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SWMU B-8 RCRA Facility Investigation 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 HSWA of 1984. In accordance with the RFI requirements of the consent order, this report has been prepared to document the environmental condition of SWMU B-8 and to recommend further investigation, if necessary, or to provide documentation necessary for site closure. The main objectives of the SWMU B-8 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 Orders RL17 and RL33. AFCEE provided technical oversight for the delivery order. Based on the project SOW, a set of work plans to govern the fieldwork were established. These include:

Work Plan Overview

(Volume 1-1, RL17 and RL33 Addenda);

Site-Specific Work Plan

(Volume 1-2, SWMU B-8);

Field Sampling Plan

(Volume 1-4, RL17 and RL33 Addenda); and

Health and Safety Plan

(Volume 1-5, RL17 and RL33 Addenda).

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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 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 CSSA Environmental Encyclopedia (Volume 1-1, Bibliography).

In addition to the consent order requirement to conduct an RFI, interim measures are also required to address SWMU B-8 soil that has been inspected to remove UXO. The UXO removal activities are described in this report, but activities related to the interim measures are addressed in the Soil Pile Disposition Report, being prepared under a separate delivery order.

1.1 - Background

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-8

1.1.2.1   Site Description

SWMU B-8 is a former burn area and suspected disposal trench located within the outer cantonment of CSSA (Figure B8-1) where fire bricks and ammunition were reportedly disposed. An approximately 0.5-acre area appeared to be disturbed in a 1966 aerial photograph. The 1973 and 1986 aerial photographs do not show disturbance in this area. As described in Section 1.3, a geophysical survey conducted at the site in 1995 indicated an electromagnetic anomaly in the area.

The site is mostly level and covered with sparse vegetation and a thin soil profile. Except for cattle and wildlife grazing, no other activities currently take place at SWMU B-8. There are no utilities at SWMU B-8; however, an overhead utility line trending northeast-southwest and an abandoned underground 4-inch diameter pipe are located just south of the site. Figure 3.1 of the Technical Memorandum on Geophysical Surveys shows the locations of these utility lines. A gravel road leading into the western portion of the outer cantonment from Gate 6 passes just to the northeast of SWMU B-8. Background information regarding the location, size, and known historical use of SWMU B-8 is also included in the Environmental Encyclopedia (Volume 1-2, SWMU B-8). Volume 1-2 also includes a Chronology of Actions and a Site-Specific Work Plan Addendum for SWMU B-8.

1.1.2.2   Potential Sources of Contamination

The potential source of contamination at SWMU B-8 was considered to be residue of burned waste at the ground surface and potentially buried waste, suspected of consisting of fire bricks and ammunition. There are no records available confirming possible waste disposed at the site. Many types of waste potentially were disposed there. Upon excavation, waste in other trenches at CSSA has been found to consist chiefly of metallic debris; therefore, this was considered to be the most likely waste type at SWMU B-8. Although liquid chemical wastes were known to be disposed at the SWMU O-1, it is possible that some paints, solvents, or fuels may also have been disposed at SWMU B-8. Fuels may also have been used to ignite fires at the site.

1.1.2.3   Site Location

SWMU B-8 is located within the North Pasture area of the outer cantonment (Figure B8-1). The SWMU is approximately one mile west of the nearest facility boundary. Well CS-16, the nearest well to the site, is located about 1,000 feet to the southwest. AOC 41 is located approximately 100 feet south of the site, and a gravel road forms the northeast boundary of the site.

1.2 - Site Environmental Setting

1.2.1   Site Topography and Soils

The elevation of the site is approximately 1,260 feet above sea level (Figure B8-2), and the ground surface slopes gently to the southwest. Surface runoff from the site drains to the southwest via an unnamed intermittent creek, which eventually drains to Salado Creek. The site is relatively flat, and vegetated with native grasses.

SWMU B-8 lies entirely within the Krum Complex soils. Detailed descriptions of the CSSA soil types are provided in the CSSA Environmental Encyclopedia (Volume 1-1, Background Information Report, Soils and Geology). Most CSSA soils are typically calcareous clay, ranging in depth from 4 to 60 inches and are underlain by limestone. SWMU B-8 appears to be fairly typical, with silty clay observed to a depth of approximately 6 feet bgs.

1.2.2   Geology

The Upper Glen Rose formation is the uppermost geologic strata in the area of SWMU B-8 and in the north pasture (Figure B8-3). 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. The thickness of the Upper Glen Rose is estimated to be up to 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 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 current published information, there are known to be two major fault (shatter) zones at CSSA: the North Fault Zone and the South Fault Zone. SWMU B-8 is located north of both of these zones (Figure B8-3). Additional information on structural geology at CSSA can be found in the Environmental Encyclopedia (Volume 1-1, Background Information Report, Soils and Geology).

At SWMU B-8, the near-surface site geology consists of 1.5 to 6 feet of surface soils composed chiefly of silt and clay. Upper Glen Rose Limestone was encountered at depths as shallow as 1.5 feet bgs. At SWMU B-8, this limestone was pale yellow to pale brown, weathered near the surface and marly. The limestone was dry, hard, and for the most part, massive. Allochemical constituents included pelecypods and bivalves, as well as assorted shell fragments. Boring logs are provided in Appendix A.

1.2.3   Hydrogeology

At CSSA, the uppermost hydrogeologic layer 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; however, no perched groundwater was encountered in the SWMU B-8 borings. Transmissivity values are not available for the Upper Glen Rose. 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 at approximately the same elevation. Principal development of solution channels is limited to evaporite layers in the Upper Glen Rose limestone. Groundwater discharge occurs predominantly via natural springs, seeps, and pumping. Regional groundwater flow 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, and the Cow Creek Limestone. The Lower Glen Rose Limestone outcrops at CSSA along Cibolo Creek and within the central and southwest portions of CSSA. Principal 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.

No site-specific information regarding groundwater is available. Groundwater was not encountered at any borings drilled at SWMU B-8, nor did any water accumulate in the open boreholes prior to their abandonment. The nearest well (Well CS-16), which is an inactive drinking water well, is located approximately 1,000 feet southwest of SWMU B-8. Water levels measured in Well CS-16 have ranged from 78.58 (November 1998) and 316.88 (April 1995) feet below top of casing (Volume 5, Introduction to Quarterly Monitoring Program, Table 3).

No creeks, streams, or ponds are located within SWMU B-8; however, a drainage channel that leads to Salado Creek is located approximately 90 feet to the northwest of the site. More information regarding surface water hydrology at CSSA is in the Environmental Encyclopedia (Volume 1-1, Background Information Report, Surface Water Resources).

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. The nearest site of potential archeological significance is a Salado Creek drainage channel, approximately 90 feet to the northwest of SWMU B-8. This drainage channel has the potential to be an area of high prehistoric archaeological potential.

1.2.5   Potential Receptors

A land use survey discussing 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 in accordance with the TNRCC TRRP. 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 are presented in Section 3 of the Technical Approach Document for Risk Evaluation (Volume 1-6).

Land within 0.25 mile of SWMU B-8 is classified as “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 there are two inactive water supply wells (Wells 16 and D). The nearest residential area is approximately 4,000 feet to the west of SWMU B-8, and Fair Oaks Elementary School is over one mile from the site.

A small herd of cattle maintained on CSSA by the USDA-ARC roam freely throughout selected areas of the North Pasture. In addition, wild game species, including white-tailed deer, axis deer, and wild turkey, roam freely throughout CSSA. A map of deer hunting stands which overlook mechanical feeders and planted food plots is shown in Figure 5.2 of the Technical Approach Document for Risk Evaluation. SWMU B-8 is located within an area where shotgun hunting is allowed, and other hunting is allowed in the surrounding area. The closest deer blind (#34) is approximately 1,500 feet northeast of SWMU B-8.

The nearest potential habitats for local endangered species (Volume 1-1, Background Information Report, Figure 11) are 600 feet to the northwest (Black-Capped Vireo) and 1,800 feet to the north (Golden-Cheeked Warbler).

1.3 - Previous Investigations

On February 27 and 28, 1995, an EM survey was performed using a Geonics EM-31 instrument along north-south transects spaced at 25-foot intervals at SWMU B-8. The dimensions of the surveyed area were 350 feet long by 250 feet wide. The EM conductivity and in-phase contour maps are shown on Figure 3.2 and Figure 3.3 of the Technical Memorandum on Geophysical Surveys (Parsons ES, 1995c). An EM anomaly was detected to the southwest of the site. However, this anomaly is associated with an abandoned underground 4-inch diameter pipe trending northeast-southwest. This metal pipe continues southwest of the site toward Well 16. The pipe is broken and exposed in certain places outside the surveyed area.

One anomaly suspected of being associated with past waste management activities was identified at the site. This anomaly, identified as “A” on Figure 3.4 of the Technical Memorandum on Geophysical Surveys, is more pronounced on the in-phase contour map, and therefore, is suspected of being associated with buried metal debris. At the time of the survey, there was no metal debris at the burn area's ground surface that may have caused electromagnetic interference.

No other previous environmental investigations have been performed at this site.

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-8 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-8) in accordance with the former RRR was sent to the TNRCC on July 12, 1999. 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 COPCs for SWMU B-8 are VOCs, explosives, and metals, the cleanup levels should be the RLs for VOCs and explosives, and the background levels for metals. Chlorinated VOCs and explosives are man-made chemicals, and rarely occur naturally. Background metals levels were statistically calculated for soil and the Glen Rose Limestone, and are reported in the Second Revision to the Evaluation of Background Metals Concentrations in Soils and Bedrock (Parsons ES, February 2002).

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