2002 Community Relations Plan Section 5 - Past Community Relations Activities

CSSA maintains good relations with the surrounding community. As part of CSSA�s community relations efforts, 13 people were interviewed and their responses reported in the August 1999 CRP. An initial public meeting (Section 5.7) was held in October 2001 and numerous fact sheets (Section 5.4) were prepared and distributed to persons on the CSSA mailing list (Section 5.5) as part of CSSA�s public information program. Additional information on the interview responses from August 1999 and the initial CRP is located in Volume 1, Other Plans and Approaches, behind the Community Relations Plan tab, in Section 5. The initial CRP was implemented in August 1999 and is superseded by this update. The following activities were conducted to promote CSSA�s CRP.

Since the CRP of August 1999, CSSA has maintained an Administrative Record for its environmental program (the Environmental Encyclopedia) at the main branch of the San Antonio Library, 600 Soledad Plaza, San Antonio, TX 78205. A copy of the administrative record is also maintained at the TCEQ Region 13 offices at 14250 Judson Rd., San Antonio, TX and at the CSSA Environmental Office and has been made available to the public on an internet website (www.stanley.army.mil). The administrative record contains copies of all plans and reports submitted to regulators, meeting minutes from all technical progress meetings, and key correspondence between CSSA and the regulatory agencies.

In July 2001, CSSA created its Off-post Monitoring Response Plan (the Plan). The Plan was revised in June 2002. The purpose of the Plan is to:

The Plan describes the well access agreements signed by off-post well owners before sampling of their well, and describes sampling procedures and laboratory analytical methods. As of September 2002, the contaminants of concern (COCs) identified in off-post wells have been VOCs (such as 1,2-DCE,etc.), PCE and TCE. The action levels for VOCs are based on MCLs established by the EPA under the Safe Drinking Water Act. The Plan sets out the following guidelines for action by CSSA dependent upon laboratory analytical results:

When off-post public supply systems are adversely impacted, CSSA will cooperate and coordinate solutions to the maximum extent practicable. As required by the Order, a Water Well Survey Report (Parsons, August 2001) identified and located both privately and publicly-owned groundwater wells within ��mile of CSSA. The Water Well Survey Report is located in the Environmental Encyclopedia in Volume 5-2, Groundwater Investigation. Beginning in September 2001, CSSA began quarterly sampling of selected off-post public and private water wells. Quarterly off-post groundwater monitoring events have been conducted in September and December 2001, March and June 2002, and will continue to be conducted on a quarterly basis in the foreseeable future. A report presenting analytical results for each event is located in the Environmental Encyclopedia in Volume 5-1, Groundwater, behind the Off-post Groundwater Monitoring tab. Based on the laboratory analytical results obtained from each sampling event and the requirements of the Plan, CSSA responded to community concerns and needs for various environmental activities in accordance with the CRP.

CSSA began sampling of off-post well LS-7 in December 1999. In March 2000, sampling of LS-7 reported PCE and TCE at concentrations of 2.87 mg/L and 0.5 mg/L, respectively. These detections were above the laboratory reporting limit but below the applicable MCL. By June 2001, the PCE concentration reported in off-post well LS-7 increased to 4.0 �g/L. Based on linear regression statistics using the limited number of data points collected to date, CSSA installed a granular activated carbon (GAC) treatment system on August 7, 2001. In August 2001, The PCE level in LS-6, which measured 6.5 mg/L, was the first measured exceedance of the MCL of all off-post samples tested. Based on this finding, CSSA immediately provided bottled water to residents using LS-6 and installed a GAC filtration system on August 15, 2001, in accordance with the Plan.

In September 2001, PCE and TCE levels in RFR-10, which were reported at 14.0 and 7.5 mg/L, respectively, in exceedance of the MCLs of both compounds (5.0 mg/L). Based on these findings, CSSA immediately provided bottled water to residents using RFR-10 and installed a GAC filtration system on October 9, 2001. In October 2001, wells RFR-11 and OFR-3 were sampled for the first time due to concentrations detected in RFR-10. RFR-11 had concentrations of PCE at 16.0 mg/L and TCE at 0.35 mg/L, PCE exceeding the MCL of 5.0 mg/L. CSSA immediately provided bottled water to residents using RFR-11 and installed a GAC filtration system on October 16, 2001. In March 2002, the PCE and TCE concentrations in well OFR-3 were 12.15 and 5.70 mg/L, respectively. CSSA immediately provided bottled water to residents using OFR-3 and installed a GAC filtration system in April 2002.

In the December 2001 sampling event, increasing concentration trends approaching the MCL for PCE in two public supply wells, LS-2 and LS-3, were identified. PCE and TCE were present in distribution system entry point samples. Evidence of increasing concentrations, potential exposure to a large group of people, and good faith, CSSA began the installation of a GAC treatment system for these wells, which was completed in April 2002. This installation was coordinated with Bexar Metropolitan Water District, the operator of the public supply wells.

Operation and maintenance (O&M) of the GAC treatment systems are performed by CSSA on a monthly basis and every six months by Carbonair, the company that supplies the activated carbon filtration systems and replacement filters. Pre- and post-GAC samples have been routinely collected during the quarterly sampling events from each well with a GAC installed. Post-GAC sample results indicate that all GAC treatment systems are effectively reducing or eliminating contaminants from the respective wells. As of September 2002, there have been no reported detections of VOCs from any of the post-GAC sample results. The GAC systems will continue to be maintained at no cost to private well owners for the foreseeable future. Off-post wells with VOC detections above MCLs will continue to be sampled and monitored on a quarterly basis until results meet CSSA�s Off-post Groundwater Monitoring Plan requirements of four consecutive quarterly events with no detection of contaminants.

An initial newsletter and various fact sheets were distributed to residents in the area of CSSA. An initial mailing to the public in December 1999 was intended to gauge public interest in CSSA�s environmental program and create an initial mailing list. In October 2000, CSSA provided responses to questions submitted by the public. A Congressional Fact Sheet was generated in July 2001. Fact Sheets 1 and 2 were distributed in August 2001, with Fact Sheet 1 including a general introduction to CSSA. The Congressional Fact Sheet, along with Fact Sheets 1 and 2, served as an introductory notice to the community regarding CSSA�s environmental program. Fact Sheet 2 addressed the contamination history, contamination sources, remediation plans, and groundwater monitoring program at CSSA. Fact Sheets 3 and 4 were distributed in October 2001 through the mailing list and were made available to the public at the public meetings. Fact Sheet 3 presented an overview of the groundwater sampling conducted from August 2000 through August 2001, including both selected on-post wells and off-post wells. Fact Sheet 3 presented specific information on the plume 1 area in the central region of CSSA. Fact Sheet 4 presented information on the off-post wells sampled from August 2000 through August 2001 and discussed the plume 2 area at the southwest corner of CSSA and the source area identified at AOC-65.

Fact Sheets 5 and 6 were distributed in February and April 2002, respectively. Fact Sheet 5 presented results of sampling conducted in September and October 2001 for off-post wells. Fact Sheet 5 was also provided in an electronic version to the President of the homeowners association of the Dominion subdivision. The association then forwarded the fact sheet to the members of the homeowners association in their newsletter. Fact Sheet 6 presented results from the December 2001 sampling event during which 20 off-post wells were sampled. Fact Sheet 6 also presented additional information on site investigation and cleanup associated with SWMU B-3 and SWMU O-1. Information on the AOC 65 geophysical surveys and future installation of a soil vapor extraction system at AOC 65 were also described in Fact Sheet 6.

Fact Sheet 7 was issued in May 2002 presenting results from the March 2002 on-post and off-post groundwater sampling events. Fact Sheets 8 and 9 were mailed in September 2002 providing detailed information on the on-post and off-post groundwater monitoring events conducted in June 2002 and describing the Environmental Encyclopedia and where to access the Encyclopedia. Fact Sheet 10 was issued in October 2002 presenting the cleanup and removal activities ongoing at SWMU B-3 and AOC-65. See Table 5.4 Additional fact sheets will continue to be prepared and distributed by U.S. Mail and e-mail to present results of future sampling events and/or cleanup activities at CSSA.

The initial mailing list for fact sheets and newsletters was created based on responses to the December 1999 postcard mailout from CSSA. In addition, the mailing list included media representatives, city and county officials, state and federal agencies, and key regulatory officials. Newspaper notices also invited community members to be added to the mailing list. Following each newsletter or fact sheet mail out, the mailing list was edited as appropriate based on forwarding order notices or returned mail items. The current version of the mailing list contains approximately 2,700 names and/or resident addresses.

The contact person in the newsletters and fact sheets was listed as LTC Jason D. Shirley, CSSA Commander, 25800 Ralph Fair Road, Boerne, Texas 78015, telephone: (210) 698-5208. The PAO from Fort Sam Houston, Mr. Phil Reidinger, supported LTC Shirley in responding to inquiries from the public and statements to various media. LTC Shirley and PAO responded to requests for information from community members in person at public meetings and from telephone requests. LTC Shirley attended meetings with local City and Homeowner Association boards and presented information on CSSA�s environmental program. Various citizen comments by telephone or correspondence to LTC Shirley have been responded to. Citizens who submitted written questions at the October 2001 public meetings received responses to their questions/comments.

Fact Sheet	Title	Subject	Date Issued
1	CSSA�s Environmental Program	CSSA�s mission, history, local geology, the environmental program, and environmental compliance issues at CSSA.	August 2001
2	CSSA�s Soil and Groundwater Contamination	Contamination history, contamination sources, future remediation plans, and groundwater monitoring program at CSSA.	August 2001
3	Groundwater Contamination � Plume 1	Groundwater sampling conducted from August 2000 through August 2001, including on-post wells and off-post wells. Discussed the central CSSA area, SWMU B-3 and SWMU O-1.	October 2001
4	Groundwater Contamination � Plume 2	Groundwater sampling conducted from August 2000 through August 2001 and specific information on the source area identified at AOC-65.	October 2001
5	Groundwater Contamination - September and October 2001 Sampling	September and October 2001 sampling results for on-post and off-post wells.	February 2002
6	Groundwater Contamination - December 2001 Sampling	December 2001 sampling results for 20 off-post wells and on-post wells.	April 2002
7	Groundwater Contamination - March 2002 Sampling	March 2002 sampling results for on-post and off-post wells.	May 2002
8	Groundwater Contamination - June 2002 Sampling	June 2002 sampling results for on-post and off-post wells.	September 2002
9	Environmental Program Information	Description of the Environmental Encyclopedia, its contents and format and where to access the hard copy and/or the internet website.	September 2002
10	Cleanup Activities at SWMU B-3 and AOC-65	Overview of cleanup activities conducted and remediation systems installed through October 2002 at SWMU B-3 and AOC-65	October 2002

CSSA hosted two public meetings the first week of October 2001. CSSA coordinated with Leon Springs Elementary School and Fair Oaks Elementary School to present open houses in the school cafeterias on Monday October 1, 2001 from 6:00 to 8:00 pm and again on Thursday October 4, 2001, from 6:00 to 8:00 pm. Five poster exhibits were displayed with technical staff from Parsons manning the displays at various booths. The meetings were conducted in an open forum, with members of the public able to view presentation materials describing CSSA�s activities and ask questions directly of technical staff. Representatives from EPA and TCEQ, as well as Bexar Metropolitan Water District and the San Antonio Metropolitan Health District were also available to discuss issues specific to concerns raised by those in attendance. Postcard notices for the two scheduled public meetings were distributed to all residents on the mailing list and by public notices in local newspapers. CSSA received written questions from members of the public during the public meetings and developed responses. Members of the public asking to be placed on the mailing list for future fact sheets and meeting notifications were added.

CSSA again hosted public meetings in October 2002. Preparations for the October 2002 public meetings began with a risk communication training session on September 23 and 24, 2002, for the public meeting participants. The training session was attended by personnel from AFCEE, San Antonio Metropolitan Health District, Bexar Metropolitan Water District, CSSA, Foster Wheeler Corporation, Fort Sam Houston Public Affairs, and Parsons at the CSSA Environmental Office. Training was provided by Fulton Communications.

On October 8 and 9, 2002 CSSA conducted public meetings to present results from the investigations and the status of the environmental program to the members of the local community. On the evening of October 8, a meeting was held at Leon Springs Elementary School, and on the evening of October 9, a meeting was held at Fair Oaks Ranch Elementary School. Public attendance for both meetings was minimal. The low public turnout for the meetings in 2002 may suggest that the community concerns are being effectively addressed by the proactive approach CSSA has taken to address off-post environmental concerns and CSSA�s community relations program set out in this CRP Update report.

	Confirm area drinking water meets EPA and TCEQ standards;
	Determine the lateral and vertical extent of contamination released from CSSA;
	Identify any potential off-post source areas of groundwater contamination;
	Provide the framework to monitor off-post water wells located downgradient of known source areas and within proximity to CSSA; and
	Provide action levels and Army response guidance when off-post ground water contamination is encountered.�

	If VOC concentrations are greater than or equal to 90 percent of the MCL (4.5 ppb for PCE and TCE) and the well is used as a potable water source, bottled water will be supplied within 24 hours. A confirmation sample will be collected from the well. Re-sampling will take place within 14 days of the receipt of the final validated analytical report. If the follow-up sampling confirms COCs above 90% of the MCLs, the residence or supply well will be evaluated and CSSA will determine an appropriate method for wellhead treatment; or, connection to an alternative water source will be selected if CSSA deems it feasible as the preferred alternative. Cost related to installation and maintenance of wellhead treatment equipment or connection to an alternative water source will be borne by the U.S. Army.
	If VOC contaminant levels are ≥80 percent of the MCL during any single monitoring event based on preliminary data from the laboratory (4.0 ppb for PCE and TCE) and the well is used as a potable water source, it will be monitored monthly. If the follow-up sampling confirms COCs are ≥80 percent of the MCL, it will be re-sampled until the level falls below the 80 percent value. Should the value be ≥90 percent of the MCL, see previous bullet. If any VOC COC is detected at levels greater than the MDL for SW846 Method 8260 (historically 0.11 ppb for PCE, 0.14 ppb TCE), the well will be re-sampled on a quarterly basis. This sampling will be completed in concert with on-post sampling events and will be used to develop historical trends in the area. Quarterly sampling will continue for a minimum of 1 year, after which the sampling frequency will be reviewed and possibly decreased with the concurrence of EPA and TCEQ.
	If VOCs are not detected during the initial sampling event, (i.e., no VOC contaminant levels above the MDL), further sampling of the well will be considered on an as needed basis. Future sampling of such a well may be required to evaluate potential seasonal variation in contaminant trends. The well owner, EPA, and TCEQ will be apprised of any re-sampling decisions regarding non-detect wells.