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Activity |
Objectives |
Action |
Objective
Attained? |
Recommendations
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Objective
1: Meet TNRCC Requirements
for Site Closure |
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Attainment of Risk Reduction Standard Number 1: Closure/Remediation to Background |
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Attainment of Risk Reduction Standard 1 |
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)). |
A
geophysical survey was conducted to determine if there is evidence of
buried waste at the site. |
The
geophysical survey indicated that there are no electromagnetic anomalies
at the site, therefore, buried waste is not suspected.
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RRS1
site closure is recommended. |
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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 Second Revision to the Evaluation of
Background Metals Concentrations in Soils and Bedrock at CSSA (Parsons,
February 2002) or PQLs. |
Yes.
All results were below background metals levels or reporting
limits. |
RRS1
site closure is recommended. |
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Attainment of Risk Reduction Standard 1
(continued) |
Attainment
of cleanup levels shall be demonstrated by collection and analysis of
samples from the media of concern (30 TAC 335.554(e)). |
Surface
soil samples were collected at the site and analyzed for contaminants of
potential concern, including metals, VOCs, and SVOC’s. |
Yes.
See above. |
RRS1
site closure is recommended. |
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Objective 2:
Meet Requirements of 3008(h) Order for RFI |
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RFI Workplan Requirements |
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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.
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NA |
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Facility Investigation |
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Characterization
of Environmental Setting - Hydrogeology (B.3.A.1) |
Evaluate
hydrogeologic conditions at the site. |
Hydrogeological
evaluation is not included in this phase of the RFI at SWMU B-6.
Drilling did not take place at B-6 therefore shallow groundwater
was not encountered. Groundwater
of the Trinity Aquifer is being addressed through the Groundwater
Investigation. |
NA |
NA |
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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.
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Yes. |
NA |
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Characterization
of Environmental Setting- Soils (B.3.A.2) (cont.) |
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 Tarrant soils
is 8.03. |
Yes. |
NA |
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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 |
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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. |
Sampling
at the site was biased toward areas most suspected of contamination.
No contamination was found. |
NA |
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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 measurement points
were identified by the CSSA Environmental Coordinator.
The boundary of the site was reviewed and adjusted, if necessary,
based on observations made during the field investigation. |
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 |
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Identify
the type of unit/disposal area (B.3.B.2(b)). |
The
type of unit/disposal area was identified during a records review in 1993. |
Yes.
A geophysical survey and surface soil sampling were performed.
No evidence of buried waste was found, and surface soil samples
indicated no waste residue. |
NA |
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Source
Characterization (B.3.B) (cont.) |
Identify
design features (B.3.A.2(c)). |
All
available information regarding the design of the disposal site is
provided in Section 1.3. |
Yes,
to the extent possible with data available. |
NA |
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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 1.3.
This information is from the records review. |
To
the extent possible with data available. |
NA |
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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. |
Yes. |
NA |
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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 records review is provided
in Section 1.1. |
Yes,
to the extent possible with data available. |
NA |
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Contamination
Characterization – Groundwater (B.3.C.1) |
Characterize
the vertical and horizontal extent of groundwater contamination. |
Not
included in this phase of the RFI. Groundwater
of the Trinity Aquifer is being addressed through the Groundwater
Investigation. |
NA |
NA |
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Contamination
Characterization – Soil (B.3.C.2) |
Determine
vertical and horizontal extent of contamination (B.3.C.2(a)). |
Surface
soil samples were collected to determine the vertical extent of
contamination, if any. |
Yes.
No contamination above RRS1 criteria was reported. |
NA |
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Describe
soil properties (B.3.C.2(c)). |
See
“Characterization of Environmental Setting – Soils” above. |
NA |
NA |
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Identify
the direction of contaminant movement (B.3.C.2(d)). |
No
samples collected at SWMU B-6 exceeded closure criteria. |
NA |
NA |
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Contamination
Characterization – Soil (B.3.C.2) (cont.) |
Extrapolate
future contaminant movement (B.3.C.2(e)). |
No
samples collected at SWMU B-6 exceeded closure criteria. |
NA |
NA |
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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. |
No
soil boring samples were collected at SWMU B-6. |
A
soil boring investigation is not considered warranted at SWMU B-6 since
there is no evidence of subsurface waste nor geophysical anomalies. |
NA |
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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 |
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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. Background metals levels, approved by the TNRCC in April
2002, are RRS1 standards for metals. |
Yes. |
NA |
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Perform
all analyses in accordance with the AFCEE QAPP. |
All
analyses were performed in accordance with the AFCEE QAPP and approved
variances. |
Yes. |
NA |
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All
data flagged with “U,” “F,” and
“J” are considered usable for site characterization and closure
purposes. |
Yes. |
NA |
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Contaminant
Characterization – Sediment and Surface Water (B.3.C.3) |
Conduct
a surface water and sediment investingation to characterize contamination
resulting from releases at the Facility. |
Salado
Creek is located 900 feet to the southwest of SWMU B-6.
Surface water was not sampled as part of the B-6 investigation.
Sampling of sediments in association with SWMU B-6 investigation is
not warranted since no contamination was detected in the surface soils at
SWMU B-6. |
NA |
NA |
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Potential
Receptors (B.3.D). |
Collect
the information necessary to describe the human populations and
environmental sysytems 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 |
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