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SWMU B-9 Final RCRA Facility Investigation/Closure Report

Section 3 - Conclusions and Recommendations

3.1 - Conclusions

SWMU B-9 was suspected to be a miscellaneous solid waste (metal debris) disposal area.  EM and GPR geophysical surveys conducted in November 1999 revealed no geophysical anomalies that were potentially related to past waste management activities.  A soil boring investigation was completed in March 2000 to verify the presence or absence of VOCs, SVOCs, metals, and explosives.  Three soil borings were completed to depths ranging from six to eight feet.  Three soil/rock samples were collected from each boring, resulting in a total of nine samples submitted for analysis. 

Analytical data gathered during this investigation indicated concentrations of zinc, mercury, dichlorodifluoromethane, methylene chloride, and toluene present in the subsurface soils slightly above RRS1 soil/rock background levels.  Background levels for metals 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 at CSSA (Parsons, February 2002).  The sample quantitation limit (SQL) was used as the RRS1 levels for VOCs, SVOCs, and explosives.

Zinc was detected above RRS1 criteria in two samples; however, both concentrations were below the Texas-specific median background level for zinc of 30 mg/kg (30 TAC 350.51(m)).  Mercury (0.2 mg/kg) exceeded the RRS1 level (0.1 mg/kg) in one limestone bedrock sample collected at a depth of 7.5 to 8 feet bgs.  This one slight exceedance at this depth is not considered to be a threat to human health or the environment.  Furthermore, mercury was not detected above the reporting limit in any of the other site samples.

The analyte dichlorodifluoromethane, a chemical primarily used in refrigeration and cooling systems, is not associated with any waste management activities at CSSA.  Low levels of dichlorodifluoromethane were detected in eight of the nine samples at SWMU B-9, and it was detected in all of the other soil samples collected at another site (SWMU B-23) that same day.  Dichlorodifluoromethane was not detected in any of the samples collected at SWMU B-23 the previous day.  It is suspected that the low level detections of this analyte at SWMUs B-9 and B-23 are a result of contamination at the analyzing laboratory.  The low level detection of methylene chloride (0.0055 mg/kg) in one sample is also suspected of being associated with laboratory contamination.

Toluene was detected at a very low concentration (0.0074 mg/kg) in only one surface soil sample. 

3.2 - Evaluation of Data Quality Objectives Attainment

All data generated during the SWMU B-9 investigation were reviewed to confirm conformance with the AFCEE QAPP; and the data verification reports are included in Appendix C.  All data are considered useable for site characterization purposes.  Although several results are flagged with an “M”, these results are considered usable because the matrix interference is minimal and does significantly affect the sample results.  Although several results are flagged with a “J”, these results are considered usable because the estimation of quantitation does not significantly affect the sample results. 

Overall DQOs for the investigations at CSSA are provided in Volume 1-1 behind the RFI Addendum tab (Section 11 of the Work Plan Overview).  A detailed list of DQOs for SWMU B-9, along with an evaluation of whether each DQO has been attained, is provided in Appendix D.  As described in Section 1, the main objectives of the SWMU B-9 investigation are to determine if the site meets TNRCC requirements for RRS1 closure and to meet requirements of the 3008(h) Administrative Consent Order.

3.3 - Recommendations

    Because exceedances of RRS1/background criteria were very slight, and geophysical survey results did not show evidence of buried waste, RRS1 closure is recommended for this site. 

3.4 - Certification

Partial Facility Closure Certification

SWMU B-9

Department of the Army

Camp Stanley Storage Activity

Boerne, Texas

I certify that the above-described closure was performed under my direction, in accordance with the work plan and 30 TAC §335 Subpart S, and as described in this report, and that, to the best of my knowledge and belief, said closure has been successfully accomplished.

  Jason D. Shirley

 

  October 9, 2002

LTC Jason D. Shirley

Commander, Camp Stanley Storage Activity

 

Date

  Kirk W. Lawson

 

  September 27, 2002

Kirk W. Lawson, P.E.

State of Texas #79204

Parsons

 

Date