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Final SWMU B-6 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 SWDA, as amended by RCRA, and further amended by the HSWA of 1984. In accordance with the RFI requirements of the Consent Order, this report has been prepared to document the environmental condition and site closure requirements of SWMU B-6 and to recommend further investigation, if necessary, or to provide documentation necessary for site closure. The main objectives of the SWMU B-6 investigation are 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 the U.S. Air Force AMC Contract F11623-94-D-0024, Delivery Order RL17. AFCEE provided technical oversight for the delivery order. Based on the project SOW, a set of work plans was established to govern the fieldwork. These include:

Work Plan Overview (Volume 1-1, RL17 Addendum);

Site-Specific Work Plan (Volume 1-2, SWMU B-6);

Field Sampling Plan (Volume 1-4, RL17 Addendum); and

Health and Safety Plan (Volume 1-5, RL17 Addendum).

For this RFI report, Section 1 provides the site-specific background and closure standard. Section 2 describes field actions and closure evaluation. Section 3 summarizes the findings, evaluates 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 is 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-6

1.1.2.1   Site Description

SWMU B-6 was initially identified during a records review in 1993. According to the records, the site was used for miscellaneous solid waste disposal for an unknown amount of time and during an unknown time period (Parsons, 1993b). Aerial photographs from 1934, 1957, 1962, 1966, 1973, 1978, 1985, 1991, 1996, and 1999 were reviewed, but no disturbed ground in the vicinity of SWMU B-6 was apparent. The site was mapped during a field investigation conducted on March 6, 1996. SWMU B-6 is covered in native grasses and shrubs and is surrounded by a cover of native Live Oak trees. The site occupies approximately 0.17 acres of land.

Background information regarding the location, size, and known historical use of SWMU B-6 is included in the Environmental Encyclopedia (Volume 1-2, SWMU B-6). Volume 1-2 also includes a Chronology of Actions and a Site-Specific Work Plan Addendum for SWMU B-6.

1.1.2.2   Potential Sources of Contamination

Potential COCs at SWMU B-6 include VOCs, SVOCs, and metals. Metals (arsenic, barium, cadmium, chromium, copper, lead, mercury, nickel, and zinc) may occur due to the potential metallic nature of any waste that may have been disposed at the site. VOCs have occurred at other waste disposal sites at CSSA and are a contaminant typically associated with disposal areas. SVOCs may be present if burning took place at the SWMU.

1.1.2.3   Site Location

SWMU B-6 is located in the center of the western half of the North Pasture (Figure B6-1), and is approximately 2,300 feet from the western facility boundary. Figure B6-1 is based on the 1998 aerial photograph. The site is roughly elliptical in shape and covers about 0.17 acres in area. A dirt road runs along the western side of the site.

Livestock water supply well CS-G is approximately 450 feet north of the site, and Salado Creek is approximately 700 feet southwest of the site. The closest SWMU is SWMU B-22, about 830 feet southwest of SWMU B-6.

1.2 - Site Environmental Setting

1.2.1 - Site Soils and Topography

SWMU B-6 occurs in the gently undulating Tarrant soil association (Figure B6-2). These soils occur on nearly level to gently sloping areas, generally with 1 to 5 percent slopes. The soils are dark-colored, very shallow, calcareous, and clayey, and are best suited for native grasses and range use. They develop over hard limestone and have scattered stones and gravel on the surface and within the surface layer. Detailed descriptions of CSSA soil types are provided in the CSSA Environmental Encyclopedia (Volume 1-1, Background Information Report, Soils and Geology).

SWMU B-6 lies on the lower slope of a hill east of the Salado Creek floodplain. The ground surface elevation of the site area is approximately 1,305 feet above sea level, sloping moderately to the southwest. Drainage from the site flows southwest across a narrow dirt road and vegetated land towards Salado Creek. The site vegetation is predominantly native grasses, with large oaks near the perimeter.

1.2.2 - Geology

The Upper Glen Rose Formation is the uppermost geologic stratum in the area of SWMU B-6 (Figure B6-3). 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 where soils are poorly developed or eroded. Where present at CSSA, the thickness of the Upper Glen Rose is estimated to be up to 150 feet thick. It is underlain by the Lower Glen Rose Limestone, 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 facies of the Hensell Sand, which is estimated to be up to 150 feet thick under the CSSA area. The Bexar Shale consists of silty dolomite, marl, calcareous shale, and shaley limestone. The geologic strata dip approximately 10 to 12 degrees to the south-southeast at CSSA.

Based on published information, there are two known major fault (shatter) zones at CSSA: the North Fault Zone and the South Fault Zone. SWMU B-6 is located approximately 3,660 feet north of the northern edge of the North Fault Zone that trends to the northeast along the north end of the inner cantonment (Figure B6-3). Additional information on structural geology at CSSA can be found in the Environmental Encyclopedia (Volume 1-1, Background Information Report, Soils and Geology).

1.2.3 - Hydrology

In general, the uppermost hydrogeologic layer at CSSA is the unconfined Upper Trinity aquifer, which consists of the Upper Glen Rose Limestone. 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. Groundwater discharge occurs predominantly via natural springs, seeps, and by groundwater pumping. Regional groundwater flow in the Upper Trinity aquifer appears to be to the southeast.

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, the Cow Creek Limestone, and the Hammett Shale. 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. In general, groundwater within the Middle Trinity aquifer at CSSA flows in a north to south direction, with some seasonal fluctuations. However, the local flow gradient may vary depending on rainfall, recharge, and possibly well pumping.

The nearest surface water body is the intermittently flowing Salado Creek, which is approximately 700 feet southwest of SWMU B-6 (Figure B6-1). Salado Creek flows generally south through CSSA and exits the facility just inside the southwest corner of the East Pasture.

No site-specific information regarding groundwater is available. Well CS-G, which is an inactive livestock water supply well, is located approximately 450 feet north of SWMU B-6. Between 1994 and 2000, static water levels for Well CS-G have ranged between 246 (October 1997) and 316 (January 1997) feet BTOC. Well completion information is not available for this well.

1.2.4 - Cultural 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. No potential sites of cultural importance are close to SWMU B-6. The nearest cultural resource site is a Paleoindian and late Archaic site consisting of a burned rock midden which was recommended as ineligible for listing in the National Register of Historic Places. This site is located approximately 200 feet southeast of SWMU B-6.

1.2.5 - Potential Receptors

A land use survey evaluating local and possible future uses of groundwater and surface water, a water well survey, and sensitive environmental areas at CSSA was completed during December 15 and 16, 1999. The results of this survey, along with results from a more in-depth survey to identify potential receptors, points of human exposure, and possible constituent pathways is presented in Section 3 of the Technical Approach Document for Risk Evaluation (Volume 1-6).

Land within 0.25 mile of SWMU B-6 is classified a “Evergreen Forest Land” in Figure 1.1 of the Technical Approach Document for Risk Evaluation. There are no buildings within 0.25 mile of the site, but a pond known as the “Drop Zone Tank” is located approximately 1,500 feet northwest of the site area.

As described in Section 1.2.3, Well CS-G, is located approximately 450 feet north of SWMU B-6. Well CS-G was formerly used for livestock watering purposes; however, sucker rods in the well are no longer operational. Dichloromethane was detected in this well at a level of 6.0 µg/l in 1994, but levels of this chemical did not exceed the MCL (5.0 μg/L) in subsequent sampling events. No other COCs have been detected at levels above the MCL.

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 that overlook mechanical feeders and planted food plots is located in Figure 5.2 of the Technical Approach Document for Risk Evaluation (Volume 1-6). SWMU B-6 is located approximately 900 feet north east of hunting stand number 24. Four water reservoirs are maintained at CSSA for the purpose of sport fishing. Two of the reservoirs are located in the northwestern and northeastern portions of the North Pasture while the other two reservoirs are located near the western boundary of the Inner Cantonment.

The nearest potential habitat for local endangered species is a potential Black-capped Vireo habitat located approximately 1,500 feet southeast of the site. A potential Golden-cheeked Warbler habitat is located approximately 2,000 feet east of the site area.

1.3 - Previous Investigations

Previous investigations performed at SWMU B-6 are located in Volume 3-1, behind tab B-6 of the Environmental Encyclopedia.

A geophysical survey was conducted at the site in 1996, during which no geophysical anomalies were found. In addition, three surface soil samples were collected in 1996. These samples were designated B6-SS01, B6-SS02 and B6-SS03. The sample analyses, performed by ITS Laboratories, were deemed unusable by the EPA in 1999. A Work Plan Amendment was subsequently created in support of resampling and analysis to replace the invalid laboratory data (RL17 Work Plan Amendment for Data Quality Rework at SWMU B-6).

1.4 - Closure Standard

As described in Section 4.3 of the Risk Assessment Technical Approach Document (Volume 1-6), CSSA has opted to pursue closure of SWMU B-6 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 meet background concentrations, then the site will be closed under TRRP. A notification of intent to close sites identified to date (including SWMU B-6) in accordance with the former Risk Reduction Rule was sent to the TNRCC on July 12, 1999. TNRCC acceptance of this notification was received 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 the deed recordation requirement.

Since the COCs for SWMU B-6 are VOCs, SVOCs, and metals, the RRS1 standards should be the RLs for VOCs, and SVOCs, and the soil or rock background values for metals. 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 Soils and Bedrock (Parsons, February 2002).