[Home]

Correspondence with
United States Fish and Wildlife Service

Links

Request for Vegetation Clearing Activities

I. Purpose of Report

This report is submitted to ensure that the proposed vegetation clearing activities necessary to support the closure of the B-20 former open burn/open detonation (OB/OD) area at Camp Stanley Storage Activity (CSSA) in Boerne, Texas complies with the Endangered Species Act (ESA). This work is being performed by Parsons Engineering Science (Parsons ES), previously Engineering-Science, Inc. (ES), under contract to Armstrong Laboratory/OEB at Brooks Air Force Base (AFB), Texas.

II. Regulatory Basis

Closure of the B-20 former OB/OD area is being conducted in compliance with a Compliance Order sent to CSSA on June 30, 1993. The U.S. Environmental Protection Agency (EPA), Region VI, Resource Conservation and Recovery Act (RCRA) Enforcement, Texas Section, issued this compliance order which required that CSSA immediately cease operation of the unit and prepare a closure plan for the unit in accordance with the applicable regulations. The compliance order required that the B-20 closure plan comply with federal and state regulations (40 Code of Federal Regulations (CFR) 265 Subpart G and Title 30 Texas Administrative Code (TAC) Chapter 335 Subchapter S, respectively) for closure of hazardous waste management units (Parsons ES, 1995).

III. Proposed Action

The proposed action is to reduce the density of vegetation in and around the B-20 site. This action is considered necessary by the unexploded ordnance (UXO) professionals to insure the safe detection, and subsequent removal, of all UXO items associated with past activities of the B-20 site. Removal of UXO items is required to insure compliance with the EPA Compliance Order for closure of the B-20 site. UXO items pose an immediate threat to human health and the environment.

The reduction in vegetation density will be accomplished primarily by the removal of junipers that constitute the mid-canopy and understory layers of the surrounding woodland. For the most part, these junipers form a dense barrier that restricts safe movement and severely limits ground visibility necessary for the safe detection of UXO. Vegetation removal will be performed by a team of qualified professionals from UXB International in Chantilly, Virginia. Vegetation removal will be accomplished by hand-held equipment, Bobcat mounted, hydraulic tree removal equipment, and to a limited extent, fire. Bobcat equipment has been selected over bulldozer clearing to minimize damage to the environment. Removal of broadleaf shrubs and trees will be avoided or limited to the extent that operational safety allows.

RRAD is proposed for realignment, no changes to the CSSA mission and military activities are expected in the future.

IV. Native Vegetation

The CSSA site is typical of the Balcones Canyonlands portion of the Edwards Plateau, encompassing a complex of limestone hills, drainages, and valleys with several springs and intermittent streams dispersed throughout (Riskind and Diamond, 1988). The upper drainages of Salado Creek occupy much of the central portion of the site. Elevation ranges from about 1,100 feet (ft) above mean sea level to about 1,500 ft above msl. The general upland vegetation community type is classified as mainly an evergreen woodland of the Ashe Juniper-Oak (Juniperus Ashei-Quercus sp) Series, and there is a minor riparian component of the Sugarberry-Elm (Celtis laevigata-Ulmus sp) Series (Diamond et al., 1987).

Approximately one-third of the property has been modified for military purposes, primarily to accommodate munitions storage and troop training activities in earlier times. Paved roads, rail lines, and a variety of buildings which support these functions are concentrated in the inner cantonment area. Remains of other buildings and infrastructure are also dispersed throughout the site (ES, 1993).

The current condition of the soils and vegetative cover in the "undeveloped" two-thirds of the site suggests previous overgrazing, land clearing for agricultural purposes, and suppression of natural fires. Management directed toward cattle grazing and game production has resulted in most of the property being maintained in an open grassland or disturbance savannah condition. Selective brush removal, particularly of the Ashe juniper, and mowing of some areas occur periodically. Supplemental food and water for stock and wildlife are provided throughout the site. Prescribed burning in some areas had been conducted in past years. However, none is done currently (ES, 1993).

The majority of the wooded uplands are characterized, generally, by a broken canopy of older live oaks (Quercus fusiformis) with somewhat younger Ashe junipers occupying the midstory and invading open areas in the woodlands. Where active juniper removal is occurring, the vegetative cover type has more of an oak/oak motte savanna appearance. Spanish oak (Q. buckleyi) is present in some areas, but is not abundant, and very little mixed shrub development is noted (ES, 1993).

The broader floodplain areas have generally been maintained as open fields. The smaller drainage areas over most of the site contain very little cedar elm (Ulmus crassifolia) or other mixed hardwood species normally associated with such area, and instead are generally dominated by stands of live oak and Ashe juniper (ES, 1993).

V. B-20 Unit Description

The B-20 unit is a 33.5-acre field surrounded by wooded areas in the northeastern portion of CSSA (Figure 3). The vegetation of the B-20 unit is composed primarily of grasses with sparsely scattered Ashe juniper and live oak shrubs. Gravel roads form the south, west, and north boundaries of the site. Site boundaries and other features are shown in Figure 4. The general vegetation community type surrounding the B-20 unit

Enforcement, Texas Section, issued this compliance order which required that CSSA immediately cease operation of the unit and prepare a closure plan for the unit in accordance with the applicable regulations. To effect clean closure of the B-20 site all unexploded ordnance (UXO) must be removed from the site. UXO items pose an immediate threat to human health and the environment. The proposed action is to reduce the density of vegetation in and around the B-20 site. This action is considered necessary by the UXO professionals to insure the safe detection, and subsequent removal, of all UXO items associated with the past activities of the B-20 site to insure compliance with the EPA Compliance Order for site closure.

VI. Figures