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Final SWMU B-5 RCRA Facility Investigation/Closure Report

Section 1 - Introduction

On May 5, 1999, an Administrative Consent Order was issued to CSSA pursuant to §3008(h) of the Solid Waste Disposal Act as amended by the Resource Conservation and Recovery Act, and further amended by the Hazardous and Solid Waste Amendments of 1984. In accordance with the RFI requirements of the Consent Order, this RFI exercise was conducted to document the environmental condition of SWMU B-5 and to recommend further investigation, if necessary, or to provide documentation necessary for site closure. The primary objective of the SWMU B-5 investigation is to determine if the site meets TNRCC requirements for closure, as described in Section 1.4, and to meet requirements of the Consent Order.

This specific RFI was performed by Parsons under U.S. Air Force AMC Contract F11623-94-D-0024, Delivery Order RL17. AFCEE provided technical oversight for the delivery order. Based upon the project SOW, dated September 1995, a set of work plans were established to govern the fieldwork. These plans include:

Work Plan Overview

(Volume 1-1, Work Plan Overview and Rework Work Plan Addendum);

Site-Specific Work Plan

(Volume 1-2, SWMU B-5);

Field Sampling Plan

(Volume 1-4); and

Health and Safety Plan

(Volume 1-5).

For this RFI report, Section 1 provides the site-specific background and closure standard. Section 2 describes field actions and the closure evaluation. Section 3 summarizes the findings, evaluates the attainment of data quality objectives, provides recommendations, and certifies the site closure, if applicable. References cited in this report can be found in the Bibliography (Volume 1-1 of the Environmental Encyclopedia).

1.1 - Background and Site Description

1.1.1   CSSA

General information regarding the history and environmental setting of CSSA are provided in the CSSA Environmental Encyclopedia (Volume 1-1, Background Information Report). In that report, data regarding the geology, hydrology, and physiography are also available for reference.

1.1.2   SWMU B-5

1.1.2.1   Site Description

SWMU B-5 is a former small arms ammunition brass disposal area. The exact dates of usage for the site are unknown. The site is located adjacent to a gravel road (Figure B5-1) and appears disturbed in aerial photographs dating back to 1966. SWMU B-5 is mostly level and sparsely vegetated.

Background information regarding the location, size, and known historical use of the site is also included in the Environmental Encyclopedia (Volume 1-2, SWMU B-5). This volume includes a Chronology of Actions and a Site-Specific Work Plan for SWMU B-5.

1.1.2.2   Potential Sources of Contamination

Potential sources of contamination at SWMU B-5 include metallic leachate from metals debris and ammunitions brass along with explosives residue associated with spent ammunitions and brass waste placed over the ground surface. The potential COCs associated with these wastes include metals and explosives. VOCs are added as COCs to evaluate the potential for typical contaminants associated with disposal areas.

1.1.2.3   Site Location

SWMU B-5 is located in the south-central portion of the North Pasture at CSSA, directly north of Gate 6 and just inside the Outer Cantonment Area. The nearest base boundary lies approximately 5,000 feet east of the site area. SWMU B-5 is a relatively small site, covering approximately 1.2 acres in area. The site area is bounded on the west by a gravel road and on the south by a dirt road. Trees bound the northern and eastern edges of the site (Figure B5-1, Site Location Map).

1.2 - Site Environmental Setting

1.2.1   Site Soils and Topography

Soils present within the site area are representative of Krum Complex soils (Figure B5-2, Soils and Topography Map). The soils are typically calcareous clay. While no descriptions of subsurface conditions have been gathered at this site and based on investigations conducted in neighboring areas, it is reasonable to assume that limestone bedrock occurs within five feet of the land surface. Detailed descriptions of the various soil types present at CSSA are located in the CSSA Environmental Encyclopedia (Volume 2, Description of Soil Types and Bedrock).

The site contains little topographic relief and lies at approximately 1,260 feet above sea level. The ground surface within the site area of SWMU B-5 slopes approximately two degrees downward in a west-southwesterly direction (Figure B5-2). Vegetation present within the site area consists mostly of native grasses. To the north and east of the site area, trees dominate the vista.

1.2.2   Geology

The Upper Glen Rose is the uppermost geologic strata in the area of SWMU B-5 and the north pasture (Figure B5-3). The Upper Glen Rose consists of beds of blue shale, limestone, and marly limestone, with occasional gypsum beds. Generally, it outcrops in stream valleys and at the ground surface. The thickness of the Upper Glen Rose is estimated to be between 0 and 150 feet at CSSA. It is underlain by the Lower Glen Rose, which is estimated to be 300 feet thick beneath CSSA. The Lower Glen Rose is a massive, fossiliferous, vuggy limestone that grades upwards into thin beds of limestone, marl, and shale. The Lower Glen Rose is underlain by the Bexar Shale (regionally known as the Hensell Shale), which is estimated to be from 60 to 150 feet thick under the CSSA area. The Bexar Shale consist of silty dolomite, marl, calcareous shale, and shaley limestone. The geologic strata dip approximately 10 to 12 degrees to the south-southeast at CSSA.

SWMU B-5 is located within what is referred to as the North Fault Zone that trends northeast-southwest, and transects the central portion of CSSA (Figure B5-3). This fault (shatter) zone has been mapped with a width between 2,000 to 3,000 feet, and consists of multiple normal faults with small throws of displacement. Numerous faults with small displacements have been located near the site using mapping, seismic, and GPR techniques. Vertical displacement between 5 to 30 feet have been reported (Volume 1-1, Background Information Report), where the downthrown blocks typically occur on the southeast side of the fault. The fracture system associated with this fault zone has been attributed as a controlling structural feature for the migration of contaminants in the vadose zone as identified during investigations conducted for other areas at CSSA.

1.2.3   Hydrology

In general, the uppermost hydrologic layer at CSSA is the unconfined Upper Trinity aquifer, which consists of the Upper Glen Rose Limestone. Locally at CSSA, low-yielding perched zones of groundwater can exist in the Upper Glen Rose. Transmissivity values are not available for the Upper Glen Rose. Regionally, groundwater flow is thought to be enhanced along the bedding contacts between marl and limestone; however, the hydraulic conductivity between beds is thought to be poor. This interpretation is based on the observation that static well levels are discordant in adjacent wells completed in different beds. Principle development of solution channels is limited to evaporite layers in the Upper Glen Rose Limestone.

The Middle Trinity aquifer is unconfined and functions as the primary source of groundwater at CSSA. It consists of the Lower Glen Rose Limestone, the Bexar Shale, and the Cow Creek Limestone. The Lower Glen Rose Limestone outcrops north of CSSA along Cibolo Creek and within the central and southwest portions of CSSA. As such, principle recharge into the Middle Trinity aquifer is via precipitation infiltration at outcrops. At CSSA, the Bexar Shale is interpreted as a confining layer, except where it is fractured and faulted, therefore allowing vertical flow from the up-dip Cow Creek Limestone into the overlying, but down-dip Lower Glen Rose. Fractures and faults within the Bexar Shale may allow hydraulic communication between the Lower Glen Rose and Cow Creek Limestones. Groundwater flow within the Middle Trinity aquifer is toward the south and southeast and the average transmissivity coefficient is 1,700 gpd/ft (Ashworth, 1983). In general, groundwater at CSSA flows in a north to south direction. However, local flow gradient may vary depending on rainfall, recharge and possibly well pumping.

The closest surface water feature is a northeast-southwest trending tributary that drains southward to Salado Creek in the South Pasture. It is located approximately 1,200 feet west of the site (Figure B5-1). Well CS-16, the closest monitoring well to SWMU B-5, is located approximately 1,060 feet west of the site.

1.2.4   Cultural Resources

All of the structures on the post are considered historical resources. Cultural resources are prehistoric and historic sites, structures, districts, artifacts, or any other physical evidence of human activity considered important to a culture, subculture, or community for scientific, traditional, or religious purposes. The nearest cultural resource to SWMU B-5, a burned rock midden, is located approximately 3,300 feet northwest of the site area.

1.2.5   Potential Receptors

All of the land within ¼-mile radius of SWMU B-5 is evergreen forest land. None of the wells within ¼ mile of the site are currently used for water supply; however, Well CS-16, a former water supply well is located approximately 1,060 feet west of the site. The nearest residential area is approximately one mile to the west of SMWU B-5. A human and ecological sensitive receptor survey has been conducted at CSSA, and the results are presented in Section 3 of the Technical Approach Document for Risk Evaluation (Volume 1-6).

A small herd of cattle is maintained on CSSA by the USDA-ARC. The cattle roam freely throughout the Inner Cantonment and in selected areas of the North Pasture. CSSA also manages wild game species for the purpose of hunting. White-tailed deer, axis deer, and wild turkey all roam freely throughout CSSA. A map of deer hunting stands which overlook mechanical feeders and planted food plots is located in the Technical Approach Document for Risk Evaluation (Volume 1-6). SWMU B-5 is located approximately 750 feet northeast of hunting stand number 2. Four water tanks are maintained at CSSA for the purpose of sport fishing. Two of the tanks are located in the northwestern and northeastern portions of the North Pasture while the other two tanks are located near the western boundary of the Inner Cantonment.

The nearest potential habitat for local endangered species, a possible Black-Capped Vireo habitat, is located approximately 1,400 feet northwest of the site area. A potential Golden-Cheeked Warbler habitat, another local endangered species, is located approximately 2,300 feet northeast of SWMU B-5 (Parsons ES, 1993).

1.3 - Previous Investigations

A chronology of actions/investigations performed at SWMU B-5 is located in the “B-5” tab of Volumes 1-2 and 3-1 of the CSSA Environmental Encyclopedia. A field investigation was intended to be conducted at SWMU B-5 during September 1993 under a separate delivery order. Although vegetation at the site area had recently been cleared prior to the site survey, the site could not be located during the survey. Expected surficial evidence of fired brass was not found within the area indicated on the field map, but the area did contain two waste piles and some unspecified scattered surface debris. The SWMU boundaries were placed so that the various debris were encompassed within the site area.

1.4 - Closure Standard

As described in Section 4.3 of the Technical Approach Document for Risk Evaluation (Volume 1-6), CSSA has opted to pursue closure of most sites under the Risk Reduction Rule (30 TAC 335). If the site concentrations do not exceed background, then the site will be closed using RRS1. If the site exceeds background, then a determination will be made regarding the feasibility of cleaning the site to meet background concentrations. If the decision is made to clean the site to background, closure under RRS1 will be sought. However, if it is determined that the site cannot be closed to background, then closure under TRRP will be conducted.

A notification of intent to close sites identified to date (including SWMU B-5) in accordance with the Risk Reduction Rule was sent to the TNRCC on July 12, 1999. Acceptance of this notification was sent by TNRCC on October 5, 1999.

RRS1 requires that the site be closed following removal or decontamination of waste, waste residues, and contaminated operation system components; and demonstration of attainment of cleanup levels (30 TAC §335.554). If closure requirements under RRS1 are attained and approved by the TNRCC Executive Director, then the owner is released from deed recordation requirements.

Since the chemicals of potential concern for SWMU B-5 are VOCs and metals, the cleanup levels should be the RLs for VOCs and the background levels for metals. VOCs rarely occur naturally. Background metals levels were statistically calculated for CSSA soils and the Glen Rose Limestone, and are reported in the Second Revision to the Evaluation of Background Metals Concentrations in Soil Types (Parsons, February 2002).

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