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SWMU I-1 RCRA Facility Investigation Report
Section 3 - Conclusions and Recommendations
As described in section 1, SWMU I-1 consists of Building 294 and its immediate surroundings. Building 294 contains an incinerator that was used to burn paper trash from 1943 to the late 1960s. Electrical transformers were also stored in the building during the late 1980s. Due to the waste management and storage activities at SWMU I-1, COCs include VOCs, metals, dioxins and furans, and PCBs.Work to characterize possible soil contamination at SWMU I-1 has been performed
under two projects. The original
work plan was drafted and approved during February 1996. A geophysical survey and soil gas survey
were completed at the site area under RL17 during March and August of 1996,
respectively. During March 1998, an
addendum to work plan was submitted and approved. Subsequently, soil borings were advanced in March 2000,
surface soil samples were collected in April 2000, and a surface wipe sample was
collected from inside the incinerator in Building 294 in April 2001.
Results of investigations indicate that there have been no significant releases of COCs to the surrounding area of Building 294 (SWMU I-1). However, because of the dioxin.furan detections the site will not meet RRS1 standards, and further remedial actions must be performed at the site.
3.2 - Evaluation of Data Quality Objectives Attainment
DQOs are quantitative statements developed during the DQO process to clarify the study objectives, define the most appropriate type of data to collect, determine the most appropriate conditions from which to collect the data, and specify tolerable limits on decision errors which will be used as the basis for establishing the quantity and quality of data needed to support the decision (EPA, 1994). The AFCEE QAPP defines DQOs as statements that specify the data type, quality, quantity, and uses needed to make decisions; these statements are the basis for designing data collection activities (AFCEE, 1998).Overall DQOs for the investigations at CSSA are provided in Volume 1-1 behind the RFI Addendum tab (Section 11). Appendix D identifies the DQOs for CSSA and how they are applicable to the investigation at SWMU I-1, along with an evaluation of whether each DQO has been attained. Several of the DQOs are met by documentation that is found in other parts of the encyclopedia, and not necessarily in this report. Where this is true, the appropriate reference is provided. The objectives listed in the table also reference appropriate sections of the Order.
The primary objective of the SWMU I-1 investigation is to determine if the site has had any releases of contaminants to the surrounding environment. Analytical results indicated the presence of eight metals and one VOC that are above applicable RRS1 criteria. These detected compounds are confined to I1-SB01 and I1-SB02. The sampling at SWMU I-1 was biased toward areas likely to have contributing sources for soil contamination. The sampling regime is therefore considered complete.The results of the analysis of I1-SB01 and I1-SB02 indicate that there have been no significant releases of contaminants to the surrounding soil from SWMU I-1. The dichlorodifluoromethane in I1-SB01 is a common laboratory contaminant and was not identified in any other sample. Sample I1-SB02 reportedly contained eight metals at concentrations above background. Since the two soil samples that were collected from above the Glen Rose Limestone were below background levels, a release most likely did not occur. The elevated levels of metals in the I1-SB02 sample are therefore probably due to natural heterogeneity in the Glen Rose Limestone.
The presence of dioxins and furans in the surface wipe sample was not unexpected. However, the levels at which they were quantified does not warrant investigation of their presence within the surrounding media. Although there is no TCEQ standard for dioxins and furans, the levels within the incinerator are extremely low and do not suggest that the surrounding soil would be affected. Therefore, no additional samples of the soil matrix surrounding Building 294 are warranted.CSSA currently plans to close SWMU I-1 under RRS1. It is recommended that Building 294 undergo decontamination by pressure washing all parts of the building to remove any remaining waste residues. Collection of rinsate samples from the final rinse of the entire interior of the building for analysis of dioxins and furans are recommended to show that all residues have been removed thus meeting RRS1 closure criteria.