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SWMU B-9 Final RCRA Facility Investigation/Closure Report

Section 1 - Introduction

On May 5, 1999, an Administrative Consent Order was issued to Camp Stanley Storage Activity (CSSA) pursuant to §3008(h) of the Safe Drinking Water Act (SDWA), as amended by Resource Conservation and Recovery Act (RCRA), and further amended by Hazardous and Solid Waste Act (HSWA) of 1984.  In accordance with the RCRA Facility Investigation (RFI) requirements of the Consent Order, this report has been prepared to document the environmental condition and site closure requirements of Solid Waste Management Unit (SWMU) B-9 and to recommend further investigation, if necessary, or to provide documentation necessary for site closure.  The primary objective of the SWMU B-9 investigation is to determine if the site meets Texas Commission on Environmental Quality (TCEQ, formerly Texas Natural Resource Conservation Commission [TNRCC]) requirements for closure, as described in Section 1.4, and to meet the requirements of the consent order.

This specific RFI was performed by Parsons under the U.S. Air Force Air Mobility Command (AMC) Contract F11623-94-D-0024, Delivery Orders (DOs) RL17 and RL53, and Air Education and Training Command (AETC) Contract F41689-96-D-0710, DO 5068.  Air Force Center for Environmental Excellence (AFCEE) provided technical oversight for the DOs.  Based upon the project Statement of Work (SOW), a set of work plans was established to govern the fieldwork.  These include:

Work Plan Overview           (Volume 1-1);

Site-Specific Work Plan       (Volume 1-2, SWMU B-9);

Field Sampling Plan (FSP)    (Volume 1-4, RL53 Addendum); and

Health and Safety Plan (HSP) (Volume 1-5, RL53 Addendum).

For this report, Section 1 provides the site-specific background, environmental setting, description of previous site investigations, and closure standard.  Section 2 describes field actions and the closure evaluations.  Section 3 summarizes the findings, evaluates attainment of data quality objectives (DQOs), provides recommendations, and certifies the site closure, if applicable.  References cited in this report can be found in the Bibliography (Volume 1-1, 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-9

1.1.2.1    Site Description

Based on historical records, SWMU B-9 was used to dispose of miscellaneous solid waste material.  SWMU B-9 covers approximately 0.25-acres and is approximately 150 feet long (northeast-southwest) by 50 feet wide (northwest-southeast).  The site is covered with rocks and native vegetation.  The only evidence of contamination observed during the investigation was a minor amount of small metal fragments found on the ground surface at the site.  No activities are currently conducted at SWMU B-9.  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-9).  Volume 1-2 includes a Chronology of Actions and a Site-Specific Work Plan Addendum for SWMU B-9.

1.1.2.2    Potential Sources of Contamination

Historical records review indicates that SWMU B-9 was used as a disposal area for miscellaneous solid waste (metal debris) (Parsons ES, 1993b).  Exact dates of this use of the site are unknown.

Possible contamination includes metal debris from the solid metal waste (metals), explosive residue from unexploded ordnance (UXO), and volatile and semivolatile organic compounds (VOCs and SVOCs) contamination from the possibility of solvent disposal and trash burning. 

1.1.2.3    Site Location

SWMU B-9 is a 0.25-acre tract that is located in the southern portion of the east pasture (Volume 1-2, Site Location Map).  The SWMU is approximately 900 feet from the nearest facility boundary to the south.  The site is located within Area of Concern (AOC)-51 and immediately south of AOC-44.  SWMU B-9 and the land immediately surrounding it are undeveloped (Figure B9-1).

1.2       Site Environmental Setting

1.2.1    Site Soils and Topography

Soils present at SWMU B-9 are classified as Brackett Soils.  Brackett Soils occur on over 12.8 percent of CSSA lands.  The soils cover a large portion of the East Pasture and the Inner Cantonment at CSSA.  These soils occur on slopes of 12 to 30 percent, such as those found on Steele, McFarland, and Schasse Hills, as well as Taylor Ridge.  These loamy and clayey soils are very shallow (about four inches thick), grayish-brown, and strongly calcareous.  Lying within and on the surface layer are gravel and cobblestones up to six inches in diameter.  The soils develop over soft limestone and are underlain by hard limestone.  The hills associated with Brackett soils are steep, cone-shaped hills with saddles between them.  The soils are nonarable and best suited to native grasses (United States Department of Agriculture [USDA], 1991).  Detailed descriptions of the CSSA soil types are provided in the CSSA Environmental Encyclopedia (Volume 1-1, Background Information Report, Soils and Geology).  Bedrock outcrops at the surface throughout SWMU B-9 and the remainder of the surface is covered by a very thin soil profile (approximately 0.5 feet).

SWMU B-9 lies just northwest of an area with steep topographic relief in the extreme southeastern portion of CSSA (Figure B9-2).  The elevation of the site is approximately 1,220 feet above sea level, sloping (eight percent grade) to the northwest.  The site is approximately 250 feet southwest of a small valley that dissects the steeper relief.

1.2.2    Geology

The Upper Glen Rose is the uppermost geologic stratum in the area of SWMU B-9 and the East Pasture (Figure B9-3).  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 varies up to 150 feet in thickness.  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 upward 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 approximately 60 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 two known major fault (shatter) zones at CSSA: the North Fault Zone and the South Fault Zone.  SWMU B-9 is located south of both the North and South Fault Zones.  Additional information on structural geology at CSSA can be found in the Environmental Encyclopedia (Volume 1-1, Background Information Report, Soils and Geology).  Boring logs from the soil borings drilled in March 2000 indicate that limestone was encountered at shallow depths below SWMU B-9, averaging 0.5 foot below ground surface (bgs).  

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 of differing static water levels 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 Middle Trinity aquifer is separated from the lower Trinity Aquifer by the Hammett Shale, which is an aquitard and is not considered to be part of either the Middle or Lower Trinity Aquifer.  The Lower Glen Rose Limestone outcrops north of CSSA along Cibolo Creek and within drainage ways located in 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.  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 gallons per day per foot (gpd/ft) (Ashworth, 1983).  In general, groundwater at CSSA flows in a north to south direction.  However, local flow gradients may vary depending on rainfall, recharge, and possibly well pumping.

No site–specific information regarding groundwater is available.  However, the nearest well, Well CS-1, which is an active drinking water supply well, is located approximately 2,300 feet southeast of SWMU B-9.  Between January 1997 and March 2000, static water levels have ranged from approximately 101 to 262 feet below top of casing. 

The nearest surface water feature, located 550 feet to the northwest, is a man-made intermittent tributary of Salado Creek.  The tributary trends northwest-southwest along the southern flank of East Pasture firing range berm and intersects the main stream of Salado Creek approximately 2,500 feet southwest of the site (Figure B9-1).

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.  Cultural resources are located within the site area of SWMU B-9.  The cultural resource consists of World War I trenches and foxholes.  The trenches surround the site on the north and northeast side.  The foxholes are located along the ridgeline just to the south-southeast of the site.

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 on 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).

A small herd of cattle is maintained on CSSA by the USDA-ARC.  The cattle roam freely 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 Figure 5.2 of the Technical Approach Document for Risk Evaluation (Volume 1-6).  In addition to managed wild game species, migratory birds, fowl, and indigenous small game are also hunted in designated areas.  SWMU B-9 is located approximately 200 feet south of hunting stand number 45.  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.

Within CSSA, there is a full-time work force of approximately 100 persons working in shops and office buildings.  Personnel also work outdoors throughout the facility to perform activities such as road and fence maintenance, brush clearing, and security patrols.  Approximately 25 people, including children, occupy seven residences on the CSSA facility.

SWMU B-9 is located within the local endangered species habitat of the Golden-cheeked Warbler.  Another potential habitat for the local endangered species of the Black-capped Vireo is located approximately 600 feet north-northwest of the site (Volume 1-1, Background Information Report, Figure 11).  The vegetation at the site consists of native grasses and scattered oak trees. 

1.3 - Previous Investigations

No previous investigations have been performed at SWMU B-9.  The site was identified during the 1993 Environmental Assessment.

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-9 under the Risk Reduction Rule (RRR) (30 Texas Administrative Code [TAC] §335).  If the site concentrations do not exceed background, then the site will be closed using Risk Reduction Standard 1 (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 Texas Risk Reduction Program (TRRP).  A notification of intent to close sites identified to date (including B-9) in accordance with the former RRR 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 contaminants of concern (COCs) for SWMU B-9 are VOCs, SVOCs, metals, and explosives the RRS1 standards should be the reporting limits (RLs) for VOCs, SVOCs, and explosives, 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 Soil Types (Parsons, February 2002).  TNRCC approved the background evaluation on April 23, 2002.

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