify that cleanup levels have been attained.
Objective 2: Meet Requirements of 3008(h) Order for RFI
RFI Workplan Requirements
Field Sampling (Detailed listing of methods and procedures are provided in project plans which are incorporated by reference).	Conduct field sampling in accordance with procedures defined in the project work plan, SAP, QAPP, and HSP.	All sampling was conducted in accordance with the procedures described in the project plans.	Yes.	NA
Facility Investigation
Characterization of Environmental Setting - Hydrogeology (B.3.A.1)	Evaluate hydrogeologic conditions at the site.	Not included in this phase of the RFI at SWMU B-13. Shallow groundwater was not encountered during drilling at the site. Groundwater of the Trinity Aquifer is being addressed through the Groundwater Investigation.	NA	NA
Characterization of Environmental Setting- Soils (B.3.A.2)	Characterize soils in accordance with USCS soil classification system (B.3.A.2(a)).	Soil types at the site are based on the SCS Bexar County Soil Survey (USDA, 1991) and are described in Section 1.2.1.	Yes.	NA
Determine soil pH (B.3.A.2(e)).	The pH of each of the soil types evaluated as part of the background metals concentration study was determined through laboratory analysis. According to those analyses, the pH of Krum Complex soils is 7.87.	Yes.	NA
Determine moisture content (B.3.A.2(g)).	The moisture content of each sample was analyzed. Moisture content values are provided in laboratory analytical packages.	Yes.	NA
Characterization of Environmental Setting – Surface Water and Sediment (B.3.A.3)	Characterize marshes, creeks, wetland areas, or ditches at the site.	No marshes, creeks, wetland areas, or ditches are present at the site. Direction of runoff flow has been evaluated in Section 1.2.1.	Yes	NA
Source Characterization (B.3.B)	Identify the source area (B.3.B.1).	A description of the source area is provided in Section 1.1.2.2.	Selection of surface and subsurface sampling locations was based on areas suspected to be contaminated and surface contamination was detected. Additional sampling is necessary in the northern and eastern portions of the site to further define the extent of contamination.	Additional excavation of waste disposal areas.
Identify the location of the unit/disposal area (B.3.B.2(a)).	In 1999, points along the boundary of each site were surveyed with a Rockwell Plugger GPS unit (estimated accuracy of ±25 feet). The points were identified by the CSSA Environmental Coordinator. The boundary of the site was established during field investigation, as shown on the figures.	Yes. Although the accuracy of the boundary survey of the site is estimated to have an approximate error of 25 feet, this accuracy is sufficient for closure under RRS1.	NA
Identify the type of unit/disposal area (B.3.B.2(b)).	The type of unit/disposal area was identified in the Environmental Assessment (ES, 1992) and by visual observation of waste in the field.	Yes. A geophysical survey, surface and subsurface sampling were performed to determine the extent of contamination.	NA
Identify design features (B.3.A.2(c)).	Information regarding design features was obtained during the Environmental Assessment (ES, 1992) and through visual observation during the field investigation. All available information regarding the design of the disposal site is provided in Section 1.1.2.1.	Yes	NA
Identification of past and present operating practices, period of operation, age of unit/disposal area, and method used to close the unit/disposal area (B.3.B.2(d), (e), (f), and (h)).	All known information regarding these items is provided in Section 1.1.2.1. This information is from the Environmental Assessment, records review, interviews, and visual observations.	To the extent possible with data available.	NA
Determine general physical conditions of the site (B.3.B.2(g))	The general physical condition of the site was determined during the field investigation. This information is presented in Section 1.1.2.3.	Yes.	NA
Identify waste characteristics, including type of waste placed in the unit, physical and chemical characteristics of the wastes, and migration and dispersal characteristics of the waste (B.3.B.3).	Records regarding historic waste disposal practices at CSSA are very limited. All known information, derived from the Environmental Assessment (if appropriate for your site), records review, interviews, and visual observations at the site is provided in Section1.3.	Yes, to the extent possible with the data available.	NA
Contamination Characterization – Soil (B.3.C.2)	Determine vertical and horizontal extent of contamination (B.3.C.2(a)).	Surface and subsurface samples were collected. Three surface samples exceeded RRS1 closure standards.	No. The lateral extent of contamination should still be investigated.	Excavation and additional sampling is recommended.
	Describe soil properties (B.3.C.2(c)).	See “Characterization of Environmental Setting – Soils” above.
	Identify the direction of contaminant movement (B.3.C.2(d)).	No actions taken.	NA	NA
	Extrapolate future contaminant movement (B.3.C.2(e)).	No actions taken.	NA	NA
	Implement a soil boring investigation to determine the extent of soil contamination. Soil gas monitoring will be performed during drilling of all borings. Laboratory analysis of borings for contaminants of potential concern will be performed on soils at depths where either visual contamination is evident, or soil gas concentrations indicate contamination. All boreholes shall be properly abandoned.	Surface and subsurface sampling to define potential contamination.	Yes.	Excavation in the area of the anomalies is recommended. Subsurface soil samples can be collected at that time to determine the vertical extent of contamination, and/or to verify that all waste and contaminated material has been removed.
	Prepare a map of all areas included in the investigation (B.3.C.2(i)).	Figures included in this report show all areas included in the investigation.	Yes.	NA
	All reporting limits should be below regulatory criteria.	RLs were approved by TNRCC on October 5, 1999. RLs are considered RRS1 standards for all analytes except metals.	Yes	NA
	Perform all analyses in accordance with the AFCEE QAPP.	All analyses were performed in accordance with the AFCEE QAPP and approved variances.	Yes	NA
	All data flagged with “U,” “F,” “M,” and “J” are considered usable for site characterization purposes.	Yes “M” flagged data are also considered usable. The matrix interference is minimal and does not significantly affect the sample results.	NA
		All data flagged with “R” are considered unusable.	No data was flagged “R.”	NA
Contaminant Characterization – Sediment and Surface Water (B.3.C.3)	Conduct a surface water and sediment investigation to characterize contamination resulting from releases at the Facility.	SWMU B-13 is located on a hillside, with an intermittent stream crossing it. This creek only contains water during and shortly after heavy precipitation. Therefore, surface water and stream sediments were not sampled as part of the SWMU B-13 investigation.	NA	NA
Potential Receptors (B.3.D)	Collect the information necessary to describe the human populations and environmental systems that are susceptible to contaminant exposure from the Facility.	Information regarding receptors is provided in the Risk Assessment Technical Approach Document (Volume 1-6). In addition, the Well Research Report identifies private groundwater users within 0.25-mile and public water suppliers within 0.5-mile of CSSA.	Yes	NA

Activity

Objectives

Action

Objective Attained?

Recommendations

Attainment of cleanup levels shall be demonstrated by collection and analysis of samples from the media of concern (30 TAC 335.554(e)).

Surface and subsurface soil samples were collected at the site.

No. Since results of the sampling and geophysical survey indicate that there is buried waste at the site, further subsurface investigation and sampling is necessary.

Waste material should be excavated to determine if there is buried waste at the site. Surface and subsurface sampling should be conducted to verify that cleanup levels have been attained.

Objective 2: Meet Requirements of 3008(h) Order for RFI

RFI Workplan Requirements

Field Sampling (Detailed listing of methods and procedures are provided in project plans which are incorporated by reference).

Conduct field sampling in accordance with procedures defined in the project work plan, SAP, QAPP, and HSP.

All sampling was conducted in accordance with the procedures described in the project plans.

Yes.

Facility Investigation

Characterization of Environmental Setting - Hydrogeology (B.3.A.1)

Evaluate hydrogeologic conditions at the site.

Not included in this phase of the RFI at SWMU B-13. Shallow groundwater was not encountered during drilling at the site.

Groundwater of the Trinity Aquifer is being addressed through the Groundwater Investigation.

Characterization of Environmental Setting- Soils (B.3.A.2)

Characterize soils in accordance with USCS soil classification system (B.3.A.2(a)).

Soil types at the site are based on the SCS Bexar County Soil Survey (USDA, 1991) and are described in Section 1.2.1.

Yes.

Determine soil pH (B.3.A.2(e)).

The pH of each of the soil types evaluated as part of the background metals concentration study was determined through laboratory analysis. According to those analyses, the pH of Krum Complex soils is 7.87.

Yes.

Determine moisture content (B.3.A.2(g)).

The moisture content of each sample was analyzed. Moisture content values are provided in laboratory analytical packages.

Yes.

Characterization of Environmental Setting – Surface Water and Sediment (B.3.A.3)

Characterize marshes, creeks, wetland areas, or ditches at the site.

No marshes, creeks, wetland areas, or ditches are present at the site. Direction of runoff flow has been evaluated in Section 1.2.1.

Yes

Source Characterization (B.3.B)

Identify the source area (B.3.B.1).

A description of the source area is provided in Section 1.1.2.2.

Selection of surface and subsurface sampling locations was based on areas suspected to be contaminated and surface contamination was detected. Additional sampling is necessary in the northern and eastern portions of the site to further define the extent of contamination.

Additional excavation of waste disposal areas.

Identify the location of the unit/disposal area (B.3.B.2(a)).

In 1999, points along the boundary of each site were surveyed with a Rockwell Plugger GPS unit (estimated accuracy of ±25 feet). The points were identified by the CSSA Environmental Coordinator. The boundary of the site was established during field investigation, as shown on the figures.

Yes. Although the accuracy of the boundary survey of the site is estimated to have an approximate error of 25 feet, this accuracy is sufficient for closure under RRS1.

Identify the type of unit/disposal area (B.3.B.2(b)).

The type of unit/disposal area was identified in the Environmental Assessment (ES, 1992) and by visual observation of waste in the field.

Yes. A geophysical survey, surface and subsurface sampling were performed to determine the extent of contamination.

Identify design features (B.3.A.2(c)).

Information regarding design features was obtained during the Environmental Assessment (ES, 1992) and through visual observation during the field investigation. All available information regarding the design of the disposal site is provided in Section 1.1.2.1.

Yes

Identification of past and present operating practices, period of operation, age of unit/disposal area, and method used to close the unit/disposal area (B.3.B.2(d), (e), (f), and (h)).

All known information regarding these items is provided in Section 1.1.2.1. This information is from the Environmental Assessment, records review, interviews, and visual observations.

To the extent possible with data available.

Determine general physical conditions of the site (B.3.B.2(g))

The general physical condition of the site was determined during the field investigation. This information is presented in Section 1.1.2.3.

Yes.

Identify waste characteristics, including type of waste placed in the unit, physical and chemical characteristics of the wastes, and migration and dispersal characteristics of the waste (B.3.B.3).

Records regarding historic waste disposal practices at CSSA are very limited. All known information, derived from the Environmental Assessment (if appropriate for your site), records review, interviews, and visual observations at the site is provided in Section1.3.

Yes, to the extent possible with the data available.

Contamination Characterization – Soil (B.3.C.2)

Determine vertical and horizontal extent of contamination (B.3.C.2(a)).

Surface and subsurface samples were collected. Three surface samples exceeded RRS1 closure standards.

No. The lateral extent of contamination should still be investigated.

Excavation and additional sampling is recommended.

Describe soil properties (B.3.C.2(c)).

See “Characterization of Environmental Setting – Soils” above.

Identify the direction of contaminant movement (B.3.C.2(d)).

No actions taken.

Extrapolate future contaminant movement (B.3.C.2(e)).

No actions taken.

Implement a soil boring investigation to determine the extent of soil contamination. Soil gas monitoring will be performed during drilling of all borings. Laboratory analysis of borings for contaminants of potential concern will be performed on soils at depths where either visual contamination is evident, or soil gas concentrations indicate contamination. All boreholes shall be properly abandoned.

Surface and subsurface sampling to define potential contamination.

Yes.

Excavation in the area of the anomalies is recommended. Subsurface soil samples can be collected at that time to determine the vertical extent of contamination, and/or to verify that all waste and contaminated material has been removed.

Prepare a map of all areas included in the investigation (B.3.C.2(i)).

Figures included in this report show all areas included in the investigation.

Yes.

All reporting limits should be below regulatory criteria.

RLs were approved by TNRCC on October 5, 1999. RLs are considered RRS1 standards for all analytes except metals.

Yes

Perform all analyses in accordance with the AFCEE QAPP.

All analyses were performed in accordance with the AFCEE QAPP and approved variances.

Yes

All data flagged with “U,” “F,” “M,” and “J” are considered usable for site characterization purposes.

Yes

“M” flagged data are also considered usable. The matrix interference is minimal and does not significantly affect the sample results.

All data flagged with “R” are considered unusable.

No data was flagged “R.”

Contaminant Characterization – Sediment and Surface Water (B.3.C.3)

Conduct a surface water and sediment investigation to characterize contamination resulting from releases at the Facility.

SWMU B-13 is located on a hillside, with an intermittent stream crossing it. This creek only contains water during and shortly after heavy precipitation. Therefore, surface water and stream sediments were not sampled as part of the SWMU B-13 investigation.

Potential Receptors (B.3.D)

Collect the information necessary to describe the human populations and environmental systems that are susceptible to contaminant exposure from the Facility.

Information regarding receptors is provided in the Risk Assessment Technical Approach Document (Volume 1-6). In addition, the Well Research Report identifies private groundwater users within 0.25-mile and public water suppliers within 0.5-mile of CSSA.

Yes