[Table of Contents]

SWMU Demo Dud Area (DD) Area Closure Report

Section 3 - Conclusions and Closure Certification

3.1 - Conclusions

RFI investigation results for SWMU DD Area indicated the presence of various waste material and elevated metals concentrations. Records regarding past historic use of this site are not available, but investigation results indicate this area was used for disposal of metal scrap and UXO. UXO removal activities were performed in May 1997 by UXO specialists. The UXO removal actions resulted in the removal of 240 UXO items and approximately 10,040 pounds of metal scrap, and the stockpiling of 600 cubic yards of sifted soil. The stockpiled soil was characterized and disposed with soils generated during the closure excavation activities.

During the RFI, copper, lead, mercury, zinc, and toluene were detected above CSSA background concentrations or RLs in one or more soil samples. Excavation activities were conducted at the site to remove all remaining waste and restore the site to RRS1.

As described in Section 2, several samples were collected during closure activities at the SWMU DD Area. Any sample locations where COCs were reported above RRS1 limits were overexcavated and resampled. As a result of overexcavation, only one result for lead (DD‑SW21), mercury (DD‑SW02), and di‑n‑butylphthalate (DD‑BOT01) exceeded RRS1 limits.

Employing statistical analyses under 30 TAC 334.443(d)(2), site wide lead, mercury, and di‑n‑butylphthalate results were determined to be below the 95 percent upper confidence limit. Therefore, all analytical results at the site meet RRS1 criteria and it is recommended that the site be closed under RRS1.

3.2 - Evaluation of Data Quality Objectives Attainment

Overall DQOs for investigations at CSSA are provided in Volume 1‑1, RFI Addendum (Section 11 of the Work Plan Overview). A detailed list of DQOs for the SWMU DD Area, along with an evaluation of whether each DQO has been attained, is provided in Appendix C.

As described in Section 1, the main objectives of the SWMU DD Area investigation are to determine if the site meets TCEQ requirements for RRS1 closure and to meet requirements of the 3008(h) Administrative Consent Order.

All data generated during the SWMU DD Area investigation were reviewed to confirm conformance with the AFCEE QAPP. The results can be found in Appendix D, and the data verification reports are included in Appendix E. All data are considered useable for site characterization purposes.

3.3 - Closure Certification

Partial Facility Closure Certification

Solid Waste Management Unit DD Area

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


January 20, 2005

LTC Jason D. Shirley

Commander, Camp Stanley Storage Activity



Kirk W. Lawson


January 11, 2005

Kirk W. Lawson, P.E.

State of Texas #79204




Julie Burdey, P.G.


January 11, 2005

Julie Burdey, P.G.

State of Texas #1913