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[Closure Plan]

Partial Facility Closure Plan for
B-20 Detonation Area
March 1994

Section 4
Closure Investigation

4.1  Data Quality Objectives

Data quality objectives (DQOs) are quantitative and qualitative statements that define the quality of the data required for closure investigation activities for the B-20 site.  The DQOs establish the level of certainty of a data set for achieving the objectives of the closure investigation.  The identification and development of DQOs result in selection of appropriate sampling and analytical methods that allow adequate level of confidence in the data to support the decisions regarding the potential necessity for corrective actions at the site.  The DQOs are established for each data collection activity associated with the B-20 closure and are presented in the QAPP (Appendix C).

The DQOs for the B-20 closure are developed as a two-step process.  The first step is to establish the objective of the remedial investigation and to define the criteria that will be used to determine the need for corrective action.  The second step is to identify a set of DQOs that will allow collection of data of sufficient quality and quantity to support the data uses for activities described under the first step.

The objective of the remedial investigation is to collect data for identification of corrective actions to achieve the closure performance standard described in section 3.2.  The results of a baseline RA will be employed as the criteria for assessing the need and nature of corrective actions for the B-20 site.  However, the data gathered during the closure investigation may also be used for site characterization, corrective measures study, and corrective action design and implementation.

The baseline RA for the site will consist of evaluation of environmental and human health risks posed by the residual contamination at the site based on appropriate exposure scenarios (section 5).  The residual contamination at the site will be characterized using various field actions described in detail in section 4.3.  These field actions include a magnetometer survey, and sampling and analysis of environmental media such as surface and subsurface soils, sediment and surface water.

The magnetometer survey is a field screening method using portable instruments.  The survey results are not contamination specific and will be used to locate buried metal objects which may be unexploded ordnance.  The results may also be used to select optimum locations for environmental media sampling.  The survey will be conducted to meet the Level 1 quality control (QC) requirements as defined in the EPA document entitled "Data Quality Objectives for Remedial Response Activities, Development Process", and dated March 1987 (EPA, 1987b).  The method specific quality assurance (QA) and QC requirements are described in the QAPP (Appendix C).

The environmental media sampling will be performed according to the sampling strategy described in section 4.2.  The samples will be analyzed in an offsite laboratory using the analytical methods described in section 4.3.5.  The target contaminants were chosen considering the unit operation history (section 2.3) and the results of the preliminary field investigation (section 2.5).  All sample analysis will be conducted to meet the Level 3 QC requirements as defined in the EPA DQO guidance document.  The method specific QA/QC requirements are presented in the QAPP.  Analytical data will be validate to ensure attainment of specific QA/QC requirements prior to data use.

4.2  Statistical Sampling Strategy

Based on the site characteristics and nature of contaminants, contamination distribution may vary both spatially and temporally.  A sampling strategy should collect sufficient number of samples to define the nature and extent of contamination.  In addition, the sampling strategy should be able to predict contaminant distribution with time.  hence, it is essential to formulate an adequate and representative sampling strategy that enables data collection to achieve the closure objective.  Sampling strategy involves definition of location and number of samples for each environmental media of concern.  Particulars of a statistical sampling strategy will depend on the anticipated variability in contaminant distribution, desired accuracy, prior knowledge of the site and contaminants, and cost of sampling and analysis.

Statistical techniques can be applied in identifying sample number and locations that will yield a reliable estimate of contaminant distribution at the site.  Frequently used statistical properties in designing a sampling program are accuracy (representativeness) and precision (variability).  The acceptable levels of sampling accuracy and precision are dependent on the data objectives.

Various statistical methods can be used to determine the accuracy and precision of a set of samples from a known population.  Of these, frequently used statistical sampling strategies in environmental sampling are judgmental (authoritative) sampling, simple random sampling and systematic random sampling.  Each of these sampling strategies is briefly described below.

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Judgmental Sampling:  This sampling strategy relies on the sampler's experience and knowledge of the site and waste distribution.  The sampler chooses the location and number of samples based on his/her knowledge of the site.  However, judgmental sampling can be combined with other statistical methods depending on the site conditions and acceptable level of bias.

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Simple Random Sampling:  In this sampling strategy, sampling locations are randomly chosen.  This requires essentially no prior knowledge of the site.  However, a large number of samples is required to achieve reliable precision.

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Systematic Random Sampling:  This is a refinement of random sampling and involves randomly selecting the first sampling location and subsequent samples are collected at a fixed distance and/or depth.

Appropriateness of a statistical sampling strategy is dependent on the data objectives, environmental media of interest, knowledge of site conditions and waste properties, and analytical method requirements.  The data objective of the B-20 closure investigation is to identify specific hazards at the site and to sufficiently quantify those hazards.  During the closure investigation, the environmental media of concern at the B-20 site are surface and subsurface soils, surface water, and sediments.  Information regarding the site conditions and contaminant distribution exist in the form of past operation knowledge and preliminary site investigation results.  Specific analytical methods for closure investigation are described in section 4.3.5, and are not expected to influence the sampling strategy.  Based on these factors, a statistical sampling strategy was developed for each environmental media of concern at the B-20 site.

4.2.1  Surface Soils

Waste disposal activities at B-20 occurred at or near the ground surface.  Also, open detonation activities may have resulted in some areal dispersion of waste residues.  Surface soil appears to be the primary environmental media of concern.  Any contamination present in surface soils may pose direct and indirect exposure risks.  Based on these factors, the data objective for surface soil samples is to obtain sufficient data for the baseline RA (section 5).

Substantial information is available on the site conditions and waste management activities that may influence the contaminant distribution in surface soils at the B-20 site.  The open detonation area appears to be limited to northern and central portions of the site as indicated by the presence of craters (Figure 2.3).  However, areas that do not contain craters may have been used for unrecorded disposal of small munitions or may not have recently been used for disposal activities.  The surface soils around the craters are considered probable zones of higher contamination than the rest of the site.

A combination of systematic random sampling and judgmental sampling is proposed for surface soils at the B-20 site.  Given the large area of the site (27.5 acres), application of simple random sampling would be cost prohibitive.  Furthermore, considering the available site information, the use of judgmental sampling is appropriate and effective.  However, large areas, such as quadrants A and H, exist where waste disposal activities may not be apparent to perform reliable judgmental sampling.  Systematic random sampling will be used to obtain data for such areas.  Proposed surface soil sampling locations for the B-20 area are shown in Figure 4.1.

The judgmental surface soil sampling at B-20 will consist of one soil sample from within selected crater areas and at least one sample within approximately 50 feet from the edge of those craters.  Exact locations of the judgmental samples will be determined by the sampler in the field.  These samples will provide contaminant data for suspected "hot spots" (craters) and in the immediate vicinity (kickout zones).  There are 15 craters identified at the site.  Craters 1 and 5 were previously sampled and found to contain arsenic above MSCs, thus these craters will be sampled again.  Crater 13 did not contain metals above MSCs and will not be resampled.  Also, craters 10 through 15 in quadrant D are clustered together.  Judgmental sampling will be used in this quadrant to sample two craters and two kickout zones.  The resulting data is judged to be representative of the six-center cluster.  Altogether, half of the fifteen craters will have judgmental samples collected at and near them for a total of fourteen judgmental surface soil samples.

The systematic random sampling will comprise one surface soil sample collected at the nodes of a regular grid spaced at 250 feet.  The starting point for layout of the grid will be randomly chosen at the site.  In the vicinity of the craters, judgmental samples may replace systematic random samples.  An estimated 26 surface soil samples may be collected through systematic random sampling.  Together, this sampling strategy is estimated to yield approximately 40 surface soil samples or about 1.5 samples per acre area.  This sample density is considered sufficient for the purposes of conducting the baseline RA.

4.2.2  Subsurface Soils

Subsurface soil or rock contamination may exist at B-20 due to below-grade detonation of the ammunition and contaminant migration from surface to deeper soils or the limestone bedrock. Subsurface soil/rock contamination may pose exposure risks during construction activities involving site disturbances, or by acting as a source for groundwater contamination.  Currently, no analytical data are available for the B-20 subsurface soils or bedrock.

During the preliminary investigation (section 2.5), no organic contaminants were found in surface soils, and only low levels of metals were present.  Considering the low vertical migration potential of metals, subsurface soil contamination from surface soils is unlikely, and thus, general contamination of subsurface soils is unlikely.  Furthermore, the estimated depth to groundwater at the site appears to be relatively large (200 feet or greater).  Hence, the subsurface rock (which has a low potential for contamination) is not expected to impact the groundwater.  Based on these factors, subsurface rock does not appear to be an environmental media of significant concern.  Therefore, contaminant identification and quantification are limited to suspected areas of subsurface contamination such as the craters where contaminant release below grade may have occurred during open detonation.

Based on the above discussion, judgmental sampling in the areas of suspected contamination is proposed for subsurface soil/rock sampling.  Therefore, two subsurface soil/rock samples will be collected from each selected crater using soil borings.  As the craters were created by the same process, and the materials in the pits that were destroyed were similar for each set of shots, half of the craters will be selected for sampling.  This number of soil borings and associated subsurface soil samples should be adequate to characterize the subsurface at B-20.

4.2.3  Sediment

Contamination may exist in sediments from surface migration of contaminants via runoff from the site soils.  Sediments may be found at the site in craters receiving some site drainage, an ephemeral stream on the site, a pond located in quadrant F, and the livestock pond.  Sediments may pose similar types of exposure risks as in the case of surface soils.

Low levels of methylene chloride, bis(2-ethylhexyl)phthalate, and metals were detected in sediment samples during the preliminary investigation (section 2.5).  Therefore, these areas and others will be sampled for data evaluation and verification.  A systematic random sampling strategy was chosen for sediments at the B-20 site.  This sampling will involve randomly choosing the first sampling point along the stream and then sampling both upstream and downstream, as applicable, at approximately 400-foot intervals.  The downstream limit will be defined by the livestock pond and the upstream limit will be the southern edge of the site where the stream begins.  This sampling strategy is estimated to collect approximately 4 sediment samples.

In addition to the statistical sampling described above, judgmental sediment samples from the livestock pond, the pond in quadrant F and crater 8 will be collected.  During the preliminary investigation, samples from these locations showed the presence of organics, albeit at low levels.  Judgmental samples may also be collected from any other crater that contains sediments at the time of the remedial investigation.

4.2.4  Surface Water

Surface water at the site consists of an ephemeral stream, a pond in quadrant F and the livestock pond.  Surface water contamination may occur from the site surface runoff.  The surface water samples collected during the preliminary site investigation contained low levels of metals.  However, the metal levels in the livestock pond sample were below the comparison criteria (Table 2.4).  Surface water contamination may pose a threat to the area ecology and groundwater quality.

Due to the limited occurrence of this environmental medium at the site and substantial information available, judgmental sampling of surface waters at the B-20 site is found most suitable.  Samples will not be collected from areas that did not contain contaminants above comparison criteria during preliminary sampling.  Therefore, one surface water sample each will be collected from the stream (if it contains water), the quadrant F pond and crater 8 water (if not dry).

4.2.5  Background Samples

Background samples will be collected for environmental media such as surface and subsurface soils to establish chemical characteristics of environmental media not impacted by any waste management activities.  There are not acceptable background locations at CSSA for collection of surface water and sediment samples which would be comparable to these media at the B-20 site.  A total of ten background samples each will be collected for surface soils and subsurface soils.

The analytical data for the background samples will be statistically evaluated to establish upper 95 percent confidence limit for each of the analytes.  The sample results exceeding the background 95 percent confidence limit will be considered statistically different from the background results.  However, if all background results for an analyte are below detection limits, the detection limits will be substituted for the background 95 percent confidence limit.

4.3  Field Actions

The remedial investigation of the B-20 area will be conducted in accordance with 31 TAC 335 Subchapter S and with the provisions of this plan.  In accordance with 31 TAC 335.6(d), CSSA will notify the EPA and the TNRCC in writing 10 days prior to beginning any investigation activities at the B-20 site.

The investigation activities are based on preliminary analytical results discussed in section 2.5 of this document.  The preliminary screening results included fifteen craters, surface water drainages, site boundaries, and scrap metal (inert remnants of exploded ordnance) over most of the site.  Surface soil, surface water, and sediment samples were collected.

The preliminary analytical data showed explosives were not detected in any of the samples.  No volatile organics or semivolatile organic compounds were detected in surface soil samples or surface water samples.  It is notable that no toluene or benzene (primary components of explosives but not degradation products of explosives) were detected in any of the samples.  However, methylene chloride was found in three sediment samples, and the semivolatile organic compound bis(2-ethylhexyl)phthalate was detected in crater 8 sediments.

Metals, with the exception of selenium and silver, were detected in the samples.  Surface soils and surface water contained arsenic, barium, cadmium, chromium, and lead.  Sediments contained arsenic, barium, cadmium, chromium, mercury, and lead.  Laboratory-measured pH indicated slightly basic surface waters, which would be expected because of limestone-weathered soils and limestone bedrock of the region.

The preliminary field mapping, observations, and analytical results were used to better define the B-20 site for specification of closure actions.  In particular, the proposed remedial investigation activities are based on preliminary results to effectively investigate the site for hazardous wastes with a cost-efficient approach.  The proposed activities were also compared and found similar to actions used at UXO sites by Department of Defense explosive ordnance specialists (EPA, 1993).

The following activities are the first phase of the remedial investigation:

  1. Prescreen the site for the presence of unexploded ordnance (UXO) and mark safe areas of traverse.

  2. Perform a magnetometer survey to locate subsurface UXO or scrap metal near areas of drilling.

  3. Drill and sample soil borings near selected craters in the B-20 area to determine both lateral and vertical extent of subsurface soil contamination.

  4. Perform verification sampling of surface soil, surface water, and sediments.

These tasks are summarized in Table 4.1.

Standard procedures for each of the above tasks include office and field record-keeping.  In the field, daily logs will be kept of that day's activity, field team names, date, times of activities, weather, field changes, personnel visiting the site, and field observations.  Copies of the logs will be kept in project files, as will copies of chain-of-custody forms.

The data generated from this phase of investigation will be analyzed, verified, and evaluated prior to preparing a remedial investigation report.  Should the data confirm that the site may be closed under risk reduction standard 2 without additional data, and that no UXO was found after screening the entire site, the report will be submitted to the EPA and the TNRCC with procedures, results, verification, and request for amended closure.

Should the data indicate that a baseline RA is necessary as the next step in closure actions, the remedial investigation report will discuss the results and propose additional work.

If there is insufficient data to finalize the remedial investigation report, or if additional data is required to perform a baseline RA, a second phase of remedial investigation will be performed.  The specific actions necessary to complete the investigative data set or to prepare for a baseline RA will be proposed and costed for the EPA and the TNRCC prior to initiating any phase II remedial investigation field actions.  Such actions might include additional soil borings, drilling of groundwater monitoring wells, and collection of additional samples in specified media.  As it is unknown at this time what phase II activities might be necessary, such activities are not further discussed in this document.

4.3.1  Prescreening

Prior to drilling or any other subcontractor actions, the site must be screened at the surface for safe passage of persons and equipment.  The preliminary investigation identified site boundaries and craters (areas of most intense demolition actions), but was not intended to define areas of safe traverse for non-UXO-experienced personnel.  CSSA has not had a UXO incident regarding cattle and other wildlife that have roamed the site since the last demolition actions in 1987.  In addition, CSSA personnel knowledgeable in UXO identification have walked through many portions of the site without observing any UXO.  Therefore, the potential for UXO appears low, but has not been completely ruled out as a potential hazard at the B-20 site.

The prescreening will be performed by a team of experienced and qualified UXO professionals.  The objectives of the prescreening will be to identify potential UXO and areas of safe traverse for non-UXO personnel and equipment.  Safe traverse is defined as an area or corridor within which there are no UXO and upon which it is safe to walk, drive mobile equipment, or perform aboveground field actions.

The first action of the UXO identification team will be to traverse the entire site and visually identify potential UXO either partially buried or on the ground.  At most sites, this action would be performed along with a magnetometer survey to detect UXO within a few feet of the ground surface (EPA, 1993).  However, the B-20 site is unique insofar as the general depth of soils is only a few inches deep (except in the crater areas), bedrock is immediately below the soil, and inert scrap metal is abundant across the site.  A magnetometer survey could be performed during this task, but it is likely that it will only detect scrap metal at the surface and that the proximity of scrap metal pieces to each other would cause interference with the magnetometer readings.  Because of the lack of soils, buried UXO is likely only in the crater areas.  Outside of craters, it is more probable that metal projectiles from demolition activities skipped against bedrock or were partially buried in a few inches of soil.

Based on the above discussion, the proposed action is to visually identify potential UXO.  The survey across the site will be in 5-foot traverses by an experienced UXO team taking all necessary health and safety precautions for UXO sites (EPA, 1993).  Should potential UXO be found, the UXO personnel will flag the area around the UXO object so as to differentiate it from areas of safe traverse and mark the location on the base map.  The potential UXO object will then be verified by CSSA demolition experts.  CSSA, RRAD, ES, and the regulatory personnel providing oversight on the B-20 closure will be informed within 24 hours, or as soon as possible, that UXO has been identified at B-20.

Depending upon the type of UXO identified and the area it is found in, CSSA demolition experts will present recommendations for appropriate disposal to the EPA and the TNRCC.  UXO can be removed for destruction at an appropriate facility, destroyed at the site, or left in place.  In most UXO situations, the best option is destruction in place (EPA, 1993).  UXO is hazardous waste, and leaving it in place would result in potential continuing release of hazardous waste.  Removing UXO requires a great deal of precaution, specialized equipment, very stable transport, and an appropriate receiving facility for destruction.  Risks are higher for the personnel handling the removal and transport when compared to destroying the UXO in place.  The latter option usually can be performed safely and efficiently without high risk to human health, especially as the B-20 site and CSSA demolition personnel have a history of demolition without incident.  Also, small items were generally disposed of at B-20 (Table 2.1), indicating that proper demolition in place should have little lasting effect on the environment.

If no UXO is found at the surface, then the following activity of flagging safe transit can be deleted from the remedial investigation.  However, if the UXO field team has any reasonable doubts as to the presence of potential UXO because of surface anomalies or other field observations, the flagging of safe transit routes will be performed.

After prescreening for UXO has been completed and it has been decided that safe transit corridors are necessary for health and safety precautions, safe transit routes will be flagged by the UXO-qualified team from the known non-hazardous zones (the roads surrounding the B-20 site) to those areas of surface and subsurface sampling.  Areas of safe transit will be identified in the field as corridors of stakes with easily identified flagging or surveyor lines and will also be marked on the site base map.  The routes will avoid identified UXO by at least 20 feet or more, based on professional experience.  The corridors will most likely north-south or east-west paths between the systematic sample locations shown in Figure 4.1.  Additional prescreening traverses to the judgmental sample locations (drilling at craters and ponds) will be performed.

4.3.2  Magnetometer Survey

Areas where potential buried UXO are most likely to be found will be surveyed using a magnetometer.  As discussed in section 4.3.1, buried UXO are most probable in craters dug out for previous demolition activities.  Other areas have bedrock a few inches below the surface, and it would be very difficult for UXO to be forced by trajectory completely into the bedrock.

A magnetometer measures the intensity of the earth's magnetic field in units of gamma or tesla (Benson et al, 1982).  Typical magnetometer readings are from a sensor (fluxgate or proton) which undergoes changes in magnetic levels in response to variations in the surrounding area.  The signals are fed to an output meter or recorder.  A gradient can also be measured as a difference between measurements at two different points.  Factors affecting the performance are magnetic properties of soil rock, e.g., iron content, mass of a buried object, distance and depth to a buried object, and the amount of permanent magnetism of an object.  The amount of magnetic anomaly measured by the magnetometer often varies widely over a traverse, and sometimes several passes in different orientations are necessary to identify an anomaly.

When magnetic properties of soil or rock are uniform, no local magnetic anomalies, or fluctuations in gamma readings, are observed.  When the magnetometer is passed over any object or native material having nonuniform magnetic properties, a response, or fluctuation in reading, is recorded.  Nearby metal objects cause difficulty in analyzing the data.

The survey will be performed by the UXO-qualified team at each of fifteen craters.  Drilling is not anticipated at all craters, but the magnetometer surveys will provide clearance for unexpected changes in the field program, if necessary.  As an abundance of scrap metal is in the vicinity of each crater as well as across the site, the metal is expected to cause some difficulty in interpreting the data.  When possible, UXO experts will direct removal of positively identified scrap metal at least 50 feet away from each crater so as to remove the surface interference.  Each crater survey will consist of a minimum of six traverses, three in a north-south direction and three in an east-west direction.  As the craters are generally 20 to 40 feet wide, the traverses will be 30 to 50 feet in length.  Surface anomalies will be identified and removed if possible.  The traverses may then be repeated to screen surface interference and identify buried metal objects.  A metal detector may also be used to aid in identifying the locations of subsurface objects within a few feet if possible.

Magnetic anomalies will be recorded and computer generated on a map for each crater.  The results will be used in identifying appropriate drilling locations at selected craters in areas where no anomalies were measured.

4.3.3  Subsurface Drilling and Sampling

The preliminary sample results (section 2.5) indicate the lack of explosives, volatile organics, and semivolatile organics in surface soil.  However, to verify that no explosive compounds migrated over time into the subsurface, it is necessary to drill for collection of subsurface soil samples.  Surface soil samples did not contain explosives, and the surface water and sediment samples, which might have contained explosives from site runoff, also did not contain explosives.  Therefore, the most probable place of subsurface contamination from explosive compounds is the subsurface in the area of the craters.

There are fifteen craters identified in the field at B-20.  One boring will be drilled in close proximity to each of seven craters.  Selected craters are shown by soil boring locations on Figure 4.1.  In addition, the six craters in quadrant D are within 75 feet of each other and many cedar trees.  Therefore, two borings will be drilled near accessible craters in quadrant D.  To provide the best coverage, drilling will be attempted near craters 10 and 11, and 14 and 15 (Figure 4.1).  Other areas of potential concern for subsurface contamination are the rocket motor standpipe (quadrant B) and the soil mounds (quadrant H).  One soil boring will be drilled next to the rocket standpipe, and two borings near each end of the soil mounds.  A total of ten soil borings will be drilled.

Total depth of each boring is based on demolition actions at the B-20 site.  According to CSSA SOPs (appendix B), pits typically were dug to hold munitions and then were covered with about 6 to 8 feet of soil.  The exact depth of the pits is unknown, but might be about 12 to 15 feet BGS.  Each boring will be at least 20 feet deep, or will be drilled 5 to 10 feet into undisturbed bedrock.  Drilling will be preceded by reconnaissance in the soil zone with a hand-held magnetometer to check for UXO.

Two subsurface soil or rock samples will be collected from each boring.  As discussed in section 4.2, these subsurface samples are considered judgmental samples for statistical evaluation, because they will be collected from known hot spots which are judged to be of sampling importance.  Surface soil samples will also be collected for analysis in selected craters as well as within 50 feet of those craters (section 4.2), providing three to four crater-specific soil samples for data analysis and evaluation of chemical constituents.  One of the subsurface soil/rock samples will be collected at depth in soils associated with the pit, or demolition activities, and one rock sample will be collected at the total depth of drilling.  The objective of the subsurface sample collection depths is to test chemical constituents near the pit bottom or sides, and within the bedrock to test for chemical migration.  Subsurface soil samples will be analyzed for metals and nitroaromatics/nitramines (explosives).

Ten background subsurface soil/rock samples will also be collected at CSSA at locations not recorded or suspected to have had contaminants at the surface or subsurface.  The background samples will be collected at 5 to 10 feet BGS in bedrock.  Analytical parameters will be metals, and the results will be statistically evaluated for comparison to B-20 subsurface soil results.

Drilling will be performed using a hollow stem auger rig capable of changing to air coring so that both soil and rock cores can be collected within each soil boring.  It is anticipated that hollow stem augers will be used for the first 1 to 15 feet within pit soil, and that air coring will be used after undisturbed limestone is encountered.  The augers will be of sufficient diameter to allow sample collection.  

It is not anticipated that groundwater will be encountered during drilling of soil borings, as the nearest groundwater well (CSSA well I) had a depth to water of 206 feet in October 1993.  However, perched water zones may be encountered after rainstorms.  If water is encountered during drilling, the boring will be left open for 24 hours to allow collection of that water.  If not enough water forms in the bottom of the boring to allow collection with a bailer, the boring will be grouted to ground surface for abandonment as a boring.

Subsurface soil samples will be collected in a split spoon sample through the hollow stem augers, and the rock cores will be collected in a core barrel  The soil will be placed in clean glass jars with Teflon(R)-lined lids, labeled, and placed into coolers to await transport to the laboratory.  Rock cores will be broken with a clean hammer to allow fit of the rock chips into glass jars.  The jars will be labeled and placed into a cooler.

Standard chain-of-custody procedures will be followed with each shipped cooler.  If the coolers are shipped to a laboratory, the Federal Express airbill number will be placed on each chain-of-custody form.  If a courier or contractor employee drives the coolers to a laboratory, records will be kept of each shipment.

The drilling equipment will be steam-cleaned prior to arriving on site.  Between borings, the drill rig, augers, and downhole sampling equipment will be steam-cleaned.  The sampling equipment will be cleaned before and after each use with an Alconox wash, potable water rinse, and distilled water rinse, and allowed to air dry.

In accordance with EPA guidance on investigation-derived wastes (IDW), the cleaning rinsate will be disposed of on the ground at the site unless field screening indicates the presence of contaminants (EPA, 1991).  Soil/rock cuttings will be left at each drilling site, unless field screening indicates the need to contain the cuttings for analysis.  If contaminants are known at the drilling site(s), the rinsate will be contained for analysis.

4.3.4  Verification Sampling and Analysis

To close the site, data must be collected that confirms the presence or absences of contaminants as defined by specific media concentrations.  The preliminary surface soil concentrations were compared to 31 TAC 335, Subchapter S MSCs for soil collected from 0 to 2 feet at industrial sites (Table 2.3).  Preliminary surface water results were compared most appropriately to state freshwater concentration criteria found at 30 TAC 307 (Table 2.4).  No comparable criteria for sediments with regard to human health were found.

Analytical results for the preliminary sampling event indicate the presence of metals in surface soil, surface water, and sediments (section 2.5).  One volatile organic compound and one semivolatile organic compound were detected only in sediment samples.  No explosive compounds were detected in any of the tested media.

To confirm the presence or absence of contaminants at the B-20 site, a statistical sampling approach was defined to best address all media of concern with a valid but limited number of samples and corresponding analyses (section 4.2).  The verification sampling and analyses will thus be concerned with surface soils, surface water, and sediments.

Surface soil samples will be collected as described in section 4.2.  To collect a representative number of surface soils samples, samples will be collected in a systematic statistical sampling grid of 250 x 250 feet.  Judgmental samples will also be collected at and within 50 feet of selected craters.  Where the grid and craters intersect, only one (rather than two) samples will be collected.  Up to 40 surface soil samples will be taken and analyzed for metals.  As no explosives were detected in surface soil samples collected during the preliminary sampling event, one-half of the remedial investigation surface soil samples will be analyzed for explosives for confirmation of previous results.

Ten background surface soil samples will be collected across CSSA to represent the three soil types found at B-20.  Analytical parameters will be metals, and the background results will be statistically evaluated and compared to B-20 surface soil sample results from the remedial investigation.

Surface water samples will be collected from those ponds or streams not dry during sampling.  It is anticipated that the ephemeral stream at the site will not contain surface water most of the year, but that the quadrant F pond and possibly crater 8 will contain enough surface water to sample.  The livestock pond will not be resampled, as detected metal levels were below comparison criteria.  The samples will be collected from clean surface water samplers so as to not include sediments.  The samples will be analyzed for metals, and one sample will be analyzed for explosives.  As the runoff channels begin at the southern boundary of the site and end at the pond, appropriate background surface water sampling locations are not available, e.g., other streams and ponds at CSSA are in different soil types and do not drain into the B-20 area.

Sediment samples will be collected along the ephemeral stream (Figure 4.1).  At least seven samples will be collected in approximately 400-foot intervals.  Sediments will be collected with a clamshell-type sampler after collection of surface water samples.  As with surface water, background samples appropriate to this stream are not available.  The sediment samples will be analyzed for volatile organics, semivolatile organics, and metals.  Three of these samples will be analyzed for explosives for verification purposes.

Because explosive compounds were not detected in any of the media tested during preliminary sampling, it does not appear that contaminants of concern have migrated into the subsurface.  As depth to groundwater is more than 200 feet BGS, groundwater will not be tested during the Phase I remedial investigation.  Should data evaluation indicate the need for groundwater sampling, appropriate actions based upon verified remedial investigation phase I data will be discussed and recommended to the EPA and TNRCC.

The analytical results will be presented in Level 3 format, and data validation will be performed on all remedial investigation samples.  The results will be presented in the remedial investigation report.

4.3.5  Analytical Procedures

Analytical techniques will be taken from Test Methods for Evaluating Solid Waste, U.S. Environmental Protection Agency, SW-846, November 1986 (EPA, 1986b).  Sampling techniques will be taken from TEGD (EPA, 1986a) and the Compendium of Superfund Field Operations Methods (EPA, 1987a).

Laboratory analytical methods are summarized in Table 4.2.  These methods are specified for water, soil, and sediment samples and are based on results of the preliminary sampling and analysis.  Surface and subsurface soil samples will be analyzed for explosives, metals, and geotechnical parameters.  Surface water samples will be analyzed for explosives, metals, and general water quality parameters.  Sediment samples will be analyzed for volatile organics, semivolatile organics, explosives, and metals.

Table 4.3 and Table 4.4 list the appropriate containers, preservatives, and holding times for soil and water, respectively.

A summary of the number of soil samples and associated QA/QC samples is shown on Table 4.5.  The samples are listed by surface soil, subsurface soil, and sediment samples.  Background samples and QA/QC samples such as trip blanks and duplicates are included in the total sample count per analysis.  Table 4.6 lists the number of surface water samples and associated QA/QC samples.

4.4  Data Evaluation and Reporting

The data collected from the field activities (section 4.3) and laboratory analyses will be evaluated to characterize any release of waste constituents at the B-20 site.  Based on the proposed field actions, the anticipated data will result from physical analyses such as magnetometer survey, borehole logging, and field observation, and from chemical analyses of samples collected at the site from different environmental media.  All chemical data will be validated using the procedures described in the QAPP (Appendix C) to ensure that the DQOs were achieved.  The analytical data collected during the remedial investigation may also be used for performing the baseline RA, CMS, and in corrective action design and implementation.  The following is a description of data evaluation and reporting methods that will be used in presenting the results of the closure investigation.

4.4.1  Magnetometer Survey

The proposed magnetometer survey will generate readings proportional to the intensity of earth's magnetic field.  The survey data will consist of survey point location and the magnetometer reading.  The data will be evaluated to determine indication of the presence of metal residues at the B-20 area.

The magnetometer survey data will be presented in tabular format.  The data will also be plotted in graphical form to create contours of magnetometer readings.  The magnetometer contours will be analyzed to locate "signature readings" for the presence of metal residues indicated by elevated magnetometer readings.  The findings of the data evaluation will be discussed in the remedial investigation report.

4.4.2  Surface Soil Samples

The analytical data will be generated from the proposed surface soil sampling activities.  The data will include sample location, analytical method, analytes, concentration of analytes found, and detection limits.  In addition, analytical QA/QC data will be generated.  The QA/QC data will be used to validate the sample results in accordance with the procedures listed in the QAPP (Appendix C).

The analytical data will be presented in tabular form.  The data will be evaluated to determine the nature, magnitude and extent of contaminants, if any, found in the surface soil samples.  If sufficient number of samples contain one or more contaminants significantly above background levels indicating significant areal coverage of contamination, the analytical data will also be presented in the form of contoured analyte concentrations.  These contours will be evaluated to determine contamination extents, waste volume and any migration trends.  The results of the data evaluation will be summarized in the closure investigation report.

4.4.3  Subsurface Soil Samples

The analytical data generated from the proposed subsurface soil sampling activities will include sample location, analytical method, analytes, concentration of analytes found, and detection limits.  Also, a log of soil type and conditions will be recorded in the field during drilling of soil borings.  Analytical QA/QC data will be generated and used in data validation as described in section 4.4.2.

The analytical data will be presented in tabular form.  Based on the analytical results, the data may also be presented in a graphical form as data flags at the sample locations.  The subsurface soil samples will be collected from suspected "hot spots" (craters).  The data will be evaluated to determine the nature, magnitude and vertical extent of contaminants in the subsurface soil samples.  In addition, soil boring logs will be prepared to define the vertical profile of the soil types and conditions at the borehole locations.  These logs will  be evaluated to determine subsurface conditions.  The results of the data evaluation will be summarized in the closure investigation report.

4.4.4  Sediment Samples

The analytical data for the proposed sediment sampling activities will include sample location, analytical method, analytes, concentration of analytes found, and detection limits.  In addition, analytical QA/QC data will be generated and used in data validation as described in section 4.4.2.

The analytical data will be presented in tabular form.  Based on the analytical results, the data may also be presented in a graphical form as data flags at the sample locations.  The data will be evaluated to determine the nature, magnitude and vertical extent of contaminants in the sediment samples.  The results of the data evaluation will be summarized in the closure investigation report.

4.4.5  Surface Water Samples

The analytical data for the proposed surface water sampling activities will include sample location, analytical method, analytes, concentration of analytes found, and detection limits.  Analytical QA/QC data will be generated and used in data validation as described in section 4.4.2.

The surface water samples analytical data evaluation and reporting will be similar to those of the sediment samples (section 4.4.4)

4.4.6  Miscellaneous Data

In addition to the data types discussed in section 4.4.1 through section 4.4.5, other data may be obtained during the remedial investigation activities.  These data my include visual observations, health and safety monitoring, and historic operating or monitoring records.  These data will be included as appropriate in the remedial investigation report.

4.5  Remedial Investigation Report

After completing the remedial investigation, CSSA's contractor will prepare a remedial investigation report.  However, should additional (phase II) data be required to complete the investigation, an interim technical report will be prepared for submittal, and the final remedial investigation report be prepared after all data has been collected, analyzed, and evaluated.

The remedial investigation report will include descriptions of all field activities, deviations from this closure plan, survey, drilling, and sampling techniques, analytical procedures, and analytical results.  A data validation report will also be prepared for submittal.  The report conclusion will indicate the characterization of the site with respect to environmental media, chemical constituents, background analysis, and the presence or absence of hazardous waste at the site.

CSSA will submit the final report to the EPA and TNRCC.  EPA and TNRCC will review the report for approval or recommendations for further investigation.